“The standards for preventing corruption as a matter of law are now higher on Canadian corporations and on corporations in the United Kingdom and even in Russia, believe it or not,” says Peter Mantas, partner with law firm Fasken Martineau DuMoulin.
Even though the Cardin-Lugar anti-corruption rules passed into law in 2010, they were to come into effect only next year. But in the interim, the adoption of Cardin-Lugar in combination with the older Foreign Corrupt Practices Act (1977) and robust enforcement practices placed the United States at the forefront of the fight against corruption.
“Sometimes it's not just about the laws but what you do with the laws. The Americans and, to a lesser degree—but not by much—the British have been very aggressive about pursuing corruption issues,” Mantas says.