Global Convergence On Anti-Corruption Compliance: A Canadian Example

Niko Resources Ltd., an international oil and natural gas exploration and production company headquartered in Calgary, recently pleaded guilty to violations of Canada's Corruption of Foreign Public Officials Act (CFPOA) and agreed to implement compliance procedures and periodically report on that implementation to the Court and to the Royal Canadian Mounted Police. Canada's second prosecution under the CFPOA represents one more example of a growing global consensus on the standards for effective anti-corruption compliance policies, as reflected in the Organisation for Economic Co-operation and Development's (OECD's) best practices guidance. By spelling out these requirements in the plea agreement, Canada has joined the US and the UK in following the OECD guidance. This proceeding reflects a further step in the global convergence on the benchmarks of anti-corruption compliance.