Transparency International (TI) recently released a consultation draft of its White Paper entitled “Anti-Bribery Guidance for Transactions”. In Part I we discussed the risks to companies involved in international mergers and acquisitions. The TI White Paper notes that anti-corruption and anti-bribery due diligence is “often not undertaken, neglected, or allocated insufficient time and resources.” In Part II we will discuss the due diligence process suggested by Transparency International for such transactions.