While many people don’t know it, a bribery scandal in Japan in 1976 was part of the motivation for the Foreign Corrupt Practices Act (FCPA), which was signed into law on December 19, 1977. Almost exactly two decades later, Japan joined the fight against foreign corruption by signing the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Anti-Bribery Convention) on December 17, 1997, and by joining the Working Group on Bribery (Working Group) of the Organisation for Economic Co-operation and Development (OECD). After signing the Anti-Bribery Convention, Japan enacted implementing legislation outlawing foreign bribery, which came into force on February 15, 1999. But this was just the beginning, not the end.

One of the hallmarks of the OECD Working Group on Bribery is its ongoing monitoring function, which Transparency International has described as the “gold standard.” This oversight function is rigorous, and many countries—including Japan recently—have felt the sting of pointed criticism in the Working Group’s monitoring reports. A recent Working Group report (released in February 2014) suggests Japan is undertaking new measures—and committing additional resources—to combat foreign corruption. As one of the world’s largest economies and as a response to such criticism, Japan may well be poised for a new phase of foreign bribery enforcement.