Key takeaways: 

• On November 26, 2021, the Organization for Economic Cooperation and Development published anti-corruption guidelines that update standards from 2009 and significantly expand the expectations of member countries regarding enforcement. 
• The recommendation promotes the use of non-trial resolutions and international cooperation in anti-bribery enforcement; requires countries to incentivize self-reporting, cooperation, and remediation; expands the protections for whistleblowers; heightens expectations for internal controls and corporate compliance programs, including related incentives; discusses the intersection of data protection and anti-corruption compliance; and addresses the demand side of bribery.
• These revised guidelines have the potential to be a game changer in international anti-corruption enforcement, particularly as the OECD evaluates the enforcement efforts of both existing members and new countries seeking to join the OECD against these new standards. We expect to see more non-trial resolutions in OECD countries as well as further incentives for companies to adopt anti-corruption compliance programs.