On 26th August, Baker McKenzie reported that a law introduced by Ireland last year, as part of an international drive aimed at combatting corruption, has been found not to be in compliance with the OECD convention behind the proposal.  The Criminal Justice (Corruption Practices) Act 2018 included a requirement that the offence be a crime both in Ireland and in the country where the bribery allegedly occurred, a requirement called “dual criminality”.  However, the OECD has recently said that such a requirement is inconsistent with Article 1 of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, which requires an autonomous foreign bribery offence.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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