OECD - Enforcement data of the OECD Anti‑Bribery Convention 1999‑2025

2  ENFORCEMENT DATA OF THE OECD ANTI-BRIBERY CONVENTION 1999-2025 © OECD 2026

HIGHLIGHTS Concluded cases From the entry into force of the OECD Anti-Bribery Convention on 15 February 1999 through 31 December 2025: • 26 Parties have, collectively, convicted or sanctioned at least 768 natural an d 321 legal persons for foreign bribery through criminal proceedings; • 8 Parties have, collectively, sanctioned at least 99 natural and 135 legal persons for foreign bribery through administrative or civil proceedings; • 11 Parties have, collectively, convicted or sanctioned at least 101 natural an d 137 legal persons for related offences (e.g. false accounting, money laundering) throug h criminal proceedings; and • 3 Parties have, collectively, sanctioned at least 80 natural and 216 legal persons for related offences through administrative or civil proceedings. Pending matters As of 31 December 2025: • 26 Parties reported having, collectively, 480 ongoing investigations for foreign bribery; • 18 Parties reported having, collectively, ongoing criminal proceedings for foreign bribery against 242 natural and 38 legal persons; and • 3 Parties reported having, collectively, ongoing administrative or civi l proceedings for foreign bribery against 4 natural and 2 legal persons.

By ratifying the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (the OECD Anti-Bribery Convention), the Parties pledge to work together to fight foreign bribery. This report contains an overview of the Parties’ enforcement efforts since the Convention’s entry into force on 15 February 1999. More information about the implementation and enforcem ent of the OECD Anti-Bribery Convention, including the Parties’ mutual evaluations of their implementatio n of the Convention, through the Working Group on Bribery, is available online at: https://www.oecd .org/en/topics/fighting-foreignbribery.html. Enforcement data of the OECD Anti-Bribery Convention

Convention, including the Parties’ mutual evaluations of their implementatio n of the Convention, through the Working Group on Bribery, is available online at: https://www.oecd .org/en/topics/fighting-foreignbribery.html. Enforcement data of the OECD Anti-Bribery Convention 1999-2025 OECD Working Group on Bribery 3

ENFORCEMENT DATA OF THE OECD ANTI-BRIBERY CONVENTION 1999-2025 © OECD 2026

OVERVIEW OF THE ENFORCEMENT DATA The following tables provide an overview of the enforcement data reported by Parties to the OECD Anti-Bribery Convention. The data for each country cover the period from the Convention’s entry into force in that country to 31 December 2025. The data distinguish foreign bribery from other related offences covered by the Convention, in particular accounting misconduct and money laundering related to the bribery of foreign public officials. Enforcement data on cases against indiv iduals and entities are recorded separately. The Annex “Methodology for Enforcement Data” provides further context for the data presented. Table 1A. Decisions on criminal foreign bribery cases Number of individuals and legal persons sanctioned or acquitted Party to the Convention Convention entry into force % share of world GDP1 % share of world exports1 Sanctioned (agreed or imposed) Acquitted Natural persons Legal persons Natural persons Legal persons Argentina 2001 0.58 0.33 2 0 1 0 Australia 1999 1.56 1.29 7 3 3 0 Austria 1999 0.49 0.85 8 0 25 3 Belgium 1999 0.61 2.16 9 2 15 5 Brazil 2000 1.93 1.33 0 0 0 0 Bulgaria 1999 0.11 0.18 1 0 0 0

Belgium 1999 0.61 2.16 9 2 15 5 Brazil 2000 1.93 1.33 0 0 0 0 Bulgaria 1999 0.11 0.18 1 0 0 0 Canada2 1999 1.96 2.11 4 4 8 0 Chile 2001 0.30 0.41 2 1 0 0 Colombia 2013 0.39 0.19 0 0 0 0 Costa Rica 2017 0.09 0.10 0 0 0 0 Croatia 2024 0.09 0.11 0 0 0 0 Czechia 2000 0.33 1.08 0 0 0 0 Denmark 2000 0.39 0.57 0 3 0 0 Estonia 2005 0.04 0.08 2 0 0 0 Finland 1999 0.27 0.32 0 0 18 4 France 2000 2.85 2.60 30 39 18 1 Germany3 1999 4.27 6.72 375 12 2 0

1 Based on OECD national accounts, Eurostat, and national statistical offices. 2 For Canada: One of the legal persons listed above pleaded guilty to on e count of fraud in connection with a foreign bribery scheme. 3 For Germany: Due to a change in methodology to align the enforcement data in this report with the data in Germany’s Phase 4 evaluation report, the German data before 2017 are not comparable to the data reported for 2017 or thereafter. Furthermore, the sanctions reported include those imposed in the conte xt of proceedings terminated after the accused or indicted accused complied with the conditions and instructions (e.g. payment o f a sum of money to a non-profit-making institution) imposed by

the sanctions reported include those imposed in the conte xt of proceedings terminated after the accused or indicted accused complied with the conditions and instructions (e.g. payment o f a sum of money to a non-profit-making institution) imposed by the public prosecution office or the court (Section 153a(2) Code of Criminal Procedure – CCP ( Strafprozessordnung)). As of Germany’s Phase 3 evaluation, it was not possible to identify which sanctions imposed under Section 153a CCP were for foreign bribery and foreign bribery-related offences. Therefore, the data include sanctions imposed under that provision for both foreign4  ENFORCEMENT DATA OF THE OECD ANTI-BRIBERY CONVENTION 1999-2025 © OECD 2026

Number of individuals and legal persons sanctioned or acquitted Party to the Convention Convention entry into force % share of world GDP1 % share of world exports1 Sanctioned (agreed or imposed) Acquitted Natural persons Legal persons Natural persons Legal persons Greece 1999 0.24 0.21 0 0 5 0 Hungary 1999 0.21 0.64 28 0 2 0 Iceland 1999 0.03 0.03 0 0 0 0 Ireland 2003 0.61 1.12 0 0 0 0 Israel4 2009 0.52 0.22 5 3 0 0 Italy 2001 2.16 2.77 23 10 43 6 Japan 1999 3.75 2.81 22 4 0 0 Korea 1999 1.58 2.70 26 9 11 0 Latvia 2014 0.04 0.08 0 2 0 0 Lithuania 2017 0.08 0.16 0 0 0 0 Luxembourg 2001 0.09 0.07 9 0 3 0

Latvia 2014 0.04 0.08 0 2 0 0 Lithuania 2017 0.08 0.16 0 0 0 0 Luxembourg 2001 0.09 0.07 9 0 3 0 Mexico 1999 1.55 2.53 0 0 0 0 Netherlands 2001 1.13 3.77 8 10 1 0 New Zealand 2001 0.22 0.18 0 0 0 0 Norway5 1999 0.45 0.65 4 4 5 1 Peru 2018 0.29 0.31 0 0 0 0 Poland 2000 0.88 1.58 1 0 0 0 Portugal 2001 0.29 0.34 0 0 1 0 Romania 2023 0.36 0.42 0 0 0 0 Slovakia 1999 0.13 0.48 0 0 0 0 Slovenia 2001 0.07 0.37 0 0 0 0 South Africa 2007 0.36 0.44 0 0 0 0 Spain 2000 1.61 1.70 4 0 2 3 Sweden 1999 0.57 0.79 6 0 9 2 Switzerland6 2000 0.88 2.11 17 15 2 0

bribery and foreign bribery-related offences. Data also include sanctions imposed under section 299 CC in foreign bribery cases (since the entry into force of the Convention). 4 For Israel: Figures include a legal person criminally sanctioned in a cas e involving foreign bribery-related facts, but which was resolved under securities law. The statistical data for Israel are supp lied by and under the responsibility of the relevant Israeli

(since the entry into force of the Convention). 4 For Israel: Figures include a legal person criminally sanctioned in a cas e involving foreign bribery-related facts, but which was resolved under securities law. The statistical data for Israel are supp lied by and under the responsibility of the relevant Israeli authorities. The use of such data by the OECD is without prejudice to the status of the Golan Heights, East Jerusalem and Israeli settlements in the West Bank under the terms of international law. 5 For Norway: The figures include cases resolved via a penalty notice under Criminal Procedure Act (CPA) paragraph 258) but not “påtaleunnlatelse” decisions under CPA paragraph 69. 6 In Switzerland, while foreign bribery cases can be pursued either at the fed eral or cantonal level, the Office of the Attorney General of Switzerland (OAG) initiates the vast majority of such cases . As the cantons are not required to report their cases to the OAG, the data contained in this table only reflect federal cases as well as those cases delegated by the cantons to the OAG. 5

ENFORCEMENT DATA OF THE OECD ANTI-BRIBERY CONVENTION 1999-2025 © OECD 2026

Number of individuals and legal persons sanctioned or acquitted Party to the Convention Convention entry into force % share of world GDP1 % share of world exports1 Sanctioned (agreed or imposed) Acquitted Natural persons Legal persons Natural persons Legal persons Türkiye 2000 1.35 1.04 0 0 1 0 United Kingdom 1999 3.39 2.12 23 17 26 1 United States7 1999 26.04 8.32 152 183 4 0 TOTAL (entire WGB) 65.12 58.38 768 natural persons sanctioned, including through plea agreements or other resolutions 321 legal persons sanctioned, including through plea

TOTAL (entire WGB) 65.12 58.38 768 natural persons sanctioned, including through plea agreements or other resolutions 321 legal persons sanctioned, including through plea agreements, NPAs, DPAs, or other resolutions 205 natural persons acquitted 26 legal persons acquitted

In addition, the numbers reported here do not take into account e xemptions from punishment under Article 53 of the Swiss Criminal Code. 7 For the United States: This row records the number of criminal cases prosecuted by t he US Department of Justice either for violations of the anti-bribery provisions of the Foreign Corrupt Practic es Act (FCPA) or for violations of both the anti-bribery provisions and the books and records and internal controls provisions of the FCPA. Therefore, this Table does not reflect criminal sanctions that have been imposed exclusively for violations of the b ooks and records and internal controls provisions of the FCPA. The data also reflect declinations with disgorgement concluded under the FCPA Corporate Enforcement Policy.6  ENFORCEMENT DATA OF THE OECD ANTI-BRIBERY CONVENTION 1999-2025 © OECD 2026

Table 1B. Decisions on administrative and civil foreign bribery cases 1 Number of individuals and legal persons sanctioned or found not liable Party to the Convention Convention entry into force % share of world GDP % share of world exports Sanctioned (agreed or imposed) Found not liable Natural persons Legal persons Natural persons Legal persons Australia 1999 1.56 1.29 0 3 0 0 Brazil 2000 1.93 1.33 0 4 0 0 Colombia 2013 0.39 0.19 0 2 0 0

Australia 1999 1.56 1.29 0 3 0 0 Brazil 2000 1.93 1.33 0 4 0 0 Colombia 2013 0.39 0.19 0 2 0 0 Germany 1999 4.27 6.72 7 5 0 0 Israel 2009 0.52 0.22 0 2 0 0 United Kingdom 1999 3.39 2.12 0 10 1 0 United States2 1999 26.04 8.32 59 109 3 0 TOTAL (relevant countries) 38.08 20.19 99 135 4 0

1 Only those countries that have reported additional sanctions ordered under administrative and/or civil procedures have been listed in Table 1B. Note that some countries have criminal and adminis trative/civil sanctions for foreign bribery, and in some cases persons sanctioned in civil proceedings have also been sanctioned in criminal proceedings. 2 For the United States: This row records the number of administrative and civil enforcement ac tions of the US Department of Justice and the US Securities and Exchange Commission that have led to sanctions for violations of the anti-bribery provisions of the FCPA either alone or in conjunction with violations of the books and records and internal controls provisions of the FCPA, whether through a court decision, an administrative order, or through another resolution. Therefore, this Table does not reflect civil or administrative sanctions that have been imposed exclusively for violations of the books and records and internal controls provisions of the FCPA. 7

ENFORCEMENT DATA OF THE OECD ANTI-BRIBERY CONVENTION 1999-2025 © OECD 2026

Table 2A. Decisions on criminal cases for other offences related to foreign bribery1 Number of individuals and legal persons sanctioned or acquitted Party to the Convention Convention entry into force % share of world GDP % share of world exports

Table 2A. Decisions on criminal cases for other offences related to foreign bribery1 Number of individuals and legal persons sanctioned or acquitted Party to the Convention Convention entry into force % share of world GDP % share of world exports Sanctioned Acquitted Natural persons Legal persons Natural persons Legal persons Australia 1999 1.56 1.29 4 0 0 0 Austria 1999 0.49 0.85 0 1 1 0 Finland 1999 0.27 0.32 3 0 1 0 Germany 1999 4.27 6.72 25 4 0 0 Israel 2009 0.52 0.22 6 1 0 0 Italy 2001 2.16 2.77 5 0 2 0 Korea 1999 1.58 2.70 4 1 0 0 Luxembourg 2001 0.09 0.07 0 1 0 0 Netherlands2 2001 1.13 3.77 4 21 1 0 Sweden 1999 0.57 0.79 1 0 0 0 United States3 1999 26.04 8.32 49 108 3 0 TOTAL (relevant countries) 38.66 27.82 101 natural persons sanctioned, including through plea agreements or other resolutions 137 legal persons sanctioned, including through plea agreements, NPAs, DPAs, or other resolutions 8 natural persons acquitted 0 legal persons acquitted

1 Only those countries that have reported criminal sanctions for offences related to foreign bribery have been listed in Table 2A.

including through plea agreements, NPAs, DPAs, or other resolutions 8 natural persons acquitted 0 legal persons acquitted

1 Only those countries that have reported criminal sanctions for offences related to foreign bribery have been listed in Table 2A. “Other offences related to foreign bribery” includes offences falling under Articles 7 (Money Laundering) and 8 (Accounting) of the Convention. Examples include books and records violations, f ailure to implement sufficient internal controls, abus de biens sociaux (misuse of company assets), and Untreue (breach of trust based on a failure to supervise). 2 For the Netherlands: One legal person was sanctioned for multiple anti-money-laund ering violations, encompassing at least one count of money laundering predicated on foreign bribery. 3 For the United States: This row records the number of criminal cases prosecuted by the US Department of Justice for violations of the books and records and internal controls provisions of the FCPA as well as supply-side money laundering violations predicated on foreign bribery either alone or in combination with violations of the FCPA anti-bribery provisions.8  ENFORCEMENT DATA OF THE OECD ANTI-BRIBERY CONVENTION 1999-2025 © OECD 2026

Table 2B. Decisions on administrative/civil cases for other offences related to foreign bribery1 Number of individuals and legal persons sanctioned or found not liable Party to the Convention Convention entry into force % share of world GDP % share of world exports Sanctioned (agreed or imposed) Found not liable Natural persons Legal persons Natural persons Legal persons Australia 1999 1.56 1.29 1 1 0 0 Israel 2009 0.52 0.22 3 2 0 0 United States2 1999 26.04 8.32 76 213 3 0 TOTAL (relevant countries) 28.12 9.83 80 natural persons

Israel 2009 0.52 0.22 3 2 0 0 United States2 1999 26.04 8.32 76 213 3 0 TOTAL (relevant countries) 28.12 9.83 80 natural persons sanctioned, through civil or administrative proceedings or other resolutions 216 legal persons sanctioned, through civil or administrative proceedings or other resolutions 3 natural persons found not liable 0 legal persons found not liable ANNEX: METHODOLOGY FOR ENFORCEMENT DATA Collection and presentation of enforcement data Tables 1A and 1B present data that the Parties to the OECD Anti-Bribery Convention have agreed to provide on a mandatory basis as part of the Working Group on Bribery’s law enforcement data collection exercise. They show the number of criminal cases (in Table 1A), and administrative and civil cases (in Table 1B) of foreign bribery that have resulted in a final court disposition, such as a criminal conviction or acquittal, or similar findings under a non-criminal procedure. The tables report the number of sanctions that have been imposed on individuals and entities in criminal, admin istrative, and civil proceedings for foreign bribery and for failures to prevent a proven case of foreign bribery in the Parties to the Anti-Bribery Convention from its entry into force in February 1999. The following additional points about these tables should be noted: ▪ In certain countries, the liability of legal persons is an administrative liability but legal persons are sanctioned in connection with a criminal offence in the context of a criminal case. ▪ The tables include data provided by countries on a voluntary basis on non-trial resolutions, i.e. foreign bribery cases that have been resolved through an agreement between law enforcement authorities and the accused person or entity, with or without court approval. In some cases, the proceedings may have been terminated or deferred for a certain period of time on condition that

foreign bribery cases that have been resolved through an agreement between law enforcement authorities and the accused person or entity, with or without court approval. In some cases, the proceedings may have been terminated or deferred for a certain period of time on condition that the accused person agrees to certain conditions, such as implementation of corporate reforms, the payment of fines, restitution, and/or full co-operation in the investig ation of others individuals or companies allegedly involved in the same case.

1 Only those countries that have reported administrative/civil sanctions for offences related to foreign bribery have been listed under Table 2B. “Other offences related to foreign bribery” include offences falling under Articles 7 (Money Laundering) and 8 (Accounting) of the Convention. Examples include books and records violations, failure to implement sufficient internal controls, abus de biens sociaux (misuse of company assets), and Untreue (breach of trust based on a failure to supervise). 2 For the United States: This row records the number of administrative and civil enforcement actions of the US Department of Justice and the US Securities and Exchange Commission that have le d to sanctions for violations of the books and records and internal controls provisions of the FCPA either alone or in conjunction with the FCPA’s anti -bribery provisions. It includes sanctions imposed through court decisions, administrative orders, as well as other types of resolutions, including NPAs. 9

ENFORCEMENT DATA OF THE OECD ANTI-BRIBERY CONVENTION 1999-2025 © OECD 2026

▪ What is not included in the tables? Unless otherwise indicated, the tables do not include other offences that might also apply to this form of conduct in certain circumstances, such as trading in influence, United Nations embargo violations, privateto-private bribery, or bribery to obtain a benefit outside of an international business transaction. They also do not record the number of sanctions that may have been imposed by the Parties against foreign public officials for receiving bribes, as this offence is not covered by the Convention. Tables 2A and 2B present the enforcement data provided on a voluntary basis by Parties regarding

sanctions that may have been imposed by the Parties against foreign public officials for receiving bribes, as this offence is not covered by the Convention. Tables 2A and 2B present the enforcement data provided on a voluntary basis by Parties regarding sanctions in criminal, administrative, and civil cases for other offences related to foreig n bribery. These include non-bribery offences that are covered by Articles 7 (Money Laundering) and 8 (Accounting) of the Convention. The specific offences vary by jurisdiction, but all relate to miscondu ct associated with foreign bribery in international business transactions, such as books and records v iolations, failure to implement internal controls, abus de biens sociaux (misuse of company assets), and breach of trust based on a failure to supervise. As with Tables 1A and 1B, this data set does not cover other offences that fall outside the Convention, such as trading in influence, United Nations embargo vi olations, or bribery to obtain a benefit outside of an international business transaction. Supplementary information about the methodology used to collect the data on enforcement is available here: www.oecd.org/daf/anti-bribery/Methodology-Enforcement-Data.pdf.

This work is published under the responsibility of the Secretary-General of th e OECD. The opinions expressed and arguments employed herein do not necessarily reflect the official views of the Member countries of the OECD. This document and any map included herein are without prejudice to the status of or sovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. The statistical data for Israel are supplied by and under the responsibility of the relevant Israeli authorities. The use of such data by the OECD is without prejudice to the status of the Golan Heights, East Jerusalem and Israeli settlements in the West Bank under the terms of international law.

Photo credits: © Epitavi / iStock / Getty Images Plus.

© OECD 2026.

Attribution 4.0 International (CC BY 4.0)

is without prejudice to the status of the Golan Heights, East Jerusalem and Israeli settlements in the West Bank under the terms of international law.

Photo credits: © Epitavi / iStock / Getty Images Plus.

© OECD 2026.

Attribution 4.0 International (CC BY 4.0) This work is made available under the Creative Commons Attribution 4.0 In ternational licence. By using this work, you accept to be bound by the terms of this licence (https://creativecommons.org/licenses/by/4.0/). Attribution – you must cite the work. Translations – you must cite the original work, identify changes to the original and add the following text: In the event of any discrepancy between the original work and the translation, only the text of original work should be considered valid. Adaptations – you must cite the original work and add the following text: This is an adaptation of an original work by the OECD. The opinions expressed and arguments employed in this adaptation should not be reported as representing the official views of the OECD or of its Member countries. Third-party material – the licence does not apply to third-party material in the work. If using such material, you are responsible for obtaining permission from the third party and for any claims of infringement. You must not use the OECD logo, visual identity or cover image without express permission or suggest the OECD endorses your use of the work. Any dispute arising under this licence shall be settled by arbitration in accordance with the Permanent Court of Arbitration (PCA) Arbitratio n Rules 2012. The seat of arbitration shall be Paris (France). The number of arbitrators shall be one.