Recent Developments In Japanese Enforcement Of Foreign Bribery Laws

In recent years, Japan has been under increasing scrutiny and pressure from the international community regarding its enforcement of its anti-corruption laws. A signatory to the OECD Anti-Bribery Convention, Japan enacted an amendment to its Unfair Competition Prevention Law ("UCPL"), which came into force on February 15, 1999, to address bribery of foreign public officials. But the OECD Working Group on Bribery in International Transactions has continually criticized Japan for its relatively lax enforcement of anti-corruption. Indeed, while the UCPL is broad in scope and prohibits offering or giving any benefit to a foreign public official, Japan is reported to have prosecuted only four cases of bribery since 1999. In February 2014, the OECD Working Group expressed significant concerns about the lack of foreign bribery enforcement in Japan, noting that numerous allegations involving Japanese companies had been reported in the media, yet did not seem to have been