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International Anti-Corruption Law And Inchoate Bribery of Foreign
Officials: Liability of Officials; Corporations and their Intermediaries
Chitengi Sipho Justine is an advocate of the High Court for Zambia and an accomplished
researcher in the field of organised crimes law; in which field he is a practitioner, lecturerand currently reading for his PhD.
2010/12 Chitengi Sipho Justine (Advocate)
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In the dawning of globalisation, economic
crimes that used to be purviews for
domestic legislation have now become a
universal concern. For instance, the vice of
bribery (hereinafter referred to as the
vice) of foreign public officials
(hereinafter referred to as FPOs) in order
to obtain international business has
become an international issue. There has
since been a quickly burgeoning
internationalplethoraof cases perpetrating
and perpetuating the vice with the most
recent being the widely reported 11 March2011 U.S. cracks down on firms that pay
bribes to foreign officials. Indeed,
[F]ederal authorities are now prosecuting
businesses that try to win contracts by
making payments to officials of
government-owned businesses. Executives
of an Azusa company are among those
being tried.1
From the afore-mentioned, it wasestablished that one Nestor Moreno was
living pretty too large for a governmentofficial, director of operations for Mexico'snationalized electricity monopoly, when itwas found that he drove a $297,000 Ferrariand owned a $1.8-million yacht namedDream Seeker; purportedly acquired frombribes offered by the Azusa companyexecutives.
In response to such heinous activities,vices, the international community has
introduced stringent measures, including
1 http://articles.latimes.com/2011/mar/11/business/la-fi-
foreign-corrupt-20110311
criminalisation of the vice, as evidenced in
the proliferation of various international
and regional legal instruments. These
instruments constitute the international
anti-corruption legal regime (hereinafter
referred to as the regime) aimed at
fighting, inter alia, this vice.
This article provides a comprehensive legal
anatomy on the appellation with reference
to the regime and a critical engagement of
the relevant provisions of the following:
United Nations Convention Against
Corruption2 (hereinafter referred to as
UNCAC); Organisation for EconomicCooperation and Development:
Convention on Combating Bribery of
Foreign Public Officials in International
Business Transactions3 (hereinafter
referred to OECD Convention); African
Union Convention on Preventing and
Combating Corruption4 (hereinafter
referred to as AU Convention); and
Council of Europe: Criminal Law
Convention on Corruption5 (hereinafterreferred to as CoE Convention). The
article is categorically segmented into
three various broad parts under respective
headings as hereinafter proceeds:
When dealing with corruption as
perpetrated by international corporations
and government official at the
international scene, the following legalissues are very pertinent, inter alia, as both
prosecutors and defence counsel tend to
2 Entered into force on 10 January 20053 Entered into force on 15 February 19994 Adopted on 11 July 20035Entered into force on 1 July 2002
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institute full-scale litigation relying chiefly
on spirited arguments founded thereon:
i) Criminalisation of the vice;ii) Actus reus, Preparation, Attempt
and Conspiracy;
iii)Mens rea;iv)Transnational jurisdiction;v) Intermediaries and modes of
participation;
vi)Active/passive bribery;vii)Corporate liability and sanctions;viii)Facilitation/Grease payments;ix)Official immunity; andx) Reporting in Bad Faith
It is trite that the OECD Conventionis the
most effective and rigorous instrument in
tackling the vive as it, prima facie, which
aims at combating bribery of FPOs6 in
international business transactions.
However, other Conventions are equally
important in bridging the gap and filling
the lacuna left by the OECD Convention
including, inter alia, the narrowed ambitwhich is restricted to criminalisation of
active bribery(supply side) only as
contrasted with UNCAC which is much
wider in terms of application and
criminalises both active and
passive(demand side) bribery.
Collectively, the international regime
criminalises the vice. For instance,UNCACprohibits and, as aforementioned,
criminalises the intentional conduct of any
person who actually gives a bribe to a FPO
or simply makes an offer or promise for a
6 M. Pieth, Taking stock: Making the OECD Initiative
against Corruption Work (2000), para 7
bribe7 on the one hand- inchoate bribery.
It equally outlaws the conduct of any FPO
who, when offered, accepts or
himself/herself solicits a bribe8 on the
other.
Similar provisions are explicitly or
implicitly entrenched in other
Conventions whereby State Parties
(hereinafter referred to as SPs) are
either obligated(mandatory) or
requested(non-mandatory) to ...adopt
such legislative and other measures as may
be necessary to establish as criminal
offences under [their] domestic law when
committed intentionally....9 the bribery of
FPOs. For example, the AU Convention
mandates its SPs [i]n the spirit of
international cooperation... to foster
regional, continental and international
cooperation to prevent corrupt practices in
international trade transactions.10
Furthermore, under the AU Convention
SPs undertake to: Adopt...measures...to
prevent companies [from] paying bribes to
win tenders.11 No doubt, such measures
include the deterrent effect of
criminalisation.
On the authority of these provisions and
indeed on a plethora of those in other
Conventions as hereinafter enunciated, the
conduct of companies, through their
intermediaries, in offering bribes to FPOs
including government ministers, inter
alios, is criminalised because a Minister is
7 Article 16(1)8 Article 16(2)9CoE Convention, Article 510 Article 19(2)11 Article 11(3)
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covered in the meaning of persons defined
as FPOs.12 Equally, it is a crime for a FPO
to receive or even just entertain a bribery
offer from a corporation or indeed
requesting a higher offer of kickback from
another corporation competing for
business either personally or through an
intermediary such a Deputy Director or
otherwise.
The regime does not require the bribery to
be implemented for the perpetrators to be
liable. Instead, mere preparatory acts of
preparation,13 conspiracy14 and attempt15
are themselves criminalised and stand
equivalent to the actual offence of bribery
of FPOs. Therefore, if a bribery scheme is
derailed, the offence of inchoate bribery
has already been committed because all
perpetrators would have impliedly
participated in at least one of the
preparatory acts. This is a somewhat
unusual departure from the routinecriminal law, but such is the law in a
legally justifiable bid to curb the vice
under the regime.
With the exception of only the AU
Convention which does not at all require
intention in the commission of offences,16
the regime criminalises the vice only
when committed intentionally. Therefore,
12UNCAC, Article 213 Ibid, Article 27(3)14 AU Convention, Article 4(1)(i)15 UNCAC, Article 27(2)16Cf:T.R. Snider and W. Kidane, Combating CorruptionThrough International Law in Africa: A ComparativeAnalysis in Cornell International Law Journal (2007) 40,p 722
intent to commit the offence is one of the
requisite elements of the offence.
Notwithstanding its importance, intent is,
however, not explicitly defined in the
regime; suffice to mention that the
UNCAC stipulates thus: [i]ntent...as an
element...may be inferred from objective
factual circumstances.17
Therefore, in the adjudication process,
mens reamay be deduced, by implication
and analogy, from consideration of
objective factual circumstances
surrounding each individual case and
decided on its own merit. As such, it could
be deduced in certain instances that
perpetrators intended to commit bribery
though even if their scheme got derailed
or even aborted provided they apparently
had the requisite mens rea to so commit
the offence.
As the case may be, after establishing that
there is a prima facie case against
perpetrators of an FPO bribery indictment
in light of the actus reus and mens rea
being present, the next important issue is:
which courts can try them? Initially, this
would be a very contentious issue. For
instance, prior to the establishment of the
regime, ...the applicability of a States
domestic law to offences committed
outside its jurisdiction...was an area of
ambiguity even in developed countriesthat had a heightened awareness of the
conduct of their businesses abroad.
Countries like the United Kingdom and
Canada, until recently, did not have any
17 Article 28
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clear provisions relating to cross border
corruption [even] when their nationals
were involved in the corruption of a
foreign public official18 as rightly
submitted by Carr, [I]t was very much a
question of speculation as to whether or
not their courts had jurisdiction over
corrupt acts committed abroad by their
nationals19
However, the controversy has since been
settled and the ambiguity clarified
following the creation of the regime;
particularly after the coming into force of
the OECD Conventionand UNCAC. BothConventions, inter alia, empower SPs to
establish and exercise jurisdictions over
economic crimes through any of the
following types of jurisdiction:
i) Nationality jurisdiction, which maybe either active or passive
nationality;
ii) Territorial jurisdiction, whichcould be subjective or objective
territoriality; oriii)Protective jurisdiction.
The author opines that with reference to
the offence of bribery of FPOs in
international commercial transactions, all
these types of jurisdictions are
extraterritorial and transnational in nature
because they encompass parties to the
transaction from two or more different.
18I. Carr, The United Nations Convention on Corruption:Making a Real Difference to the Quality of Life ofMillions? in Manchester Journal of International
Economic Law (2006) 3, pp 3- 44, at 919Ibid, citingR v Libman [1985] SCR 178 (footnote 20) asexample where the issue of extraterritoriality gave rise tosubstantive debates as to whether Canadian criminal lawwas sufficient to cope with corruption of foreign publicofficial by their nationals.
Carl Pacini, et al, take a similar position
when they espouse that: [T]he OECD
Convention... obligates signatory nations
to make bribery of foreign public officials
a criminal act on an extraterritorial
basis.20 Succinctly stated, this means that
since the regime is non-self-executing, SPs
are employed to adopt into their domestic
legislation the offence as created under the
regime and establish jurisdiction over it;
even when committed outside their
boundaries.
Therefore, in the exercise of jurisdiction a
SP may act as follows, inter alia,depending on given scenarios:
a) Prosecute its public officials andtheir intermediaries, subject to
applicable domestic laws on official
immunity, on the basis of active
nationality because the perpetrators
are its nationals. Furthermore, a
country may also prosecute both a
corporation and its human agents
premised on objective territorialitywhere the offence was partially
committed in its territory;
b) In consultation with othercountries with sufficient nexus
(legal connection to the case), SPs
may, in the alternative, have
concerned perpetrators extradited
to their respective countries for
prosecution on the basis of active
nationality jurisdiction,
notwithstanding that the offences
were committed abroad.
20 C. Pacini, J.A. Swingen and H. Rogers, The Role oftheOECD and EU Conventions in Combating Bribery ofForeign Public Officials in Journal of Business Ethics(2002) 37, p 385
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The later approach operates on the
international law principle of aut dedere
aut judicare which compels the custodial
State to try perpetrators itself or hand
perpetrators over to a State that is willing
to prosecute.21
The UNCAC criminalises participation in
the commission of an offence by
intermediaries in any capacity such as
accomplice, assistant, or instigator....22
The AU Convention has a similar
provision which is actually more
comprehensive and detailed stipulating
thus:
This Convention is applicable to the
following acts of corruption...(i)
participation as a principal, co-
principal, agent, instigator, accomplice
or accessory after the fact, or on any
other manner in the commission or
attempted commission of, in
collaboration or conspiracy tocommit....23
Although the AU Convention does not
explicitly provide for bribery of FPOs, by
analogy and implication of Article 4(2)
thereof,24 the same is captured. Therefore,
the above quoted provision implicitly
applies to bribery of FPOs, mutatis
mutandis, provided the SPs in question
mutually agree; and there is compliance
21 G. Werle, Principles of International Criminal (2005), p63, para 18322 Article 27(1)23 Article 4(1)(i)24 It states: This Convention shall also be applicable bymutual agreementwith respect to any other act or practiceof corruptionnot described in this Convention.
with the rigors and niceties of dual
criminality.
Depending on the matrix of a specific case,
the taxonomy of participation may vary
taking a complexion such as: corporationexecutives participating as agents25 for
their corporations; regional directors of
corporations participating as assistants26 to
the group CEOs, while directors of
operation in government departments may
participate as accomplices27 and/or aiders28
to a Minister. The same government
directors of operation may equally
participate as conspirators29 with group
CEOs of foreign corporation while group
CEOs of multi-national corporations may
also participate as instigators of their
regional directors to commit FPO
bribery.30
In the final analysis, unless otherwise, it is
seldom that any of intermediaries in FPO
bribery offences would participate as a
principal offender but simply aiders and/or
abettors31 of some kind owing to the fact
that the most appropriate principal is the
corporation itself and not the
intermediaries- though in exceptional
offences the FPO could be legally deemed
as a reciprocating/alternate/equating
principal offender.
The vice manifests itself in two forms
namely; active bribery and passive bribery.
25 AU Convention, Article 4(1)(i)26 UNCAC, Article 27(1)27Ibid.28 OECD Convention, Article 1(2)29 AU Convention, Article 4(1) (i)30
Ibid31 OECD Convention, Article 1(2)
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One of the most common impediments to
the successful prosecution of FPO Bribery
offences arises from the fact the OECD
Conventionis the chief legal instrument of
authority hereon and yet the OECD
approach thereto is such that OECD
member nations have bound themselves to
prevent bribery by multinational firms by
criminalising active bribery....32
Consequently, defence counsel is likely to
aver that FPO are not criminally liable
under International Anti-Corruption Law
since passive bribery is not outlawed, in as
far as the OECD is concerned hence a FPO
recipient of a bribe from a multinationalcorporation should be acquitted.
Solace is however, found in those
instruments that criminalise both active
and passive bribery such as the CoE
Convention.33 However, the issue remains
controversial because the CoE Convention
is a regional instrument; not binding States
outside its region of operation. The critical
question is what does the UNCACprovide hereon since it is the UN
instrument thus the true International
anti-Corruption Law?
One would think that UNCACsolves this
issue because it is a universal instrument,
binding all States of the world, and
criminalises both active and passive
bribery. Of course it criminalises both
forms of bribery; but the issue remainsunresolved because under UNCAC only
the criminalisation of active bribery is
32 C. Pacini, J.A. Swingen and H. Rogers, op cit, at 390citing G. Sacerdoti, To Bribe or Not to Bribe? in K.Elliott (ed),No longer Business As Usual (2000), pp 29- 5033 Article 5 read together with Articles 2 and 3
mandatory.34 Criminalisation of passive
bribery is non-mandatory.35
Except the AU Conventionwhich does notincorporate the concept of corporate
liability, the regime provides for liability
of legal persons. For instance, the OECD
Convention obligates SPs to legislate on
[l]iability of legal persons for the bribery
of a foreign public official.36
Consequently, corporations may be held
liable for participating, usually, as
principals in the offence37on the provisionof the CoE Convention which holds legal
persons liable only for active bribery
committed on its behalf. It obligates SPs to
[a]dopt such legislative and other
measures as may be necessary to ensure
that legal persons can be held liable for the
criminal offences of active bribery...
committed for their benefit by any natural
person....38
Equally, if another corporation competing
for business is offered chance by a FPO to
beat the bribery offer from another, such a
corporation will also be liable for active
bribery or attempted active bribery
because the offer from the FPO would
not at law amount to an offer of a bribe
but simply an invitation to treat on an
envisaged illegal activity or stimulation to
34 See Article 16 (1). See also A. Argandoa, The UnitedNations Convention Against Corruption and its Impact onInternational Companies in Journal of Business Ethics(2007) 74, pp 481- 496, at 48935 UNCAC, Article 16(2). See also A. Argandoa, op cit.36 Article 237 AU Convention, Article 4(1)(i)38 Article 18
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offer a bribe. On this point alone, the FPO
would be held liable for soliciting a bribe.
Another dimension hereto is that
corporations may also be held liable for
authorisation39 of their respective CEOscorrupt practice by implied acquiescence
contrary to Article 1(2) of the OECD
Convention. This liability is
jurisprudentially founded on the
extrapolation of the doctrines of vicarious
liability40 and alter ego. These two
doctrines, working in collusion, may also
hold the companies liable atparwith their
CEOs as collaborators.41
In any case, [L]iability of a legal person...
shall not exclude criminal proceedings
against natural persons who are
perpetrators, instigators of, or accessories
to, the criminal offences.42
Concerning the issue of sanctions, the
OECD Convention mandates SPs to
prescribe either civil or administrative
sanctions in addition to,43 and/or, criminalsanctions (subject to domestic legal
systems), or non-criminal sanctions which
may include monetary fine.44 The proviso
thereto is that whatever sanctions SPs opt
for should be effective, proportionate and
dissuasive.45 SPs are further urged to
legislate on seizure and confiscation of the
bribe itself together with its proceeds or
the monetary equivalence thereof.46
39OECD Convention, Article 1(2)40Cf: Pieth, op cit, para 4(a) (3)41 AU Convention, Article 4(1) (i)42 CoE Convention, Article 18(3)43 Article 3(4)44 Article 3(2)45 Article 3(2)46 Article 3(3)
Where the scheme is not executed
(attempted bribery) the most appropriate
penalty would be monetary sanctions in
form of a fine in addition to custodial
sentencing.
Perpetrators of the FPO bribery offence
have often erected the defence of
facilitation/grease payments which is
allowable as per the OECD Convention;
and include payments ...made to induce
public officials to perform [their] non-
discretionary routine functions such as
issuing licenses and permits.47
Technically, therefore, this defence cannot
be sustained at law where the FPOs
functions are discretionary function and
not a non-discretionary routine function.
The FPO should be liable if they had the
discretion to decide which corporation to
award business to in preference over
others hence the reason for bribery.
Furthermore, the amount involved shouldbe scrutinised. If it is unreasonably too
huge (not petty amount) to be treated as
part of the de minimisrules under which
the facilitation/grease payments fall
concept is anchored48 then the defence of
grease payment would fail with liability
being established. In any case, the issue of
facilitation/grease payments is at best
contested because other than the OECD
Convention, the rest of the regime does
not embrace it.
47 Pacini et al, op cit, p 39748 Pieth, op cit, para 4(a)(2)
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This is another ground of defence a FPO
may raise in their memorandum of
appearance. However, it is more likely
than not bound to fail because, subject to
domestic laws, the regime does not allow
FPOs official immunity to hinder the
investigation and/or prosecution of erring
FPOs.49
As enunciated in the case of D v National
Society for the Prevention of Children
Cruelty,50 the importance and associated
dangers of informants role in crime
detection has been appreciated world-
over, hence the need to protect them.
However, there are issues to do with the
reciprocating need to equally protect
innocent persons from disgruntled
whistle-blowers. With the exception of
the OECD Convention, the regime
protects informants so long as the
reporting is in good faith and on
reasonable grounds.51
Informants whomake false and malicious reports against
innocent people52 risk punishment.
Therefore, for informants to be liable for
bad-faith reporting, three elements must
be established against them namely; i)
falsity of the report; ii) malice of the
reporter; and iii) innocence of the reported
person(s).
The emphasis on reporting in good faith
hereon is hinged on the realisation that
FPOs are busy agents of their respective
49 AU Convention, Article 7(5)50 [1977] 1 All ER 58951 Article 3352 AU Convention, Article 5(7)
governments hence should not be left to
the whims and caprices of busy bodies
who could be disgruntled elements trying
to derail government programmes not
only through malicious insinuations but
also unfounded allegations resultant in bad
faith reporting; with the possibility of
ultimately disturbing development
business plans of the FPO. Nevertheless,
SPs should take all reasonable steps to
balance the scale of mere suspicion and
possibility of actual perpetration. As such,
courageous and well-meaning informants
deserve commendation because, as per
Judge Cory, [t]he position of informers...isalways precarious and their role fraught
with danger....53
From the foregoing, and indeed on a
plethora of authorities, it is clear that a
critical mass of expatiations is slowly
building up at the international level
aimed at combating the abhorrent offence
of FPO bribery in internationalcommercial transactions. Better still, it is
generally settled at international anti-
corruption law that the aforesaid offence is
criminalised even by ordinary preparatory
acts and not actual implementation
whereby capturing the wide inchoate
offences incidental thereto or indeed
consequential therefrom. This is clear
from the buttressing and/or replicated
provisions in other legal instruments nothereinbefore explored but on all-fours
therewith. For example, the Organisation
of American States Convention obligates
its SPs to punish the offering... to a
53R v Scott[1990] 3 SCR 979 at 994
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government official of another state
promise or advantage, in connection with
any economic or commercial transaction
in exchange for any act or omission in the
performance of that officials public
functions.54
Equally, the SADC Protocol55 criminalises
acts of corruption relating to an official of
a foreign State even before
execution/implementation of the plans.56
Therefore, the non-implementation of the
scheme in an attempted FPO bribery cases
is immaterial because it does not
relinquish the perpetrators liability. Onthe authority of the many provision
espoused above and many more verbatim
one, perpetrators of FPO bribery risk
being prosecuted, accordingly, by their
domestic courts or foreign courts with
established jurisdiction.
54 Article VIII55 Signed on 14 August 2001but not yet entered into force56 Article 6
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1. D v National Society for the Prevention of Children Cruelty[1977] 1 All ER 589.2. R v Libman[1985] SCR 178.3. R v Scott[1990] 3 SCR 979.1. African Union Convention on Preventing and Combating Corruption (2003), Maputo.2. Council of Europe: Criminal Law Convention on Corruption (2002), Strasbourg.3. Organization of American States: Inter-American Convention against Corruption
(1996/97), Caracas.
4. Organisation for Economic Cooperation and Development: Convention on CombatingBribery of Foreign Public Officials in International Business Transactions (1999), Basel.
5. United Nations Convention against Corruption (2005), Washington D.C.1. Southern African Development Community Protocol against Corruption (2001),
Victoria Falls.
1. A. Argandoa, The United Nations Convention Against Corruption and its Impact on
International Companies in Journal of Business Ethics (2007) vol. 74, Springer
Publishers, Amsterdam.
2. C. Pacini, J.A. Swingen and H. Rogers, The Role of the OECD and EU Conven tions inCombating Bribery of Foreign Public Officials in Journal of Business Ethics(2002) vol.37, Kluwer Academic Publishers, Amsterdam.
3. G. Sacerdoti, To Bribe or Not to Bribe? in K. Elliott (ed), No longer Business As Usual(2000) OECD, Paris.
4. G. Werle, Principles of International Criminal(2005) T.M.C. Asser Press, The Hague.5. I. Carr, The United Nations Convention on Corruption: Making a Real Difference to
the Quality of Life of Millions?In Manchester Journal of International Economic Law
(2006) Vol. 3, No. 3, London.
6. M. Pieth, Taking stock: Making the OECD Initiative against Corruption Work (2000)available and accessed on 7 October 2009 at
www.oas.org.juridica/english/pieth2000.htm7. T.R. Snider and W. Kidane, Combating Corruption through International Law in
Africa: A Comparative Analysis in Cornell International Law Journal (2007) vol. 40,
New York.
1. http://www.articles.latimes.com/2011/mar/11/business/la-fi-foreign-corrupt-201103112. http://www.oas.org.juridica/english/pieth2000.htm
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