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The Department of State’s Bureau of International Narcotics and Law Enforcement Affairs (INL) manages US. participation in many multilateral anti-corruption political and legal initiatives at the global and regional level. INL also funds and coordinates significant efforts to assist countries with combating corruption through legal reform, training, and other capacity-building efforts. Inquiries about the US. government’s general anti-corruption efforts and implementation of global and regional anti-corruption ini- tiatives may be directed to INL on its website, http://www. state.gov/j/inl/c/crime/corr/index.htm, or by email to: anticorruption@state.gov. In addition, the US. Agency for International Development (USAID) has developed several anti-corruption programs and publications, information about which can be found at hetp://www.usaid.gov/what- we-do/democracy-human-rights-and-governance/promot- ing-accountability-transparency. Finally, the Department of State’s brochure “Fighting Global Corruption: Business Risk Management,” available at http://www.oge.doc.gov/pdfs/ Fighting Global_Corruption.pdf, provides guidance about corporate compliance programs as well as international anti- corruption initiatives. International Landscape: Global Anti- Corruption Efforts In recent years, there has been a growing interna- tional consensus that corruption must be combated, and the United States and other countries are parties to a number of international anti-corruption conventions. Under these conventions, countries that are parties undertake commit- ments to adopt a range of preventive and criminal law mea- sures to combat corruption. The conventions incorporate review processes that allow the United States to monitor other countries to ensure that they are meeting their inter- national obligations. Likewise, these processes in turn permit other parties to monitor the United States’ anti-corruption laws and enforcement to ensure that such enforcement and legal frameworks are consistent with the United States’ treaty obligations.” US. officials regularly address the subject of corruption with our foreign counterparts to raise awareness of the importance of fighting corruption and urge stronger enforcement of anti-corruption laws and policies. OECD Working Group on Bribery and the Anti- Bribery Convention The OECD was founded in 1961 to stimulate eco- nomic progress and world trade. As noted, the Anti-Bribery Convention requires its parties to criminalize the bribery of foreign public officials in international business transac- tions.*! As of November 1, 2012, there were 39 parties to the Anti-Bribery Convention: 34 OECD member coun- tries (including the United States) and five non-OECD member countries (Argentina, Brazil, Bulgaria, the Russian Federation, and South Africa). All of these parties are also members of the OECD Working Group on Bribery (Working Group).” The Working Group is responsible for monitoring the implementation of the Anti-Bribery Convention, the 2009 Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions, and related instruments. Its mem- bers meet quarterly to review and monitor implementation of the Anti-Bribery Convention by member states around the world. Each party undergoes periodic peer review.” This peer-review monitoring system is conducted in three phases. The Phase 1 review includes an in-depth assess- ment of each country’s domestic laws implementing the Convention. The Phase 2 review examines the effectiveness of each country’s laws and anti-bribery efforts. The final phase is a permanent cycle of peer review (the first cycle of which is referred to as the Phase 3 review) that evaluates a country’s enforcement actions and results, as well as the country’s efforts to address weaknesses identified during the Phase 2 review. All of the monitoring reports for the par- ties to the Convention can be found on the OECD website and can be a useful resource about the foreign bribery laws of the OECD Working Group member countries.® The United States was one of the first countries to undergo all three phases of review. The reports and appen- dices can be found on DOJ’s and SEC’s websites.** In its HOUSE_OVERSIGHT_022509