anti corruption research

How anti-corruption efforts strengthen global democracy and security

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December 6, 2023

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Corrupt regimes around the world threaten global democracy and security. On this episode of The Current, Norman Eisen, senior fellow in Governance Studies and chair of the newly launched global Anti-Corruption, Democracy, and Security (ACDS) project at Brookings, talks about the project and explains why fighting corruption and promoting good governance are key to strengthen democracy and security.

Exploring the dynamics of corruption perceptions in sustained anti-corruption campaigns: a survey experiment in China

Yating Pan ORCID: orcid.org/0000-0002-6398-7899 1 ,
Zhan Shu 2 &
Zhipeng Ye 3

Humanities and Social Sciences Communications volume 10 , Article number: 570 ( 2023 ) Cite this article

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Criminology
Politics and international relations
Social policy

Evidence increasingly shows that anti-corruption investigations generate negative perceptions in the short run and lead to perceptions of reduced corruption in the long run. However, there is a lack of research on the effects of anti-corruption investigations on corruption perceptions within sustained anti-corruption campaigns. In certain nations, anti-corruption campaigns can be relentless. In such sustained campaigns, can fluctuations in the annual number of investigations affect corruption perceptions? This study aims to address the gap by conducting a survey experiment in China. The findings indicate that corruption perceptions are formed in an online evaluation fashion rather than a memory-based one. Individuals spontaneously form and revise their perceptions by integrating new information into their existing evaluations. Corruption perceptions are positively correlated with both the past trend in the annual number of investigations and recent investigations. Unexpected recent investigations can reverse people’s corruption perceptions that are based on past trends. These findings are applicable to other nations in which anti-corruption campaigns are sustained and anti-corruption information is publicly accessible.

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Introduction

Corruption can be defined as the abuse of power to pursue private profit at the expense of the public interest (Jensen et al., 2010 ; Keliher and Wu, 2016 ). Although functionalists argue that corruption can lubricate political mechanisms and reduce the chances of political violence (Pharr and Putnam, 2000 ), it’s more widely acknowledged that corruption undermines government performance and erodes political trust (Seligson, 2002 ; Richey, 2010 ), thereby challenging the political legitimacy of a nation (Anderson and Tverdova, 2003 ; Chang and Chu, 2006 ; Gingerich, 2009 ; Morris and Klesner, 2010 ). In recent decades, there has been a growing phenomenon of anti-corruption efforts aimed at combating the misuse of public resources (Mungiu-Pippidi, 2006 ). Anti-corruption institutions have been established in many nations, and anti-corruption campaigns have been launched.

Corruption perception refers to individuals’ assessment of the level of corruption, and it is influenced by people’s tolerance toward corruption and their evaluations of a government’s anti-corruption measures (Bauhr and Grimes, 2014 ; Dimitrov, 2013 ). High corruption perceptions can undermine political stability and the legitimacy of governments (Melgar et al., 2009 ). Therefore, public perceptions of corruption should be considered when guiding efforts to combat corruption and when adjusting a government’s future work (Li et al., 2016 ).

There is debate over the relationship between the number of investigations and corruption perceptions. It is widely argued that corruption investigations reduce corruption and therefore mitigate corruption perceptions in the long run (Grönlund and Setälä, 2012 ; Hakhverdian and Mayne, 2012 ; Villoria et al., 2013 ). In the short run, however, anti-corruption efforts that reveal corruption scandals may lead to people’s “informed disenchantment” and increase their corruption perceptions (Sun et al., 2022 ; Wang and Dickson, 2022 ; Zhu, 2017 ; Corbacho et al., 2016 ). Most relevant studies focus on the number of anti-corruption investigations over a specific period when examining the effects of anti-corruption efforts. However, there is a lack of empirical research on sustained anti-corruption campaigns that involve long-term and comprehensive efforts aimed at combating corruption. Corruption is often deeply rooted in societal, economic, and political structures, and some governments may continuously strive to bring about lasting change in these areas. Theoretically and practically, it is necessary to look into how people process anti-corruption information and form their perceptions.

In a sustained anti-corruption campaign, the relationship between anti-corruption investigations and corruption perceptions can be even more complex. As stated earlier, anti-corruption efforts can affect perceptions in a positive direction since they convince people that corruption is less prevalent, while the exposure of corruption cases may be interpreted as evidence of its existence. Therefore, each year’s investigations can be seen as the anti-corruption effects of previous years. We argue that in a sustained anti-corruption campaign, it is not just the total number of investigations that matters. Presenting information in different orders may lead to different effects (Anderson and Hubert, 1963 ), and the impact of corruption investigations on corruption perceptions may differ with fluctuations in the annual number of investigations.

This study researches corruption perceptions within sustained anti-corruption campaigns. How do different trends in the annual number of corruption investigations affect people’s perceptions? How do individuals update their perceptions in response to new investigations? Examining the formation of corruption perceptions can help uncover cognitive mechanisms that contribute to negative perceptions and legitimacy crisis (Booth and Seligson, 2009 ). We conducted an online survey experiment in China to investigate how year-to-year fluctuations in the number of corruption investigations affect corruption perceptions. The survey findings suggest that people engage in online evaluation when assessing corruption levels in a sustained anti-corruption campaign. They continuously revise their perceptions based on new information. We observe that different past trends in the annual number of anti-corruption investigations result in different perceived levels of corruption, and new investigations that reveal unexpected corruption numbers can reverse people’s corruption perceptions.

The paper is structured as follows: “Literature review and hypotheses” section reviews relevant literature and puts forward hypotheses by explicating the two possible evaluation models. In “Methods,” we present our online survey experiment conducted in China. “Results and findings” reports the results and findings regarding how year-to-year fluctuations in the number of corruption investigations impact people’s corruption perceptions. It also discusses that individuals form their perceptions in an online evaluation fashion rather than a memory-based one. “Conclusion and limitations” highlights the implications and limitations of this research.

Literature review and hypotheses

Corruption and corruption perceptions.

Corruption can be measured using objective and subjective indicators. Objective indicators include the number of officials disciplined, the number of anti-corruption investigations or convictions, etc. (Zhu and Gong, 2015 ). The indicators can also reflect a government’s anti-corruption efforts and capabilities (Alt and Lassen, 2014 ).

The subjective indicators are typified by corruption perceptions. Corruption perceptions represent people’s subjective evaluations of perceived corruption (Kanol, 2015 ), reflecting opinions rather than experiences (Treisman, 2007 ). Corruption perceptions are widely used to measure corruption, although the reliability of these perceptual indexes remains controversial due to perceptual bias. Disparities exist between the actual level of corruption and these subjective measures (Melgar et al., 2009 ; Golden and Picci, 2005 ). An empirical research based on Indonesian data even suggests no correlation between corruption perceptions and actual corruption (Olken, 2009 ). However, it is more widely believed that while corruption perceptions might not provide an exact depiction of actual corruption, the two are highly correlated (Mocan, 2008 ).

The influencing factors of corruption perceptions

The influencing factors of corruption perceptions have been widely researched. First, an individual’s place of residence, which implies his socio-economic and cultural background, is believed to impact corruption perceptions (Melgar et al., 2009 ).

Second, three primary channels of information, which are personal experience, media coverage, and grapevine, contribute to shaping people’s beliefs about corruption. As suggested by Sharafutdinova ( 2010 ), individuals who have personal experience of corruption tend to perceive a higher level of corruption compared with those who have no relevant experience. However, it has been found that most people have no corruption experience, even in nations where corruption is known to be common, and they primarily rely on news media for information about government corruption (Zhu et al., 2013 ). As pointed out by Lambsdorff ( 1999 ), it is the circulation of information, rather than personal experience, that most significantly influences corruption perceptions.

Both formal and informal information sources play crucial roles in setting the public agenda and shaping how people perceive corruption (Singer, 2011 ; Pan and Shu, 2022 ). Given that corruption is often covert, the public has limited access to complete information about government corruption, particularly in those low-information authoritarian nations (Zhu et al., 2013 ; Corbacho et al., 2016 ). Informal information sources, such as grapevine news, can serve as supplements. While some scholars argue that grapevine news causes people to overestimate the actual level of corruption (Robinson, 1976 ), evidence suggests that mass media can also contribute to unreasonable collective behavior. The media are known to be biased (Entman, 2007 ), potentially emphasizing corruption news and exaggerating the situation (Duffy et al., 2008 ). Media exposure can consequently lead to systematic biases among people. An empirical study based on South Korean data suggests that those who obtain corruption information from traditional media may perceive a relatively high level of corruption, while news consumption on social media does not boost perceived corruption (Park and Lee, 2017 ).

Evidence from authoritarian nations may lead to a different conclusion. Mass media, which are not necessarily government-owned, can be controlled and manipulated by illiberal regimes to forge a government-supportive public opinion. In China, mass media are mandated to relay the editorial content of the government-owned Xinhua News Agency when reporting political news (Zhu et al., 2013 ). Thus, evidence from China demonstrates that state-controlled media coverage can significantly lower public perceptions of corruption, while grapevine information might influence audiences in the opposite way (Zhu et al., 2013 ).

Third, corruption perceptions can be influenced by the government’s anti-corruption efforts. The relationship between the two is complex and nuanced. Ni and Sun ( 2015 ) argue that increased anti-corruption efforts do not necessarily cause a change in public perceptions of corruption. Some other scholars believe that anti-corruption efforts aimed at combating corruption and promoting good governance can ultimately reduce perceived corruption in the long term. However, increasing evidence indicates that intensive anti-corruption efforts may actually aggravate corruption perceptions rather than mitigate them (Zhang and Kim, 2018 ). Such efforts expose a corrupt political culture and damage the government’s reputation, leading the public to believe that corruption is widespread in the short term. Olken and Pande ( 2012 ) introduce the example of Indonesia, suggesting although the downfall of Soeharto in 1998 led to a decrease in actual corruption, the allegations of corruption disclosed by the accompanying freer press resulted in an increase in corruption perceptions. Therefore, in a sustained anti-corruption campaign, the positive long-term effects of anti-corruption investigations may be overshadowed by the annual number of investigations in the subsequent years, which can serve as an indicator of anti-corruption accomplishments.

Memory-based evaluation vs. online evaluation

Corruption perceptions refer to people’s subjective evaluations of corruption. Within the realm of social psychology, two models of evaluation—memory-based evaluation and online evaluation—can be applied to understand corruption perceptions.

Memory-based evaluation suggests that people are more inclined to make judgments when they are requested to do so (Hastie and Park, 1986 ). This model assumes that judgments are based on information recall, where individuals retrieve relevant information from memory (Chartrand and Bargh, 1996 ; Lichtenstein and Srull, 1987 ; Mackie and Asuncion, 1990 ). An effect known as the “recency effect” occurs in information recall, indicating that the most recent information holds the greatest influence. Therefore, according to the memory-based evaluation model, people’s evaluations are largely shaped by the most recent information. Researchers are increasingly discovering that anti-corruption investigations, particularly recent ones, uncover corruption scandals and negatively impact public corruption perceptions. That is, the recent number of investigations is positively related to corruption perceptions. When the number of investigations in the recent period is large, people perceive a high level of corruption. Conversely, a small number of investigations result in perceptions of low corruption.

On the other hand, the online evaluation model suggests that people continually form and revise their attitudes by integrating new information into their existing evaluations (Tormala and Petty, 2001 ). Beliefs are continuously evolving, with evaluations being updated as new information is received. The evaluation formation process concludes after receiving the latest information. In this model, the sequence of information significantly influences belief formation and updating. In addition to the most recent information, evaluations are also influenced by individuals’ prior beliefs. Therefore, according to the online evaluation model, people’s evaluations are shaped by both prior and the most recent information.

In a sustained anti-corruption campaign, the annual number of anti-corruption investigations fluctuates, indicating a sequence of information that can affect public perceptions of corruption. The trends can be categorized as upward, downward, or flat. An upward trend denotes a continuous increase in the annual number of corruption investigations, a downward trend represents a decline over the years, and a flat trend indicates stabilization. Taking an upward trend as an example, individuals initially perceive a low level of corruption when the number of investigations is low. However, their perceptions may progressively increase as the annual number of investigations rises, culminating in a high perceived level of corruption. One assertion is that upward trends in investigation numbers correlate with relatively high levels of corruption perception.

Hence, according to the online evaluation model, trends in investigations number shape the formation of corruption perceptions, with the most recent information prompting individuals to revise their beliefs. Both a past upward trend in the number of anti-corruption investigations and a high recent number of investigations can contribute to a high level of perception. Based on the online evaluation model, we expect corruption perceptions to be influenced by both the number of corruption investigations in the most recent year and the past trend of investigations.

It is widely believed that individuals’ corruption experiences that correlate with their pre-existing beliefs can significantly influence the impact of anti-corruption efforts on corruption perceptions. Wang and Dickson ( 2022 ) find that individuals’ prior beliefs regarding officials’ integrity can influence how an anti-corruption initiative affects the level of public support for the government. Consequently, we anticipate that alongside recent anti-corruption efforts, people’s pre-existing beliefs about corruption can strongly shape their perceptions of it. In the context of a sustained anti-corruption campaign, we posit that corruption perceptions are formed in an online fashion rather than a memory-based one. We formulate the hypothesis that individuals’ perceptions of corruption are influenced by the past trend in the number of anti-corruption investigations. This hypothesis can disprove the memory-based evaluation model if supported.

Hypothesis 1: All else being equal, people’s perceptions of corruption positively correlate with the past trend in investigation numbers .

The online evaluation model suggests that individuals consistently integrate new information into their existing evaluations. Accordingly, we propose the hypothesis that past trends in the number of investigations shape the formation of corruption perceptions, with the most recent information promoting individuals to revise their beliefs.

Hypothesis 2: Recent investigations, which unveil corruption numbers unexpected by the public, can reverse individuals’ corruption perceptions that are based on past trends in the number of investigations .

The current study delves into how individuals respond to fluctuations in the number of corruption investigations throughout a sustained anti-corruption campaign. We aim to examine whether the public adopts the online evaluation model when perceiving corruption by empirically testing the hypotheses outlined above.

In early 2022, we conducted an online survey experiment on Chinese respondents to examine the hypotheses. Since China embarked on its market reforms in the late 1970s, the accompanying political corruption has escalated social discontent and has become an intractable problem (Teets et al., 2010 ). The Communist Party of China launched its first anti-corruption campaign in 1982. The Xi Jinping government has started its anti-corruption campaign since the 18th National Congress held in late 2012, which is widely seen as the least compromising and the most effective campaign since the founding of the People’s Republic of China (Keliher and Wu, 2016 ). Hundreds of thousands of officials, including “tigers” (senior corrupt officials) and “flies” (junior corrupt officials), have been investigated and disciplined. According to a report released by the Central Commission for Discipline Inspection, around 631,000 corruption cases were investigated in China in 2021. The government considers its anti-corruption campaign as an important achievement. Discipline Inspection Commissions always publish a notification when they start investigating a corrupt suspect, and their publicly available annual review reports reveal the number of corruption investigations conducted every year. Chinese mass media typically relay these notifications and annual reports by giving a positive spin to justify the campaign. Therefore, Chinese respondents are likely to have a good understanding of sustained anti-corruption campaigns.

Participants

We recruited participants on Sina Weibo, one of the most popular social media platforms on which people openly share information and exchange ideas in China (Vuori and Paltemaa, 2015 ). Since the public typically learns about annual figures of corruption investigations from media reports, we aimed to recruit a representative sample of news consumers. We posted the recruitment advertisement in the comments sections of hot news posts on Weibo, offering a ¥2 cash bonus to each volunteer.

A total of 2626 volunteers completed our questionnaire. We excluded 111 of them who spent less than 1 min finishing the questionnaire (30 s for the control group) and another 198 inattentive participants who failed the attention check questions. We have a final sample of 2317 participants, 1205 male (52.0% of the participants) and 1112 female (48.0% of the participants), ranging in age from 16 to 65 years (mean = 30.25 years old, median = 29 years old) (see Supplementary Appendix Table A1 ). This sample is representative of news consumers on the social media platform (see Supplementary Appendix Table A2 ).

Research design

We asked our participants to fill in an online questionnaire at https://www.wjx.cn/ . The survey began with questions concerning participants’ demographic characteristics that might influence their corruption perceptions. As a guise, we asked about participants’ reading habits and whether they liked working with numbers.

In the experiment, we introduced a fictitious country instead of China to control for respondents’ pre-existing knowledge and attitudes toward Xi’s anti-corruption campaign. Adapted from a real news post reported by Chinese state-owned media, we claimed the fictitious country had initiated an anti-corruption campaign since 9 years ago when the current generation of leadership took power, and we set the corruption ratio to be the same as in China. According to the figure for the year 2021, China’s population had reached 1.44 billion, government-affiliated institutions had about 50 million staff members, and more than 4 million government officials had been investigated since the 18th Communist Party of China National Congress (the Central Commission for Discipline Inspection, 2021). In our experiment, the fictitious country had a population of 480,000, government-affiliated institutions had 16,700 staff members, and 1330 corruption cases had been investigated since the campaign started. We intentionally set the figures relatively low to reduce the cognitive burden associated with large numbers.

After introducing the background information of the fictitious country and providing the total number of corruption investigations, participants were shown nine individual news reports that revealed the numbers of investigations for each of the past 9 years, one at a time. The only difference among the nine reports was the number of anti-corruption investigations launched each year. To ensure participants’ engagement and information processing, an attention check question followed each news report, asking participants to select the correct number of anti-corruption investigations for the specified year.

By assigning values to the annual number of investigations for each year, we created a 2*2 design that crossed the past trend in the number of anti-corruption investigations (an upward trend and a downward trend) with the number of investigations in the most recent year (high and low). These combinations of past trends and recent numbers, along with a control group that did not receive annual figures, were employed (see Table 1 ). The total number of anti-corruption investigations was the same across all the five groups.

We examine how different past trends and recent investigations result in differences in participants’ corruption perceptions among the five groups. The online evaluation model suggests that people form and update their evaluations based on new information. We design the upward/downward past trends in the number of investigations and the high/low number of investigations in the most recent year to explore how corruption perceptions are affected by the fluctuations in the number of investigations (see Table 2 for annual figures). Our experiment design allows us to observe the process by which people form and update their beliefs, shedding light on how individuals react to different past trends and how their perceptions change with the introduction of the most recent information.

The five conditions are as follows:

Condition 1

In the continuous upward trend condition, the annual number of anti-corruption investigations increases from a low level in 2013 to a high level in 2021 ( k = 3194.4).

Condition 2

In the unexpected decrease condition, the annual number of anti-corruption investigations increases from a low level in 2013 to a high level in 2020 ( k = 4107.1) and then decreases to the same level as 2013 in 2021.

Condition 3

In the continuous downward trend condition, the annual number of anti-corruption investigations decreases from a high level in 2013 to a low level in 2021 ( k = −3194.4).

Condition 4

In the unexpected increase condition, the annual number of anti-corruption investigations decreases from a high level in 2013 to a low level in 2020 ( k = −3285.7) and then increases to the same level as 2013 in 2021.

Condition 5

In the undisclosed condition, the participants were not provided with the annual figures.

The participants were randomly assigned to one of the five groups. After giving the treatments of annual figures, we asked the respondents to evaluate the government’s current corruption level. We used the following question to measure it: “To what extent do you perceive the government to be corrupt currently after the 9-year anti-corruption effort?” The respondents were asked to evaluate on a scale from 1 (not corrupt at all) to 5 (extremely corrupt), with a higher score indicating a higher level of perceived corruption.

Results and findings

Descriptive analysis.

In support of the random sampling principle, we found no significant differences among the respondents in the five groups regarding gender, χ2 (4) = 1.36, p = 0.85; and age, F(4, 2312) = 0.71, p = 0.59 (see Supplementary Appendix Table A3 ).

Regarding the outcome variable, significant differences were observed among respondents’ perceived levels of corruption across the five groups (χ2 = 2072.56, df = 16, p < 0.001) (see Table 3 ). The average perceived corruption level was 2.42 in the undisclosed condition (Condition 5), and it was 1.42 in the continuous downward condition (Condition 3) (see Table 2 ). In contrast, respondents tended to perceive relatively high levels of corruption (above scale 4) in the other three groups, which were 4.34 in the continuous upward condition (Condition 1), 4.06 in the unexpected decrease condition (Condition 2), and 4.15 in the unexpected increase condition (Condition 4). Among the four treatment groups in our experiment, respondents perceived a high level of corruption when either the trend in the number of anti-corruption investigations was upward or the number of investigations in the most recent year was high.

The online evaluation model proposes that individuals form and revise their perceptions in response to newly released information. Accordingly, Hypothesis 1 predicts that the past trend of investigations and the recent number of investigations work together to affect corruption perceptions. We found that four combinations of past trend and recent number of investigations can generate different levels of corruption perception, which confirmed hypothesis 1 while rejecting the memory-based evaluation model that neglects the critical role of past trend of investigations. Specifically, the perceived level of corruption was low (mean = 1.42) in the continuous downward condition (Condition 3), in which the past trend was downward and the number of investigations in the most recent year was low. It was the opposite in the continuous upward condition (Condition 1), with an average perceived corruption level of 4.34. Respondents perceived high levels of corruption in both the unexpected decrease condition (mean = 4.06) and the unexpected increase condition (mean = 4.15), where either the past trend was upward or the number of corruption investigations in the most recent year was high. Hypothesis 1 is supported.

Hypothesis 2 predicts that the number of anti-corruption investigations in the most recent year can revise people’s pre-existing perceptions that are based on past trend. Our experiment reveals that respondents form and revise their evaluations in an online evaluation fashion. In the continuous upward condition (Condition 1), the annual number of corruption investigations continues to climb, reaching the highest level in the final year. In the unexpected decrease condition (Condition 2), the number of corruption investigations surprisingly decreases in the final year after eight consecutive years of growth. Respondents perceived corruption to be prevalent (mean = 4.34) in the continuous upward condition, and the average perceived level of corruption was 4.06 in the unexpected decrease condition. The difference in corruption perceptions between the two groups can be attributed to the decrease in the final year.

Meanwhile, an unexpected increase in the recent number of investigations can reverse people’s corruption perceptions that are based on the past downward trend in investigations. Specifically, in the continuous downward condition (Condition 3), the annual number of corruption investigations continues to decline, and respondents perceived the level of corruption to be low (mean = 1.42). In the unexpected increase condition, the number of corruption investigations surprisingly increased in the final year after eight consecutive years of decrease, and the average perceived level of corruption was 4.15. We observe a clear difference in corruption perceptions between the above two groups as a result of the unexpected increase. The sudden change in the most recent year updated people’s beliefs and led them to perceive a significantly higher level of corruption. Hypothesis 2 is supported.

Regression results

Building upon the aforementioned analysis, we further test the two hypotheses using the Ordinary Least Squares (OLS) regression method. Respondents’ corruption perception is the dependent variable, while the past trend in number of investigations and the recent number of investigations are the two independent variables, coded as dummy variables (upward = 1, downward = 0; high = 1, low = 0). Our analysis takes gender (coded as a dummy variable, male = 1, female = 0) and age (a continuous variable) as control variables. The results are reported in Table 4 . In Model 1 and Model 2, each independent variable is included separately while controlling for respondents’ gender and age. Model 3 contains all independent variables and control variables. Model 4 introduces an interaction term between the explanatory variables to assess whether the recent number of investigations can reverse people’s corruption perceptions that are based on the past trend in number of investigations.

Model 1 and Model 2 reveal that either the past trend in the annual number of investigations (β = 1.32, p < 0.01) or recent investigations (β = 1.46, p < 0.01) is positively correlated with the perceived level of corruption, respectively. Model 3 further verifies that respondents’ corruption perception is simultaneously related to the annual number of investigations (β = 1.39, p < 0.01) or recent investigations (β = 1.52, p < 0.01). This suggests that individuals perceive a high level of corruption either when the past trend is upward or when the recent number of investigations is high. Thus, Hypothesis 1 and the online evaluation model are supported. In other words, the above results also suggest that respondents’ corruption perception is not solely shaped by the recent number of investigations that is argued by the memory-based evaluation model.

The interaction between the past trend and the recent number of investigations shows a significant association with corruption perception (β = −2.39, p < 0.01), as shown in model 4. The interaction effect is graphically depicted in Fig. 1 , which plots two regression lines for upward and downward past trend in numbers, indicating that the recent unexpected corruption numbers can influence and even reverse people’s corruption perceptions that are based on trends over the past several years. The plot reveals that the impact of the recent number of investigations on corruption perception is heightened when respondents have experienced a downward past trend in number of investigations. In other words, the marginal reverse effect of the “Unexpected Increase Condition” (|4.15–1.42| = 2.73) outweighs that of the “Unexpected Decrease Condition” (|4.06–4.34| = 0.28). This further bolsters the support for Hypothesis 2.

The linear predictions for the recent number of investigations on corruption perception, depending on whether the past trend in the number of investigations is upward or downward, are presented. The “recent number of investigations” is coded on the x -axis. The red line represents the participant group with an upward past trend, while the blue line represents the participant group with a downward past trend of investigations.

This work explores how the formation of corruption perceptions is affected by fluctuations in the annual number of corruption investigations. In the experiment, we assigned different groups to upward/downward trends in the annual number of investigations and high/low number of investigations in the most recent year. After receiving the treatments, respondents were asked to evaluate their perceived level of current corruption.

The result suggests that when informed about a large number of corruption investigations launched during a long-term anti-corruption campaign, people tend to perceive the current corruption level to be relatively low (mean = 2.42). However, when being provided with the annual figures, people’s perceptions of government cleanliness can vary depending on the sequence of information. This indicates that corruption perceptions are formed in an online evaluation fashion rather than a memory-based fashion and are affected by both recent investigations and past trends in the number of investigations. Specifically, people perceive a high level of corruption when either the past trend in the annual number of corruption investigations is upward or the number of investigations in the most recent year is large. Our regression analysis further confirms that respondents’ corruption perceptions are positively associated with both recent investigations and past trends in the number of investigations, aligning with the propositions of the online evaluation model.

These findings fit with previous studies suggesting that anti-corruption efforts can lead people to perceive corruption as more prevalent. Moreover, this study focuses on a sustained anti-corruption campaign and provides evidence that it is not only the total number of investigations or recent investigations that affect corruption perceptions but also the fluctuations in the annual number of investigations. Different trends in the annual number of investigations result in different corruption perceptions. A continuous downward trend leads people to believe that corrupt officials have been removed and perceive a low corruption level. Conversely, a continuous upward trend leads people to believe that corruption is prevalent and perceive a high corruption level.

People revise their corruption perceptions based on new information from recent investigations, and the extent of revision is influenced by pre-existing attitudes that are associated with past trends. Comparing the perceived levels of corruption in the downward trend condition and the unexpected increase condition, we find that an unexpected increase following a downward trend leads people to update their perceptions and perceive more corruption than they may do in a downward trend condition. Meanwhile, an unexpected decrease following a continuous upward trend does not convince people that the government has successfully reduced its corruption level, and the perceived level of corruption does not significantly decrease compared with that of the upward trend condition. This suggests that corruption perceptions can be revised as new information is received, and individuals may have their own interpretations of the unexpected decrease or increase, leading to varying perceptions of corruption levels.

Conclusion and limitations

Corruption, which poses a significant challenge to good governance, is a concern for governments worldwide. Many governments resort to anti-corruption campaigns to tackle this issue, and in some countries, these campaigns are sustained over time.

Previous studies have indicated that anti-corruption investigations can have mixed effects on corruption perceptions. In the short term, investigations may increase corruption perceptions by exposing corruption scandals. However, in the long run, they are expected to have a positive influence by signaling that authorities are taking action against corruption to reduce its prevalence. This study furthers the understanding by analyzing how anti-corruption investigations influence corruption perceptions in sustained campaigns. It argues that each year’s anti-corruption investigations can be seen as a result of previous anti-corruption efforts. Therefore, the total number of investigations within a specific period is not sufficient to explain corruption perceptions, and fluctuations in the annual number of investigations can serve as indicators of a campaign’s effectiveness and affect how corruption is perceived. Building upon the online evaluation model, this work highlights the significance of past trends in the annual number of investigations and recent investigations, as well as their varied combinations, in explaining the evolving perceived level of corruption within a sustained campaign.

To explore citizens’ corruption perception formation, we conducted a survey experiment in China. The findings reveal how year-to-year fluctuations in the number of corruption investigations affect individuals’ perceptions. It demonstrates that corruption perceptions are formed in an online evaluation fashion. Individuals spontaneously form and revise their perceptions based on new information about annual figures. People’s current perceptions are built on their prior beliefs, which are affected by past trends of corruption investigations, and they update their perceptions in response to recent investigations.

More specifically, an upward trend in the annual number of investigations correlates with high corruption perceptions, while a downward trend evokes the opposite effect. Unexpected new information can reverse individuals’ corruption perceptions that are based on the past trend in the annual number of investigations. An unexpected increase following a downward trend significantly leads people to perceive more corruption. In contrast, an unexpected decrease has a comparatively minor effect in revising their existing negative perceptions.

This study contributes to the existing literature on the effects of anti-corruption investigations on corruption perceptions, particularly in the context of sustained campaigns. It sheds light on how corruption perceptions can be affected by past trends in the annual number of anti-corruption investigations and recent investigations. Importantly, it highlights that corruption perceptions are formed in an online evaluation fashion. People view the number of anti-corruption investigations as quantitative evidence of the effectiveness of previous efforts, interpreting a downward trend as progress in combating corruption. These findings are of interest to those studying corruption perceptions, government satisfaction, and public opinion. They suggest that governments should initiate anti-corruption efforts early to avoid counterproductive outcomes in sustained campaigns. The findings of this paper can also be applicable to other nations where governments publicly report anti-corruption information.

It is worth noting that this work does not enumerate and analyze all possible fluctuations in the annual number of corruption investigations. Further research should thus explore fluctuations that may lead people to perceive a low level of corruption. For instance, can an unexpected decrease lasting for 2 or 3 years result in the perception of a clean government?

Limitations

This study did not control for individuals’ corruption experiences, which may influence respondents’ corruption tolerance, and individuals’ educational background, which may influence their ability to read, analyze and interpret anti-corruption information. Moreover, we posted the recruitment advertisement in the comments sections of hot news posts on Weibo. The sample in this study represents social media users who are likely to engage in public affairs and give their comments, but it does not represent the general population in China. Social media have been extensively used to access news information, and as Gonzalez-Bailon et al. ( 2010 ) find, online discussions, although not demographically representative of the population, are representative of public opinion trends. However, further investigations are needed to determine whether the findings are generalizable to the general population.

Moreover, our experiment cannot perfectly simulate the complexity of reality. In reality, the media may delve deeply into the details of sensational corruption cases, which has been found to increase corruption perception (Sun et al., 2022 ). Furthermore, in order to avoid the possible influence of individuals’ pre-existing political attitudes and their knowledge about the anti-corruption campaign, our participants were presented with a fictitious country. However, this may limit the external validity of the study to a certain extent.

Data availability

The datasets generated or analyzed during this study are available from the corresponding author upon reasonable request.

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YP did the conception and design, literature research, analysis, and interpretation. ZS performed the research, collected the data, and analyzed the data. ZY did regression analysis and interpretation. All authors contributed to drafting and revising the manuscript. All authors gave final approval of the paper as well as their agreement to be accountable for all aspects of the work in ensuring that questions related to the accuracy or integrity of any part of the work are appropriately investigated and resolved.

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Pan, Y., Shu, Z. & Ye, Z. Exploring the dynamics of corruption perceptions in sustained anti-corruption campaigns: a survey experiment in China. Humanit Soc Sci Commun 10 , 570 (2023). https://doi.org/10.1057/s41599-023-02084-0

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Preventing “Development in Reverse”: Building a Systemic Anticorruption Approach

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As the world focuses on the climate change crisis, emerging security issues, and the long-dragging COVID-19 pandemic, another international challenge is getting global attention: Corruption, along with the way it undermines democracy and human rights, deepens inequality, and corrodes natural resources.

Academia , international organizations , the media and the nonprofit sector have all quite publicly turned their attention to corruption. Much of this renewed energy has come as a result of the June 2021 National Security Study Memorandum (NSSM) where the Biden-Harris administration established confronting corruption as a key national security interest. The NSSM is clear that corruption can cut across and undermine all development efforts.

Other leaders in the Biden administration agree; USAID Administrator Samantha Power recently said , “Corruption is basically development in reverse. It harms long-term economic development, scares away private sector investment, deepens inequality, and even harms the environment.... It also disproportionately harms the most marginalized in a society.”

The NSSM directs development and security policymakers and practitioners to focus on anticorruption best practices and improve enforcement measures.With those marching orders, and reflecting on the current wealth of discussions, as well as my years of anticorruption work around the world, here are seven best practices I believe should form part of a systematic approach to combatting corruption:

1. Unbundle and understand what corruption means locally

The standard definition of corruption from Transparency International—one used by many organizations—is “the abuse of entrusted power for private gain.” However, this phrase fails to provide insight into what is happening in a given place and how to understand what is “corrupt”.

There are many tools and approaches that might have an impact on corruption, but the right approach will be context specific. Unbundling the definition of corruption and understanding its context in a given place can give practitioners deeper insight into why corruption occurs, why it may be so persistent, and then, of course, what to do about it .

2. Integrate new insights around the importance of social norms

Understanding how social norms drive behaviors that cause corruption (or undermine the effectiveness of anticorruption efforts) can also give practitioners and policy makers deeper insight into the nature of problems and why corruption in some contexts is so persistent.

Corruption is often a “ collective action problem ” and a social phenomenon underpinned by complex relationships. Approaching corruption from this perspective can shift interventions away from traditional “principal-agent” approaches. RTI is investing in research this year to identify such social norms and also design new interventions that directly address these issues.

3. Approach corruption as a system dependent on the local political context

Singular approaches rarely work in countries with endemic corruption, since suppressing an opportunity for corruption in one area may just push it up in others, and many governments can hide behind the appearance of reform without actually implementing changes that have an effect in practice.

Understanding how the whole system operates (including political, economic, and social factors) and which combination of investments and reforms—including awareness raising, prevention, detection, and enforcement/sanctioning—will be effective needs to be the starting point for thinking through solutions.

4. Design anticorruption programs that target specific problems

Unless anticorruption projects target a specific corruption problem (e.g., how a behavior or process leads to corruption that negates or reduces development outcomes) then it will be difficult to determine whether they have had an anticorruption impact.

Systemic changes may be necessary to root out corruption writ large. But in many countries, targeted approaches focused on specific problems will be more effective and successful.

Anticorruption practitioners should find (or help to create and support) champions or change agents with the political influence to drive reform , and partner with them to carry out initiatives that are both high-impact and feasible.

5. Leverage new approaches to big data

The role that technology can play in both understanding corruption and bringing new anticorruption approaches to bear is expanding as practitioners and researchers perform groundbreaking work using big data: Exposing corruption risks through public procurement data , identifying Russian politicians’ illicit gains by analyzing their financial disclosures , and pinpointing how optimal spend approaches for governments in developing countries can improve governance and the rule of law to combat corruption.

When equipped with data, civil society organizations can be more effective in advocating for transparency and accountability. Of course, many of these approaches need to be built on good governance reforms supported by champions, and development practitioners can look for opportunities to further strengthen bottom-up approaches.

Because we’ll need to ensure that the data exist in the first place, that it is open, timely, and in a format civil society and researchers can use, many of these methods will have to be implemented hand in hand with more traditional institution-building approaches focusing on transparency and accountability.

6. Consider how the international system facilitates national or local corruption

The ease with which many corrupt officials can move illicit gains around the world continues to be a significant concern. Important legislation in the U.S. and other jurisdictions is moving to close some of these loopholes, but reforming anti-money laundering legislation and strengthening financial intelligence units within all countries will continue to be necessary.

It is critical to ensure that those efforts integrate a strong anticorruption approach —particularly where the risks of high-level corruption or state capture are high.

7. Coordinate across sectors

Robust in-country dialogue with partner governments needs to be paired with cross-sectoral discussion about the systemic and political nature of corruption to avoid so-called “ orphan sectors ”: sectors that might not receive much support for good governance, particularly anticorruption reforms. If ignored, these sectors can provide significant resources to corrupt actors and undermine good governance reforms elsewhere.

For instance, the vast illicit gains from the renewable natural resource management (NRM) sector have been under-scrutinized for a long time, and investments in integrating anticorruption approaches in NRM institutions have lagged compared to many other sectors. From carbon markets to climate finance, the opportunities for shielding vested interests in conventional energy sources and upending the climate agenda are vast.

By coordinating across sectors, anticorruption practitioners can better partner with local champions to learn, develop tools and guidance, and gather evidence that can be shared and amplified.

As development practitioners, we must work with anticorruption champions in government, civil society, and within communities to inform a deeper and more nuanced understanding of what corruption means in a given context and how all of us can most effectively root it out for good.

Richard Nash is a Senior Anticorruption Specialist at RTI with 18 years of experience working on anticorruption, rule of law, and good governance projects around the world.

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Reviewing international anti-corruption cooperation arrangements in China – based on the implementation review mechanism of UNCAC

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The United Nations Convention against Corruption (UNCAC) is the first legally binding global anti-corruption instrument, and its own review mechanism provides a channel for states and civil society to participate in the commitment to combat corruption. Theoretically, this article engages with the theory of international regime to offer a broad framework explaining why and how China has adapted to the international anti-corruption regime. As a response, legally, this article analyses both good practices and shortcomings in China’s legislation and law enforcement mechanisms in terms of international anti-corruption cooperation based on Chapter IV (International Cooperation) of the UNCAC. The data collection and analysis methods include documentary review, interviews, questionnaires, and expert investigation. Then, after elaborating the most recent institutional anti-corruption achievements achieved by China since 2012, the author concludes that legal and ideological obstacles to China’s full adaptation into the global anti-corruption community remain. Thus, some suggestions for how to improve the legislation and enforcement of China’s international anti-corruption cooperation are provided.

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Based on the interviews with officials of the International Cooperation Bureau of the Central Commission for Discipline Inspection. Interviews were conducted in July, 2015.

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Acknowledgements

Thanks for the funding support from Danish Government and the comments and supports from our research team and interviewees.

People Engagement & Support: Promoting Civil Society Participation through UNCAC Promotion (2014–32988), funded by Danish government; Social Science Research Fund of Hunan Province (17JD15).

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Questionnaire and interview outline

Interview outline.

Interview Objectives: to understand the main measures and the main obstructions of international anti-corruption campaign.

Interview Questions:

Which departments are responsible for relevant issues of international anti- corruption cooperation? and what are their specific tasks and duties ?

How about achievements of Fox Hunt and Sky Net operation? Such as the number of fugitives and asset recovery.

During the practice of international anti-corruption operations, what kind of legal and technical obstructions being required to be solved urgently?

In order to implement the central government policy of international anti-corruptions initiations, what kind of innovative measures and policies being adopted at the local level?

How about the forthcoming plans for anti-corruption based on the previous achievement?

Notes: The questionnaire and interview questions are designed for experts in the relevant fields including international law, criminal law, political science and public administration and policy. (See interviewees list); officials in relevant departments at the central level and the H province, involving Discipline Inspection Department of H Province, People’s Procuratorate of province, Public Security Department of H Province, and International Cooperation Bureau of CCID Table 4 and 5 .

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HAN, L. Reviewing international anti-corruption cooperation arrangements in China – based on the implementation review mechanism of UNCAC. Crime Law Soc Change 77 , 133–157 (2022). https://doi.org/10.1007/s10611-021-09989-4

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Accepted : 24 August 2021

Published : 31 August 2021

Issue Date : March 2022

DOI : https://doi.org/10.1007/s10611-021-09989-4

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Call for chapters: Routledge Handbook of Anti-Corruption Research and Practice

Call for chapters, routledge handbook of anti-corruption research and practice, editors: joseph pozsgai-alvarez (osaka university) & roxana bratu (university of sussex).

We are opening the call for chapters from experts interested in contributing to the upcoming edited volume Routledge Handbook of Anti-Corruption Research and Practice .

Selected submissions will focus on at least one of seven themes listed below, framed within the study and/or practical engagement with anti-corruption efforts (as opposed to the focus on corruption alone).

Submissions must fall into one or more of the following themes:

Regulatory framework: The first theme deals with policy adoption, implementation, and enforcement originated in the public sector, including legal innovations. Some of the questions found here include: what drives the selection of anti-corruption strategies? What is the rate of success of different anti-corruption policies? How do aid donors in the field define ‘success’ and ‘failure’ in relationship to anti-corruption? How is anti-corruption adopted in countries affected by high levels of political corruption?
Compliance: The second theme deals with administrative systems in the private sector designed to prevent and control corruption. Some of the questions found here include: what industries are at the forefront of innovation in anti-corruption compliance? What conditions increase the risk of compliance failures? How do different anti-corruption strategies impact the performance of business organizations?
Activism and mobilization: The third theme deals with civil society initiatives to hold leaders accountable and bring about reform. Some of the questions found here include: how do anti-corruption movements emerge? What conditions increase their degree of impact on government reform? How do international networks and public support impact their outlook and performance? How do state actors, private sector and civil society actors interact in bottom-up mobilization campaigns?
Integrity development: The fourth theme deals with activities and programs developed in the public and private sectors to foster, develop, and support higher standards of professional conduct. Some of the questions found here include: are there important differences in the ethical performance of public and private employees? What is the impact of compliance systems on the moral commitments of employees? Do national values influence an organization’s ethical culture?
Ethics and norms: The fifth theme deals with the informal norms, moral constraints, and environmental conditions that influence the ethical decision-making of groups and individuals. Some of the questions found here include: Are public campaigns effective in changing people’s ethical preferences? Does religion increase the rejection of corruption among citizens? Can anti-corruption be included in the formal education of children?
Instrumentalization: The sixth theme deals with the capture of the anti-corruption agenda and the abuse of anti-corruption activities to pursue objectives unrelated to the prevention or control of corruption. Some of the questions found here include: how are the targets of foreign bribery investigations/prosecutions selected? Are anti-corruption movements susceptible to political capture? Do anti-corruption pledges and compliance certification respond to concerns for reputation or a truly ethical stance?
Anti-corruption narratives: The seventh theme deals with the use of anti-corruption rhetoric to frame political action. Some of the questions found here include: how do official texts frame anti-corruption in various spaces/contexts? How do anti-establishment political leaders use anti-corruption narratives? What is the impact of social media for anti-corruption?

About this edited volume

While the focus on corruption often highlights its nature, causes, consequences, and manifestations, the connection between the extent of the problem and its potential solutions is not always clear. Although there is much more we know today about corruption than we did three decades ago, the ideas, tools, and strategies commonly offered to reformers and activists have not changed much over the past two decades. There is limited knowledge currently available about what works and what does not; and a growing appreciation of the magnitude of the problem once corruption is scrutinized with the wider spectacles of policy reform, where the myriad factors of political, economic, and social reality become equally relevant.

This handbook will build on what is already known about corruption from a variety of academic approaches (such as economics, political science, organizational studies, anthropology, psychology, etc.) to focus on the other side of the question—that is, on the processes, conditions, impacts, and typologies of activity that hold the potential to control corruption. The volume will adopt a holistic approach to reflect the rich nature of anti-corruption, both as it has been and currently is, and the possible shapes it may still take in the future. Given the breadth of the subject, the approach adopted is therefore multidisciplinary, multidimensional, and as comprehensive as the limits of current knowledge allow.

About the editors

Joseph Pozsgai-Alvarez is Associate Professor of Political and Global Studies at the School of Human Sciences of Osaka University. He previously held the position of Assistant Professor at the Center for Southeast Asian Studies (CSEAS) of Kyoto University from 2018 to 2021. His research activities focus on public corruption, ethical decision-making, political reform, and anti-corruption institutions. He is the editor of The Politics of Anti-Corruption Agencies in Latin America, published by Routledge in 2021, and has a number of peer-reviewed papers published in journals such as Crime, Law and Social Change, and others.

Roxana Bratu is Lecturer in Corruption Analysis at the School of Law, Politics and Sociology, University of Sussex. She held several visiting fellowships at the Centre for Criminology at the University of Oxford (as an OSI/FCO Chevening Scholar) and LSE Mannheim Centre for Criminology, UK. Roxana currently works on issues related to corruption and good governance in relation to new technologies, integrity and anti-corruption practices. Her first monograph, Corruption, Informality and Entrepreneurship in Romania, was published in 2018 with Palgrave. She co-edited the special issue Innovation in Corruption Studies (Slavonic & East European Review, 2017).

Interested contributors are invited to send a 500-word chapter proposal (in English) as a Word file to [email protected] and [email protected] .

The proposal should include:

author(s) name(s)
affiliation(s)
e-mail address(es)
short bio(s) (max. 100 words).

Please follow the style:

Times New Roman
1.5 line spacing
Chicago reference

You can also send any inquiries to [email protected] and/or [email protected] .

1 April 2022: deadline for proposal submissions
15 April 2022: decision on selected submissions
10 July 2022: deadline for full manuscript drafts (max. 7000 words including bibliography)
Late-2023: expected publication

Supreme Court Poised to Cut Back Scope of Anti-Corruption Law

The question for the justices was whether a federal law prohibits not only before-the-fact bribes but also after-the-fact rewards.

The front facade of the United States Supreme Court is seen above trees in Washington, DC.

By Adam Liptak

Reporting from Washington

The Supreme Court seemed ready on Monday to limit the reach of a federal statute that makes it a crime for state and local officials, along with institutions that receive federal money, to accept gifts and payments meant to influence or reward their actions.

In a lively argument studded with hypothetical questions about gifts as varied as cookies, Starbucks gift cards, meals at the Cheesecake Factory and 10-figure donations to hospitals, a majority of the justices seemed persuaded that the government’s interpretation of the law was too broad.

Before the argument, Chief Justice John G. Roberts Jr. announced that Justice Clarence Thomas would be absent but would participate in the case by reading the briefs and the transcript of the argument. The chief justice did not say why.

The case concerned James Snyder, who was mayor of Portage, Ind., along Lake Michigan, when the city bought garbage trucks from a local company under a bidding process that prosecutors said had been manipulated to ensure the company prevailed. After the process was complete, the company paid Mr. Snyder $13,000 for what he later said were consulting services.

Prosecutors charged Mr. Snyder with violating the federal law, which covers anyone “who solicits or demands for the benefit of any person, or accepts or agrees to accept, anything of value from any person, intending to be influenced or rewarded.” He was found guilty in March 2021 and sentenced to 21 months in prison.

The question for the justices was whether the law applies only to before-the-fact bribes or also to after-the-fact gratuities.

Lisa S. Blatt, a lawyer for Mr. Snyder, warned the justices that a broad reading of the law would turn routine gifts into crimes backed by 10-year prison sentences. She added that it was impossible to draw a workable line between prohibited gifts and permissible ones.

“I don’t know where on the Harry & David menu the gift becomes corrupt,” she said, referring to the retailer known for its fruit baskets.

Along the same lines, under the government’s theory, she said, the gift of a meal at Chipotle was probably permissible, while one at the Inn at Little Washington, an expensive restaurant in Virginia, would not be. The hard question, she said, suggesting that the line-drawing exercise was absurd, was the Cheesecake Factory.

Justice Sonia Sotomayor noted that the law requires that the payment be made in connection with actions worth at least $5,000. Ms. Blatt said that amount was easily satisfied.

“The doctor who removes your wart, fine,” she said, indicating that such a procedure may not meet the threshold. “But the doctor who takes your gallbladder out or does your face, like my plastic surgeon, no, that’s worth over $5,000.”

Colleen R. Sinzdak, a lawyer for the federal government, said the anti-corruption law was not concerned with “innocuous gift-giving activity that occurs in the ordinary course of business.”

Better hypothetical examples, she said, were demands from a police chief for $10,000 payment after his officers foiled a burglary or a request for $30,000 from a safety inspector after he issued a permit for a dangerous project. She argued that Mr. Snyder’s case was along those lines.

Justice Brett M. Kavanaugh agreed that “the facts of this case are great” for the government’s interpretation of the law. But he added that the court must decide how it should apply in other cases.

Justice Elena Kagan echoed the point. “This statute applies not just to government officials but to pretty much, like, every important institution in America,” she said, asking about a hypothetical hospital that provides a billionaire with special treatment in hopes of receiving a big contribution.

“That would land you 10 years in prison?” she asked.

Ms. Sindzak said the government would not bring questionable cases. Chief Justice Roberts responded that “we don’t rely on the good faith of the prosecutors in deciding cases like this.”

In earlier rulings, the court has interpreted anti-corruption laws narrowly.

Last year, the court threw out two fraud convictions involving accusations of bid-rigging and illicit payments during the administration of Gov. Andrew M. Cuomo, a New York Democrat.

In 2020, the court unanimously overturned the convictions of two defendants in the so-called Bridgegate scandal, in which associates of Chris Christie, a Republican who was the governor of New Jersey, closed access lanes to the George Washington Bridge in 2013 to punish one of the governor’s political opponents. That was an abuse of power, the court ruled, but not a federal crime.

Similarly, the court in 2016 unanimously overturned the conviction of Bob McDonnell, a former governor of Virginia. Mr. McDonnell, a Republican, had accepted luxury products, loans and vacations from a business executive.

Adam Liptak covers the Supreme Court and writes Sidebar, a column on legal developments. A graduate of Yale Law School, he practiced law for 14 years before joining The Times in 2002. More about Adam Liptak

Top 10 International Anti-Corruption Developments for March 2024

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past month, with links to primary resources. This month we ask: Why did two Swiss commodities companies resolve Latin American bribery allegations with the U.S. Department of Justice (DOJ)? Which DOJ component will be responsible for enforcing the new Foreign Extortion Prevention Act (FEPA)? How can Luxembourg improve its efforts to combat foreign bribery? The answers to these questions and more are here in our March 2024 Top 10.

1. Swiss Commodities Trader Pleads Guilty in Connection with Ecuador Bribery Scheme

On March 1, 2024, DOJ announced that Gunvor S.A. had pleaded guilty in the Eastern District of New York to one count of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA). Between 2012 and 2020, the company allegedly paid more than $97 million to third-party intermediaries knowing that some portion of those funds would be used to bribe officials at the Ecuadorian Ministry of Hydrocarbons and at Ecuador’s national oil company, Empresa Publica de Hidrocarburos del Ecuador (PetroEcuador), in exchange for contracts to acquire oil products. The money was allegedly funneled through a complicated network of shell companies and offshore bank accounts, including accounts in the United States, and several meetings in furtherance of the conspiracy were allegedly held in the Miami area. The company agreed to pay a total of over $661 million, comprised of a criminal monetary penalty of approximately $374.5 million and forfeiture of approximately $287 million in profits connected to the alleged bribery scheme. According to DOJ, the fine amount represents a 25% reduction off the 30th percentile of the U.S. Sentencing Guidelines range, reflecting the company’s cooperation and remediation, but also a prior bribery scheme in Africa that was the subject of an October 2019 resolution with Swiss authorities. DOJ will credit up to one quarter of the monetary penalty each for amounts the company pays to resolve related investigations by Swiss and Ecuadorian authorities. Switzerland also announced its parallel resolution on March 1, 2024. DOJ did not impose an independent compliance monitor as part of its resolution, based on the company’s remediation and the state of its compliance program, as demonstrated, at least in part, through effectiveness testing. Former Gunvor employee Raymond Kohut pleaded guilty in April 2021 for his role in the scheme. According to DOJ’s press release, two intermediaries, Antonio Pere Ycaza and Enrique Pere Ycaza, pleaded guilty to related FCPA and money laundering charges in October 2020, and an allegedly corrupt PetroEcuador official, Nilsen Arias Sandoval, pleaded guilty to a money laundering charge in January 2022. (For more on the Petroecuador prosecutions, please see our April 2018 , September 2018 , November 2018 , April 2019 , October 2019, November 2019 , December 2019 , January 2020 , February 2020 , September 2020 , and January 2021 Top 10s.)

2. Swiss Commodities Trader Pleads Guilty in Connection with Brazilian Bribery Scheme

On March 28, 2024, DOJ announced that Trafigura Beheer B.V. had pleaded guilty in the Southern District of Florida to one count of conspiracy to violate the FCPA’s anti-bribery provisions. Between 2003 and 2014, the company allegedly paid nearly $20 million in “corrupt commissions,” portions of which were used to bribe officials at Brazil’s national oil company, Petróleo Brasileiro S.A. (Petrobras), in order to secure improper advantages and to retain and obtain business in connection with the purchase and sale of oil products. The company agreed to pay a total of nearly $127 million, comprised of a criminal monetary penalty of approximately $80.5 million and forfeiture of approximately $46.5 million in profits connected to the alleged bribery scheme. DOJ will credit up to $26.8 million of the monetary penalty for any amount Trafigura pays to resolve a related investigation by Brazilian authorities. According to DOJ, the fine amount represents a 10% discount off the fifth percentile of the U.S. Sentencing Guidelines range, which accounts for the company’s cooperation and remediation, as well as its 2006 guilty plea for entry of goods by means of false statements and 2010 conviction in the Netherlands for export and environmental misconduct. The company was also indicted in Switzerland in December 2023 for a scheme to bribe Angolan government officials in exchange for ship-chartering and bunkering contracts between 2009 and 2010. DOJ did not impose an independent compliance monitor as part of its resolution, based on the company’s remediation and the state of its compliance program.

3. Waste Management Executive Charged in Conspiracy to Bribe Foreign Officials in Latin America

On March 19, 2024, DOJ announced that Mexican citizen Abraham Cigarroa Cervantes, a former finance director of the Latin American division of waste management company Stericycle, Inc., had been indicted in the Southern District of Florida on charges that he conspired to violate the FCPA’s anti-bribery and books and records provisions. From 2011 to 2016, Cigarroa and others allegedly paid over $10 million in bribes to foreign officials in Argentina, Brazil, and Mexico in order to obtain and retain business and secure advantages in connection with providing waste management services. The bribe payments, which represented a percentage of underlying contracts payments made by or owing from a government customer, were allegedly tracked in spreadsheets and disguised with code words and euphemisms. Cigarroa and others also allegedly created false books and records to conceal the bribe payments, and Cigarroa allegedly submitted and maintained falsified Sarbanes-Oxley certifications and business unit representation letters falsely attesting that the company’s books, records, and accounts were accurate. In February 2024 , Mauricio Gomez Baez, former Stericycle Senior Vice President, pleaded guilty to one count of conspiracy to violate the FCPA’s anti-bribery provisions. Stericycle entered into resolutions with DOJ and SEC in April 2022 , agreeing to pay $84 million in penalties, for related conduct.

4. DOJ Announces New Whistleblower Pilot Program Targeting FCPA Violations and Other Offenses

On March 7, 2024, Deputy Attorney General Lisa Monaco announced during her keynote address at the American Bar Association’s 39th National Institute on White Collar Crime that DOJ would establish a whistleblower Pilot Program, pursuant to its authority to pay awards for “information or assistance leading to civil or criminal forfeitures,” to incentivize individuals to report allegations of corporate wrongdoing to DOJ. According to Monaco, DOJ’s Pilot Program is intended to “fill gaps” by offering financial incentives to disclose misconduct in areas in which no other incentives currently exist. Monaco said that DOJ is particularly interested in reports relating to certain crimes, including FCPA cases outside the jurisdiction of the SEC, criminal abuse of the U.S. financial system, and domestic corruption cases. Monaco stated that DOJ will undertake a “90-day policy sprint” to gather information, consult with stakeholders, and design the whistleblower Pilot Program before the program is made effective later this year. DOJ’s Criminal Division, and in particular its Money Laundering and Asset Recovery Section (MLARS), will lead this information gathering effort. (For more on the Pilot Program, see our client alert .) DOJ is hoping to capitalize on the perceived success of similar whistleblower reward programs, particularly the program run by SEC ( see, e.g ., #8 in our November 2023 Top 10). Countries such as the UK are also considering implementing their own whistleblower award programs.

5. Foreign Extortion Prevention Act (FEPA) Prosecutions Assigned to DOJ’s FCPA Unit

On March 8, 2024, Acting Assistant Attorney General Nicole Argentieri announced that “the same attorneys who investigate and prosecute FCPA violations w[ill] also handle cases brought under FEPA [the Foreign Extortion Prevention Act].” FEPA, which became law in December 2023 , effectively extends the FCPA, which applies only to bribe payers, to foreign government officials who demand or accept bribes from companies and individuals with a U.S. nexus. Argentieri also announced that the Justice Manual had been updated to reflect this assignment. We agree with Argentieri’s view that assigning FEPA to the FCPA Unit “makes sense,” as FEPA prosecutions are essentially the flip side of FCPA prosecutions. For many years, the FCPA Unit had used other laws, primarily the federal money laundering laws, to prosecute foreign officials who received bribes given to them in violation of the FCPA. (We had previously predicted that FEPA cases would be assigned to the FCPA Unit .)

6. Executives of European Aircraft Manufacturer Acquitted of Bribery Charges in the UK

On March 6, 2024, the UK Serious Fraud Office (SFO) announced that Jeffrey Cook, former managing director of former Airbus SE subsidiary GPT Special Project Management Ltd. (GPT) was found guilty of one count of misconduct in public office. Before joining GPT, Cook allegedly took £70,000 in bribes while he was employed with Britain’s Ministry of Defence and seconded to defense contractor Paradigm, which was owned by Airbus SE. Cook, as well as John Mason, a part owner of the firm that directed the payments, were acquitted of corruption charges accusing them of bribing a Saudi prince and his associates to secure business for GPT. In their successful defense, Cook and Mason argued that the British government knew and approved of the millions of pounds of payments to the Saudi royal family and other senior Saudi officials that were intended to secure the deals. In April 2021 , GPT pleaded guilty to one count of corruption, contrary to Section 1 of the Prevention of Corruption Act 1906, and was ordered to pay a confiscation order of £20.6 million, a fine of £7.5 million, and the SFO’s costs of £2.2 million. In January 2020 , Airbus SE agreed to pay over $3.9 billion in total penalties, the largest global foreign bribery resolution in history according to DOJ, to resolve foreign bribery allegations with authorities in the United States, France, and the UK, as well as export controls allegations in the United States, for unrelated conduct.

7. Singapore Charges Former Marine Contractor Employees for Bribing Brazilian Officials

On March 28, 2024, Wong Weng Sun and Lee Fook Kang, former executives of Jurong Shipyard Pte Ltd, a wholly owned subsidiary of Singapore-based offshore and marine contractor Sembcorp Marine (now known as Seatrium following a merger), were charged with bribing Brazilian officials to further the company’s business interests in the country. According to a joint press release from Singapore’s Corrupt Practices Investigation Bureau (CPID) and the Attorney General’s Chambers (AGC), between 2009 and 2014, the former executives paid approximately $44 million to a Brazilian middleman, Guilherme Esteves de Jesus, for the benefit of Petrobras officials, Brazilian politicians, and other Brazilian officials. Both executives were charged with five counts of conspiracy to corruptly give gratification to a Brazilian official in violation of Singapore’s Prevention of Corruption Act . Wong is additionally facing an obstruction charge for allegedly ordering two employees to remove an email containing evidence of the bribery. According to the joint press release, the Public Prosecutor is also in discussions with Seatrium on a deferred prosecution agreement.

8. South Africa Orders Subsidiary of German Software Company to Repay Funds Received through Bribery

On March 20, 2024, a Special Tribunal in South Africa ordered Systems Applications Products (South Africa) (Pty) Ltd (SAP South Africa), a subsidiary of Germany’s SAP SE, to repay 500 million rand that it had received pursuant to two software license contracts with South Africa’s national electricity company, Eskom. The order approved a settlement agreement between the company and South Africa’s Special Investigating Unit (SIU), which is responsible for recovering financial losses suffered by the state as a result of negligence or corruption and was authorized by South African President Cyril Ramaphosa to investigate allegations of corruption, malpractice, and maladministration in Eskom’s affairs. According to the SIU , the contracts were not in accordance with South African law and were entered into illegally. The SIU resolution is part of a larger resolution between South African authorities and SAP, which also entered into related FCPA resolutions with DOJ and SEC in January 2024 . DOJ agreed to credit against the U.S. criminal penalty up to $55.1 million in penalties paid to South African authorities.

9. World Bank Debars Consultant for Corrupt Payments in Nigeria

In a Notice of Uncontested Sanctions Proceedings dated March 12, 2024, the World Bank’s Office of Suspension and Debarment recommended that Akuboh Victor Uneojo be debarred for at least two years and one month after he admitted to making two corrupt payments to an intermediary that were intended to be transferred to an official working on the Nigeria National Social Safety Nets Project in order to improperly influence the official’s actions in connection with the execution of an individual consultancy contract under the Project. According to the Notice, the World Bank’s investigation uncovered evidence demonstrating that Akuboh “may have felt coerced by the soliciting public official regarding the corrupt payments.” The World Bank debarment could result in Akuboh’s cross-debarment by other multilateral development banks under the April 9, 2010, Agreement for Mutual Enforcement of Debarment Decisions .

10. OECD Working Group on Bribery Urges Luxembourg to Strengthen Foreign Bribery Enforcement Efforts.

On March 15, 2024, the OECD Working Group on Bribery announced the results of its Phase 4 evaluation of Luxembourg’s implementation of the OECD Anti-Bribery Convention. All parties to the Convention are subject to a rigorous peer-review process, Phase 4 of which focuses on the evaluated country’s enforcement of the Convention and considers the country’s particular challenges and positive achievements. The Working Group found that Luxembourg has undertaken substantial legislative and institutional reforms since its last evaluation in 2011, including constitutional reforms aimed at strengthening and modernizing the status of judges and prosecutors, the adoption of a new whistleblower protection regime, the implementation of a plea‑bargaining mechanism to help facilitate the resolution of complex financial cases, and the strengthening of its ability to execute foreign-bribery-related mutual legal assistance requests. But the Working Group also found Luxembourg significantly lacking in its efforts to investigate and prosecute foreign bribery cases. The Working Group recommended, among other things, that Luxembourg devote greater attention and resources to the detection, investigation, and prosecution of foreign bribery and increase the level of fines for foreign bribery offenses.

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