by Veronica Root Martinez and Liz Carrasco
Left to proper: Veronica Root Martinez and Liz Carrasco (photographs courtesy of authors)
As anti-corruption compliance applications have turn into normal inside firms, an rising variety of corporations are shifting their focus to the effectiveness of those applications. The Organisation for Financial Cooperation and Growth (OECD) report Corporations’ Assessments of Anti-Corruption Compliance[1] offers an in depth have a look at this shift inside the non-public sector. Drawing on survey information and examples from a variety of corporations, the report highlights a rising recognition that compliance can’t be remoted from an organization’s tradition, management, or construction. In brief, the query shouldn’t be merely whether or not a compliance program exists, however whether or not it’s efficient.
The report contains anonymized firm case research for example varied approaches and insights. This weblog publish explores three key elements of the report: (1) why corporations assess the effectiveness of their anti-corruption compliance applications; (2) what methodologies they use to take action; (3) the instruments corporations leverage to observe progress over time.
Based on the OECD, company anti-corruption compliance is primarily pushed by danger avoidance. Many corporations view compliance with anti-corruption laws as a “means to an finish,” with the tip being the avoidance of sanctions and reputational injury. In consequence, firms tailor their applications to the relevant legislation and consider effectiveness by assessing their means to scale back the danger of enforcement. Corporations reported utilizing United States Division of Justice, the Agence Francaise Anticorruption, or the UK Severe Fraud Workplace requirements as frameworks for his or her compliance applications. Such applications are labeled as “reactive” since they reply to current laws, in distinction to applications pushed from inside the firm.
The report notes that reactive compliance applications might have unintended penalties. First, their efforts are centered on short-term compliance with current legislation fairly than long-term enchancment. With the goal of avoiding enforcement, reactive assessments might characterize points which might be reported as “failures,” discouraging reporting and permitting points to worsen earlier than they’re addressed. In distinction, investigating the root-cause of the problem permits corporations to handle issues that will not be obvious and supply long-term options. This method might encourage staff to report smaller points earlier on and permit for extra environment friendly and cost-effective options.
Though danger avoidance is understandably on the forefront of many corporations’ initiatives, it will be important for compliance departments to border the utility of those applications in enterprise phrases as nicely. Exhibiting a return on compliance investments might justify the price of company compliance applications and encourage extra funding to attain the specified outcomes. It might additionally help investing in evaluation instruments, which can be costly however are necessary for long-term success in compliance efforts. Thus, compliance departments ought to articulate the anticipated advantages of such investments and safe help from administration. That is particularly necessary for corporations with restricted assets as compliance applications may in any other case be seen as an pointless expense.
The report discusses one firm’s return on compliance undertaking (Field 2) and highlights its essential findings. The science-based mannequin identifies compliance competence, choice relevance, and adaptableness as key elements for efficient compliance. “Compliance competence” is outlined as staff’ means to determine and appropriately reply to potential compliance dangers. “Resolution relevance” signifies that compliance is a part of the group’s strategic and operational choice making. “Adaptability” appears at whether or not a compliance program is ready to reply to modifications within the enterprise atmosphere. The findings point out that efficient and environment friendly compliance accounts for 15-18% of variance in enterprise efficiency, suggesting that company compliance is a big issue of enterprise success. As well as, it identifies the measure of success as depending on enter and process-oriented Key Efficiency Indicators (“KPIs”), whereas calling for the creation of outcome-oriented KPIs.
The tradition inside a company largely influences the notion and remedy of corruption inside it. Surveyed corporations recognized a tradition of integrity as the inspiration for efficient compliance, whether or not their staff knew the way to act ethically, did so, and felt comfy reporting misconduct when wanted. Whereas most corporations acknowledged the significance of a tradition of integrity, solely a subset reported taking deliberate steps to construct it. The businesses that actively fostered this tradition had superior, proactive compliance applications, usually due to prior enforcement. Shifting in direction of a holistic method to anti-corruption compliance requires altering evaluation methodology to position better significance on long-term compliance as a substitute of reactive compliance.
The report additionally highlights an organization’s undertaking (Field 3) which offers a scale to evaluate the extent to which company anti-corruption efforts are rooted in a tradition of integrity. It states that deliberation is important to foster an moral tradition inside a company, defining deliberation as “a discursive course of during which stakeholders trade and justify their positions, present mutual respect, and are prepared to reevaluate and revise their preliminary preferences.”[2] The OECD report presents a number of quantitatively measurable gadgets to find out whether or not anti-corruption efforts are based mostly on a tradition of ethics and integrity, resembling involvement by all ranges of the group, the inclusion of exterior stakeholders, and members being free to specific their views.
Shifting from a reactive to proactive anti-corruption compliance program requires altering the methodology employed to evaluate its effectiveness. It additionally requires altering the best way that anti-corruption compliance measures are developed. Compliance officers might want to determine targets, decide the way to obtain these targets, and develop related initiatives in response. The particular objectives of particular person compliance measures ought to information anti-corruption applications and their assessments. For instance, corporations searching for to foster a tradition of integrity can assess whether or not their staff know the way to apply their requirements of conduct to concrete conditions.
The OECD’s Good Observe Steerage, an annex of the OECD Anti-Bribery Suggestion, says that compliance efforts ought to be tailor-made to the corruption dangers that the corporate is uncovered to. Along with company-specific corruption dangers, moral concerns ought to be factored into evaluation methodology to judge the extent to which the tradition of integrity has turn into a part of the corporate. To find out how moral requirements are mirrored in worker conduct, corporations ought to have a look at staff’ capability to self-regulate and draw on inside motives, fairly than exterior enforcement of guidelines. A mixture of quantitative and qualitative inputs permits for a extra complete evaluation of whether or not a compliance program successfully mitigates corruption dangers and fosters moral values.
Common testing of compliance measures is important to develop an efficient anti-corruption program. When undesired outcomes happen, testing permits the corporate to find out the basis trigger and deal with it, adjusting their program as wanted. Surveyed corporations carried out root trigger analyses after low survey scores, undertook transactional testing processes, and utilized survey responses as grounds for enchancment. Whereas linking compliance actions to desired outcomes is tough, corporations might be able to overcome these challenges by testing and utilizing proxies to grasp causal parameters.
It’s crucial that management and multidisciplinary groups are a part of assessments measuring program effectiveness. Surveyed corporations reported that the ‘tone from the highest’ and center administration affect employees responses to anti-corruption efforts. Which means that senior and center administration ought to take possession and lead the implementation of such efforts. To set the ‘tone from the highest’, some corporations made ethics and compliance a part of their recruitment processes, efficiency administration, and monetary incentive insurance policies and processes. As seen in Field 4, one firm included an integrity part into their administration construction and noticed enchancment of their staff’ willingness to report misconduct.
It’s also necessary that cross-disciplinary groups work collectively to make sure that compliance efforts are embedded within the enterprise insurance policies, procedures, and coaching. Such collaboration might cut back the problem of measuring the effectiveness of behavioral interventions by involving specialists from totally different departments with varied ability units. Field 5 discusses the significance of involving cross-disciplinary groups in information analytics, tying it to higher outcomes for the group. Corporations also needs to incentivize conduct that aligns with their targets, actively taking measures to weave moral conduct into day by day operations.
Corporations should measure outcomes and actions to evaluate the effectiveness of their applications. To take action, they have to develop and make the most of correct indicators, examples of which might be seen in Desk 1. Importantly, the OECD cautions that an overemphasis on activity-based indicators—such because the variety of trainings delivered—might obscure whether or not these efforts are literally altering conduct or lowering corruption danger.
Most of the corporations surveyed didn’t share the indications they used to evaluate effectiveness, and those that did had been centered on actions. This can be associated to the problem of measuring outcome-based indicators, which can be mitigated by utilizing proxy indicators. The businesses referred to as for info sharing and authorities help to develop indicators to evaluate anti-corruption efficiency.
Surveys could also be an efficient means to evaluate the extent to which a tradition of integrity has been embedded inside a company. Corporations with extra superior compliance applications go additional by incentivizing moral conduct amongst third events and utilizing surveys that may information future compliance measures. To mitigate self-selection biases and enhance the reliability of findings, corporations can use factorial surveys that assign situations for members to reply to.
The report means that governments might be able to complement firm efforts to judge effectiveness by using information analytics and synthetic intelligence (“AI”). Corporations can leverage information analytics to detect and monitor areas of weak point particular to their firm, examples of which might be seen in Bins 8 and 9. Generative AI has the potential to make assessments of compliance efforts extra environment friendly and enhance the standard of their findings. AI methods based mostly on statistical algorithms and machine studying might present superior stories that determine correlations between sorts of anti-corruption efforts and corruption incidents.
Whereas data-driven anti-corruption compliance applications may present extra refined outcomes and observations, in addition they pose extra prices. First, corporations should determine and map information in all of the methods throughout their organizational construction, which can take time and require the involvement of various departments. Additionally they want to contemplate the potential for biases in AI methods and proactively take steps to mitigate the related dangers. Corporations might be able to deal with issues concerning the confidentiality of data by aggregating and anonymizing information earlier than analyzing it.
Corporations can even make the most of inside and exterior audits to judge the effectiveness of their anti-corruption compliance applications. Most of the massive corporations reported utilizing monitoring features and inputs from inside audits to evaluate their compliance applications. Some corporations took an extra step and utilized exterior audits to judge effectiveness from exterior of the corporate. Whereas massive corporations with superior compliance applications reported discovering much less utility in exterior audits, they could be precious to smaller corporations at an earlier level of their compliance journey. Utilizing behavioral science in audits might assist corporations assess how a compliance program has impacted the group’s tradition.
Cooperation throughout corporations might enhance assessments of anti-corruption compliance effectiveness. Benchmarking, peer studying, and collective motion might maximize collective considering and increase the information with which corporations are working. Peer studying between corporations in industries dealing with related challenges could also be particularly helpful if completed on a confidential foundation. Airbus explains the utility it present in peer studying in Field 10. Different corporations reported wanting to have interaction in peer studying however missing the assets and networks to facilitate it. Corporations might also examine their anti-corruption compliance applications to a bunch of corporations or the business common, a apply often called benchmarking that’s highlighted in Field 11.
Collective motion initiatives involving the efforts of presidency entities, corporations and nongovernmental organizations might also encourage collaborative considering and produce higher assessments of program effectiveness. Sectoral initiatives, business alliances, anti-corruption coalitions, and collaborative platforms are a number of approaches to collective motion. Such initiatives might foster open dialogue amongst corporations, constructing a optimistic tradition round anti-corruption compliance.
Nevertheless, firm stakeholders have expressed reluctance to have interaction with others resulting from confidentiality issues and the potential to jeopardize authentic enterprise pursuits. Different stakeholders contended that public disclosure would construct belief amongst shoppers, staff, and different companies, probably resulting in additional collaboration. Corporations have referred to as for presidency intervention to encourage public-private dialogue and foster a extra clear atmosphere for anti-corruption compliance.
Whether or not corporations are starting their compliance journey or leveraging new instruments to enhance the reliability of their findings, firms should acknowledge that anti-corruption compliance is the accountability of a company and never a single division. Making a tradition of integrity calls for cross-functional management, long-term funding, and significant measurement. By embracing these practices, corporations might be able to not solely cut back corruption danger but in addition display real moral management.
[1] OECD (2025), Corporations’ assessments of anti-corruption compliance, OECD Publishing, Paris, https://doi.org/10.1787/977ed5a8-en.
[2] Organisation for Financial Cooperation and Growth, Corporations’ assessments of anti-corruption compliance, 13 (2025), https://www.oecd.org/content material/dam/oecd/en/publications/stories/2025/03/companies-assessments-of-anti-corruption-compliance_363b6821/977ed5a8-en.pdf.
Veronica Root Martinez is the Simpson Thacher & Bartlett Distinguished Professor of Legislation at Duke College College of Legislation and Lead Advisor to the OECD on its Strengthening Compliance Assessments Initiative. Liz Carrasco is a J.D. scholar at Duke College College of Legislation, Anticipated Class of 2027.
The views, opinions and positions expressed inside all posts are these of the writer(s) alone and don’t symbolize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College College of Legislation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this website and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the writer(s) and any legal responsibility almost about infringement of mental property rights stays with the writer(s).
by Veronica Root Martinez and Liz Carrasco
Left to proper: Veronica Root Martinez and Liz Carrasco (photographs courtesy of authors)
As anti-corruption compliance applications have turn into normal inside firms, an rising variety of corporations are shifting their focus to the effectiveness of those applications. The Organisation for Financial Cooperation and Growth (OECD) report Corporations’ Assessments of Anti-Corruption Compliance[1] offers an in depth have a look at this shift inside the non-public sector. Drawing on survey information and examples from a variety of corporations, the report highlights a rising recognition that compliance can’t be remoted from an organization’s tradition, management, or construction. In brief, the query shouldn’t be merely whether or not a compliance program exists, however whether or not it’s efficient.
The report contains anonymized firm case research for example varied approaches and insights. This weblog publish explores three key elements of the report: (1) why corporations assess the effectiveness of their anti-corruption compliance applications; (2) what methodologies they use to take action; (3) the instruments corporations leverage to observe progress over time.
Based on the OECD, company anti-corruption compliance is primarily pushed by danger avoidance. Many corporations view compliance with anti-corruption laws as a “means to an finish,” with the tip being the avoidance of sanctions and reputational injury. In consequence, firms tailor their applications to the relevant legislation and consider effectiveness by assessing their means to scale back the danger of enforcement. Corporations reported utilizing United States Division of Justice, the Agence Francaise Anticorruption, or the UK Severe Fraud Workplace requirements as frameworks for his or her compliance applications. Such applications are labeled as “reactive” since they reply to current laws, in distinction to applications pushed from inside the firm.
The report notes that reactive compliance applications might have unintended penalties. First, their efforts are centered on short-term compliance with current legislation fairly than long-term enchancment. With the goal of avoiding enforcement, reactive assessments might characterize points which might be reported as “failures,” discouraging reporting and permitting points to worsen earlier than they’re addressed. In distinction, investigating the root-cause of the problem permits corporations to handle issues that will not be obvious and supply long-term options. This method might encourage staff to report smaller points earlier on and permit for extra environment friendly and cost-effective options.
Though danger avoidance is understandably on the forefront of many corporations’ initiatives, it will be important for compliance departments to border the utility of those applications in enterprise phrases as nicely. Exhibiting a return on compliance investments might justify the price of company compliance applications and encourage extra funding to attain the specified outcomes. It might additionally help investing in evaluation instruments, which can be costly however are necessary for long-term success in compliance efforts. Thus, compliance departments ought to articulate the anticipated advantages of such investments and safe help from administration. That is particularly necessary for corporations with restricted assets as compliance applications may in any other case be seen as an pointless expense.
The report discusses one firm’s return on compliance undertaking (Field 2) and highlights its essential findings. The science-based mannequin identifies compliance competence, choice relevance, and adaptableness as key elements for efficient compliance. “Compliance competence” is outlined as staff’ means to determine and appropriately reply to potential compliance dangers. “Resolution relevance” signifies that compliance is a part of the group’s strategic and operational choice making. “Adaptability” appears at whether or not a compliance program is ready to reply to modifications within the enterprise atmosphere. The findings point out that efficient and environment friendly compliance accounts for 15-18% of variance in enterprise efficiency, suggesting that company compliance is a big issue of enterprise success. As well as, it identifies the measure of success as depending on enter and process-oriented Key Efficiency Indicators (“KPIs”), whereas calling for the creation of outcome-oriented KPIs.
The tradition inside a company largely influences the notion and remedy of corruption inside it. Surveyed corporations recognized a tradition of integrity as the inspiration for efficient compliance, whether or not their staff knew the way to act ethically, did so, and felt comfy reporting misconduct when wanted. Whereas most corporations acknowledged the significance of a tradition of integrity, solely a subset reported taking deliberate steps to construct it. The businesses that actively fostered this tradition had superior, proactive compliance applications, usually due to prior enforcement. Shifting in direction of a holistic method to anti-corruption compliance requires altering evaluation methodology to position better significance on long-term compliance as a substitute of reactive compliance.
The report additionally highlights an organization’s undertaking (Field 3) which offers a scale to evaluate the extent to which company anti-corruption efforts are rooted in a tradition of integrity. It states that deliberation is important to foster an moral tradition inside a company, defining deliberation as “a discursive course of during which stakeholders trade and justify their positions, present mutual respect, and are prepared to reevaluate and revise their preliminary preferences.”[2] The OECD report presents a number of quantitatively measurable gadgets to find out whether or not anti-corruption efforts are based mostly on a tradition of ethics and integrity, resembling involvement by all ranges of the group, the inclusion of exterior stakeholders, and members being free to specific their views.
Shifting from a reactive to proactive anti-corruption compliance program requires altering the methodology employed to evaluate its effectiveness. It additionally requires altering the best way that anti-corruption compliance measures are developed. Compliance officers might want to determine targets, decide the way to obtain these targets, and develop related initiatives in response. The particular objectives of particular person compliance measures ought to information anti-corruption applications and their assessments. For instance, corporations searching for to foster a tradition of integrity can assess whether or not their staff know the way to apply their requirements of conduct to concrete conditions.
The OECD’s Good Observe Steerage, an annex of the OECD Anti-Bribery Suggestion, says that compliance efforts ought to be tailor-made to the corruption dangers that the corporate is uncovered to. Along with company-specific corruption dangers, moral concerns ought to be factored into evaluation methodology to judge the extent to which the tradition of integrity has turn into a part of the corporate. To find out how moral requirements are mirrored in worker conduct, corporations ought to have a look at staff’ capability to self-regulate and draw on inside motives, fairly than exterior enforcement of guidelines. A mixture of quantitative and qualitative inputs permits for a extra complete evaluation of whether or not a compliance program successfully mitigates corruption dangers and fosters moral values.
Common testing of compliance measures is important to develop an efficient anti-corruption program. When undesired outcomes happen, testing permits the corporate to find out the basis trigger and deal with it, adjusting their program as wanted. Surveyed corporations carried out root trigger analyses after low survey scores, undertook transactional testing processes, and utilized survey responses as grounds for enchancment. Whereas linking compliance actions to desired outcomes is tough, corporations might be able to overcome these challenges by testing and utilizing proxies to grasp causal parameters.
It’s crucial that management and multidisciplinary groups are a part of assessments measuring program effectiveness. Surveyed corporations reported that the ‘tone from the highest’ and center administration affect employees responses to anti-corruption efforts. Which means that senior and center administration ought to take possession and lead the implementation of such efforts. To set the ‘tone from the highest’, some corporations made ethics and compliance a part of their recruitment processes, efficiency administration, and monetary incentive insurance policies and processes. As seen in Field 4, one firm included an integrity part into their administration construction and noticed enchancment of their staff’ willingness to report misconduct.
It’s also necessary that cross-disciplinary groups work collectively to make sure that compliance efforts are embedded within the enterprise insurance policies, procedures, and coaching. Such collaboration might cut back the problem of measuring the effectiveness of behavioral interventions by involving specialists from totally different departments with varied ability units. Field 5 discusses the significance of involving cross-disciplinary groups in information analytics, tying it to higher outcomes for the group. Corporations also needs to incentivize conduct that aligns with their targets, actively taking measures to weave moral conduct into day by day operations.
Corporations should measure outcomes and actions to evaluate the effectiveness of their applications. To take action, they have to develop and make the most of correct indicators, examples of which might be seen in Desk 1. Importantly, the OECD cautions that an overemphasis on activity-based indicators—such because the variety of trainings delivered—might obscure whether or not these efforts are literally altering conduct or lowering corruption danger.
Most of the corporations surveyed didn’t share the indications they used to evaluate effectiveness, and those that did had been centered on actions. This can be associated to the problem of measuring outcome-based indicators, which can be mitigated by utilizing proxy indicators. The businesses referred to as for info sharing and authorities help to develop indicators to evaluate anti-corruption efficiency.
Surveys could also be an efficient means to evaluate the extent to which a tradition of integrity has been embedded inside a company. Corporations with extra superior compliance applications go additional by incentivizing moral conduct amongst third events and utilizing surveys that may information future compliance measures. To mitigate self-selection biases and enhance the reliability of findings, corporations can use factorial surveys that assign situations for members to reply to.
The report means that governments might be able to complement firm efforts to judge effectiveness by using information analytics and synthetic intelligence (“AI”). Corporations can leverage information analytics to detect and monitor areas of weak point particular to their firm, examples of which might be seen in Bins 8 and 9. Generative AI has the potential to make assessments of compliance efforts extra environment friendly and enhance the standard of their findings. AI methods based mostly on statistical algorithms and machine studying might present superior stories that determine correlations between sorts of anti-corruption efforts and corruption incidents.
Whereas data-driven anti-corruption compliance applications may present extra refined outcomes and observations, in addition they pose extra prices. First, corporations should determine and map information in all of the methods throughout their organizational construction, which can take time and require the involvement of various departments. Additionally they want to contemplate the potential for biases in AI methods and proactively take steps to mitigate the related dangers. Corporations might be able to deal with issues concerning the confidentiality of data by aggregating and anonymizing information earlier than analyzing it.
Corporations can even make the most of inside and exterior audits to judge the effectiveness of their anti-corruption compliance applications. Most of the massive corporations reported utilizing monitoring features and inputs from inside audits to evaluate their compliance applications. Some corporations took an extra step and utilized exterior audits to judge effectiveness from exterior of the corporate. Whereas massive corporations with superior compliance applications reported discovering much less utility in exterior audits, they could be precious to smaller corporations at an earlier level of their compliance journey. Utilizing behavioral science in audits might assist corporations assess how a compliance program has impacted the group’s tradition.
Cooperation throughout corporations might enhance assessments of anti-corruption compliance effectiveness. Benchmarking, peer studying, and collective motion might maximize collective considering and increase the information with which corporations are working. Peer studying between corporations in industries dealing with related challenges could also be particularly helpful if completed on a confidential foundation. Airbus explains the utility it present in peer studying in Field 10. Different corporations reported wanting to have interaction in peer studying however missing the assets and networks to facilitate it. Corporations might also examine their anti-corruption compliance applications to a bunch of corporations or the business common, a apply often called benchmarking that’s highlighted in Field 11.
Collective motion initiatives involving the efforts of presidency entities, corporations and nongovernmental organizations might also encourage collaborative considering and produce higher assessments of program effectiveness. Sectoral initiatives, business alliances, anti-corruption coalitions, and collaborative platforms are a number of approaches to collective motion. Such initiatives might foster open dialogue amongst corporations, constructing a optimistic tradition round anti-corruption compliance.
Nevertheless, firm stakeholders have expressed reluctance to have interaction with others resulting from confidentiality issues and the potential to jeopardize authentic enterprise pursuits. Different stakeholders contended that public disclosure would construct belief amongst shoppers, staff, and different companies, probably resulting in additional collaboration. Corporations have referred to as for presidency intervention to encourage public-private dialogue and foster a extra clear atmosphere for anti-corruption compliance.
Whether or not corporations are starting their compliance journey or leveraging new instruments to enhance the reliability of their findings, firms should acknowledge that anti-corruption compliance is the accountability of a company and never a single division. Making a tradition of integrity calls for cross-functional management, long-term funding, and significant measurement. By embracing these practices, corporations might be able to not solely cut back corruption danger but in addition display real moral management.
[1] OECD (2025), Corporations’ assessments of anti-corruption compliance, OECD Publishing, Paris, https://doi.org/10.1787/977ed5a8-en.
[2] Organisation for Financial Cooperation and Growth, Corporations’ assessments of anti-corruption compliance, 13 (2025), https://www.oecd.org/content material/dam/oecd/en/publications/stories/2025/03/companies-assessments-of-anti-corruption-compliance_363b6821/977ed5a8-en.pdf.
Veronica Root Martinez is the Simpson Thacher & Bartlett Distinguished Professor of Legislation at Duke College College of Legislation and Lead Advisor to the OECD on its Strengthening Compliance Assessments Initiative. Liz Carrasco is a J.D. scholar at Duke College College of Legislation, Anticipated Class of 2027.
The views, opinions and positions expressed inside all posts are these of the writer(s) alone and don’t symbolize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College College of Legislation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this website and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the writer(s) and any legal responsibility almost about infringement of mental property rights stays with the writer(s).
