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Commentary: Several prominent instances of bribery between US corporations and foreign government officials occurred in the 1970s. This led to criminalising illicit payments under US law: Foreign Corrupt Practices Act 1977 (US) 17 ILM 214 (1978) & 28 ILM 455 (1989). Bilateral intergovernmental agreements facilitated information exchange with a view to prosecuting corporations: for example, Japan–US (1976), Agreement on Procedures for Mutual Assistance in Administration of Justice in the Lockheed Matter, 15 ILM 278 & 1010. Corruption also began to be addressed at the international level: UNGA Resolution 3514 (1975). An Ad hoc Intergovernmental Working Group within ECOSOC formulated a draft Convention: ECOSOC (1977), ‘Report on the Problem of Corrupt Practices in International Commercial Transactions, Part A, Provisions relevant to the Elaboration of an International Agreement to Eliminate and Prevent Illicit Payments in whatever form, in connection with International Commercial Transactions by Transnational and Other Corporations, their Intermediaries and Others Involved’, UN Doc E/6006; ECOSOC Resolution 2041 (1976) on Corrupt Practices and Illicit Payments in International Commercial Transactions. See further, UNCTC (1991), Report on efforts by the UN to address the issue of corrupt practices, UN Doc E/1991/31/Add.1. The UNGA called upon companies and financial institutions to implement its resolutions, observe national law and pursue ethical practices: UNGA Resolution 51/59 (1996) on Action Against Corruption, paragraph 10 & International Code of Conduct for Public Officials; UNGA Resolution 51/191 (1996), paragraph 6 and UN Declaration against Corruption and Bribery in International Commercial Transactions; UNGA Resolution 51/210 (1997) paragraphs 3(d) & (f). Considering an...