On 21st October, Clifford Chance published a briefing saying that in June 2019, the OECD Working Group on Bribery in International Transactions criticised Japan’s efforts to combat bribery of foreign public officials.  The OECD has identified continuing weaknesses in Japan’s anti-bribery laws and enforcement, although Japan took steps to implement the majority of the OECD’s recommendations following a 2013 report.  The OECD did commend Japan for its implementation of the Convention in certain areas – e.g. noting that legislation amendments in 2017 criminalised the laundering of the proceeds of foreign bribery and allowed their confiscation.  The article says that OECD identified a “major loophole” and “legislative defects” in Japan’s Unfair Competition Prevention Law (UCPL), calling on Japan to take “urgent” action.   The briefing says that Japan will be in the spotlight for the 2020 Olympics and the OECD report may be just the encouragement it needs to take a tougher stance on foreign bribery.


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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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