Steven Sampson

Abstract: Over the past decade, a new global regime of anti-corruption has taken shape. Pushed by NGOs such as Transparency International, and with coalitions of international organizations, Western governments, and private business circles, we now have a framework of conventions and regulations that impel governments and international firms to act with integrity and to prevent corruption in business and international development. New anti-bribery laws reward whistleblowers and penalize firms whose employees are caught bribing foreign governments or paying facilitation payments. Yet conventions must be enforced. Statements of good intention are not enough. Governments and firms must show the world that they are actually implementing these new regulations and conventions and establishing anti-corruption programs. We have entered the Age of Compliance. What does compliance look like? How do organizations, firms and countries ‘perform’ compliance? How do they make compliance ‘real’. How do we know that the transparency of compliance practice is not simply a vacuum? Based on fieldwork with various actors in the anti-corruption industry, including Transparency International, this paper describes the elements of the emerging compliance regime.