The report Sanctioning Foreign Bribery through Multijurisdictional Resolutions examines how countries co-ordinate the investigation and resolution of transnational corruption cases involving several jurisdictions, where at least one Party to the OECD Anti-Bribery Convention takes action against a legal person in co-ordination with one or more other jurisdictions that are also enforcing their laws in relation to the same or a related corruption scheme.
The report notes that this practice began with the Siemens case, when in 2008 Germany and the United States first announced parallel resolutions in a transnational bribery case. Since then, enforcement in major foreign bribery cases has gradually shifted from isolated national investigations towards co-ordinated action by several countries.
The OECD analysed 31 such cases resolved between December 2008 and March 2026, involving 12 jurisdictions. The United States played the most active role: it was involved in all the cases reviewed, and U.S. authorities accounted for around 58% of individual resolutions. It was followed by Brazil (15%), the United Kingdom (7%), Switzerland (6%) and France (4%).
In total, the report reviewed 114 individual resolutions and agreements, 113 of which were concluded through non-trial resolutions (NTRs). The publication identifies several main types of NTRs: Deferred Prosecution Agreement-like resolutions (DPAs), Non-Prosecution Agreement-like resolutions (NPAs), civil and administrative resolutions, and plea agreements or equivalent procedures. The OECD notes that virtually all of the resolutions reviewed used such mechanisms, demonstrating their key role in co-ordinating transnational foreign bribery cases.
The OECD pays particular attention to how countries co-ordinate such cases in practice. Resolutions may be concluded either simultaneously or consecutively: in 21 of the 31 cases reviewed, the resolutions were reached within roughly the same period, while in 10 cases they were concluded at different times, but with account taken of actions by other jurisdictions. Such co-ordination relies both on formal mutual legal assistance mechanisms and on more flexible channels of interaction between prosecutors, regulators and investigative authorities, including parallel investigations, joint investigation teams and preliminary consultations between competent authorities.
Sanctions in the cases analysed were imposed on at least 74 entities, including parent companies, subsidiaries and affiliated entities. The report also emphasises that such resolutions are usually not limited to fines: sanctions may include confiscation or disgorgement of proceeds, compensation to affected states or state-owned entities; companies may also be required to improve their compliance programmes, undergo independent monitoring and submit regular reports to the authorities.
According to the OECD’s estimates, the total amount of fines, confiscation and other financial sanctions imposed in these cases exceeded USD 33.7 billion in constant 2024 U.S. dollars. At the same time, countries are increasingly co-ordinating not only their investigations, but also the allocation of recovered funds. This makes it possible to take into account each jurisdiction’s contribution to the case, avoid duplicative sanctions for the same misconduct, and direct part of the recovered funds to the countries harmed by the corrupt conduct.
The OECD also notes that, in recent years, transnational corruption cases have increasingly involved not only countries prosecuting companies for the “supply side” of bribery, but also countries whose public officials received the unlawful payments. This makes it possible to address international corruption schemes more comprehensively: alongside corporate liability, conditions are created for remediation of harm and for the prosecution of natural persons involved in corruption.
At the same time, countries’ participation in such resolutions depends on the existence of an appropriate legal framework. Relevant factors include the availability of non-trial resolution mechanisms, the ability to co-ordinate with foreign authorities, rules on evidence sharing, judicial or other oversight, procedures for crediting sanctions imposed in other jurisdictions, and tools that allow enforcement against natural persons to be preserved after a case against a company has been resolved.
According to the OECD, to further develop this practice, countries should strengthen international co-operation mechanisms, enable parallel or joint investigations, promptly approach other interested jurisdictions in cases with a cross-border element, and use tools that allow financial sanctions to be allocated in proportion to each country’s role and the harm caused.