by Kara Brockmeyer, Andrew M. Levine, Bruce E. Yannett, Ada Fernandez Johnson, and Katelyn McNelis
On November 26, 2021, the Organization for Economic Cooperation and Development (the “OECD”) published revised anti-corruption guidelines, the Recommendation for Further Combating Bribery of Foreign Officials (the “2021 Recommendation”). These guidelines update the original recommendation from 2009 and significantly expand the expectations of member countries regarding anti-corruption enforcement.