A lasting commitment to integrity: Why anti-corruption efforts remain crucial for businesses

Recent announcements from the current US administration about scaling back enforcement of the Foreign Corrupt Practices Act (FCPA) have created a defining moment for businesses worldwide. In the aftermath, numerous conversations with colleagues, legal experts, and businesses point to a clear consensus regarding the significance of these announcements. 

A critical crossroads 

This policy shift creates a key decision point for company management: continue doing the right thing and upholding standards of business conduct despite relaxed enforcement or break the law for short-term gain. The latter path, while potentially tempting, carries substantial risks that extend far beyond regulatory penalties. 

Why abandoning anti-corruption efforts remains dangerous 

Setting aside the corrosive societal impact of engaging in corruption, there are compelling reasons that make it unwise for companies to relax their anti-corruption efforts.  

1. Global regulatory landscape: the US Department of Justice is not the only regulator enforcing anti-corruption laws. One of the themes in international law over the last decade has been an ever-increasing number of anti-bribery laws, many of which have extraterritorial reach, encompassing acts of bribery and corruption beyond their country of origin.
2. Future liability: the FCPA remains on the books, and the statute of limitations for violations is five years, meaning companies could certainly face investigations and penalties under a new administration.
3. Irreparable reputational damage: investors and other partners know that doing business through corruption signals poor governance, false accounting, and weak ethics, all of which can come back to bite them were they to engage with such a company.  

The real decision: improve or slide back 

Companies face a choice between continuing to improve their corruption risk management or letting their approach slide. Stagnating, however, risks falling behind peers, failing to keep up with ever-changing risks, and potentially becoming mired in corruption, perhaps just in time for US enforcement to return. 

Benchmarking for improvement 

For the past decade, Transparency International UK has been working with companies committed to improvement through our Corporate Anti-Corruption Benchmark Service. This service has become essential for businesses across various sectors to assess, compare and improve their anti-bribery and corruption programs. 

Our Benchmark participants cover multiple sectors, including mining, energy, financial services, telecommunications and consumer goods. Feedback from participants has highlighted several areas of benefit that engaging in the Benchmark has brought them: 

1. Reflection and collaboration: Participants praise the process for ‘encouraging critical assessment and cross-team cooperation’.
2. Driving change: Participants find that the Benchmark ‘provides actionable insights and supports internal advocacy’ for improvements or increased resources.
3. Peer learning: Our quarterly workshops offer ‘valuable industry insights as well as practitioner networking opportunities’.
4. Comprehensive assessment: The Benchmark framework covers 30 key aspects of anti-corruption compliance and ‘continues to evolve with best practice’.
5. Objective comparisons: Our interactive dashboards provide ‘clear assessment against peers and support alignment with good practice’. 

Our 2025 Benchmark includes expert input from leading law firm Ropes and Gray, PwC UK’s and Grant Thornton UK’s Forensics teams, and a working group of participants including experienced practitioners from HSBC, Lloyds Bank, Santander UK, Vodafone, GSK and Johnson & Johnson.   

The business case for integrity 

In an era where the value of ethical business practices is not universally recognised, a firm commitment to anti-corruption efforts is vital. This is not merely because it’s prudent to comply with laws, but also because doing so demonstrates to all stakeholders that the company operates to high standards, and has a properly functioning business model, which doesn’t create unforced risks, and which can protect long-term success in the global market. 

The Corporate Anti-Corruption Benchmark Service is here to support businesses in their commitment to integrity and creates a space for participating companies to work towards excellence in compliance, while fostering a culture of ethical business. 

To  learn more about joining our benchmarking service, contact us at [email protected]