Australia's anti-foreign bribery framework
Australia has signed and ratified the Organisation for Economic
Co-operation and Development (OECD) Convention on Combating Bribery of Foreign
Public Officials in International Business Transactions (OECD Convention),
as well as the United Nations Convention Against Corruption (UNCAC). The
principles enshrined in these conventions are embodied in Australia's criminal
law—including through explicit anti-bribery provisions in the federal Criminal
Code Act 1995 (Criminal Code). Despite this commitment Australia's record
in investigating and prosecuting foreign bribery matters is poor and, as a
result, Australia has been criticised on its implementation of the conventions,
particularly the OECD Convention.
This chapter examines Australia's international foreign bribery obligations
and the way in which they have been implemented through domestic law. It then outlines
recent developments in anti-foreign bribery legislation before looking at relevant
reports examining the effectiveness of Australia's foreign bribery framework.
OECD Convention on Combating
Bribery of Foreign Public Officials in International Business Transactions (OECD
The OECD Convention was adopted by the OECD on 21 November 1997.
It entered into force on 15 February 1999 and has been ratified by all 34 OECD member
countries, as well as Argentina, Brazil, Bulgaria and South Africa. Australia signed the OECD Convention on 7 December 1998 and it
was ratified in Parliament on 18 October 1999.
The preamble to the OECD Convention states that:
...bribery is a widespread phenomenon in international business
transactions, including trade and investment, which raises serious moral and
political concerns, undermines good governance and economic development, and
distorts international competitive conditions...all countries share a
responsibility to combat bribery in international business transactions...
Article 1 of the OECD Convention requires that signatories
criminalise the bribery of foreign public officials:
Each Party shall take such measures as may be necessary to
establish that it is a criminal offence under its law for any person
intentionally to offer, promise or give any undue pecuniary or other advantage,
whether directly or through intermediaries, to a foreign public official, for
that official or for a third party, in order that the official act or refrain
from acting in relation to the performance of official duties, in order to
obtain or retain business or other improper advantage in the conduct of
Article 1 also requires that signatories criminalise the
incitement, aiding and abetting, and authorisation of bribery of foreign public
The OECD Convention also contains provisions relating to
sanctions, jurisdiction, enforcement, mutual legal assistance and extradition.
United Nations Convention against
UNCAC entered into force on 14 December 2005, and has 140
signatories and 178 parties. It was signed by Australia on 9 December 2003 and
ratified by the Parliament on 7 December 2005.
Article 1 sets out the purposes of the UNCAC:
promote and strengthen measures to prevent and combat corruption more
efficiently and effectively;
promote, facilitate and support international cooperation and technical
assistance in the prevention of and fight against corruption, including in
promote integrity, accountability and proper management of public affairs and
Chapter III of UNCAC deals with criminalisation and law
enforcement. In particular, article 16 provides:
State Party shall adopt such legislative and other measures as may be necessary
to establish as a criminal offence, when committed intentionally, the promise,
offering or giving to a foreign public official or an official of a public international
organization, directly or indirectly, of an undue advantage, for the official
himself or herself or another person or entity, in order that the official act
or refrain from acting in the exercise of his or her official duties, in order
to obtain or retain business or other undue advantage in relation to the
conduct of international business.
State Party shall consider adopting such legislative and other measures as may
be necessary to establish as a criminal offence, when committed intentionally,
the solicitation or acceptance by a foreign public official or an official of a
public international organization, directly or indirectly, of an undue
advantage, for the official himself or herself or another person or entity, in
order that the official act or refrain from acting in the exercise of his or
her official duties.
Chapter IV of UNCAC deals with international cooperation, making
provision for extradition, transfer of sentenced persons, mutual legal
assistance, transfer of criminal proceedings, law enforcement cooperation,
joint investigations and special investigative techniques.
Domestic implementation of international obligations
Current legislative framework
The foreign bribery offence
Division 70 of the Criminal Code embodies Australia's ratification
of the OECD Convention. Division 70 was inserted in the Criminal Code by the Criminal
Code Amendment (Bribery of Foreign Public Officials) Act 1999. It was
- prohibit providing or offering a benefit which is not legitimately
due to another person with the intention of influencing a foreign public
official in the exercise of his or her duties in order to obtain or retain
business or obtain or retain a business advantage that is not legitimately due
to the recipient or intended recipient;
- apply the prohibition to conduct within and outside Australia, so
long as, where the conduct occurs wholly outside Australia, the person is an
Australian citizen or the company is a company incorporated in Australia;
- ensure that the ancillary offences of attempt, complicity,
incitement and conspiracy which occur within and outside Australia apply where
they relate to conduct included in the primary offence (clause 70.2); and
- ensure Australia complies with the key feature of the OECD
Subsection 70.2(1) of the Criminal Code, as amended, provides
person is guilty of an offence if:
a benefit to another person; or
a benefit to be provided to another person; or
to provide, or promises to provide, a benefit to another person; or
an offer of the provision of a benefit, or a promise of the provision of a
benefit, to be made to another person; and
benefit is not legitimately due to the other person; and
first-mentioned person does so with the intention of influencing a foreign
public official (who may be the other person) in the exercise of the official’s
duties as a foreign public official in order to:
or retain business; or
or retain a business advantage that is not legitimately due to the recipient,
or intended recipient, of the business advantage (who may be the first-mentioned
This liability can also attach to a body corporate:
Code applies to bodies corporate in the same way as it applies to individuals.
It so applies with such modifications as are set out in this Part, and with
such other modifications as are made necessary by the fact that criminal
liability is being imposed on bodies corporate rather than individuals.
- A body
corporate may be found guilty of any offence, including one punishable by
Prosecutions of foreign bribery by Australian corporations are
not necessarily pursued under the Criminal Code and, depending on the type of
offence, may be prosecuted under other Commonwealth or state legislation.
The Criminal Code also provides for an Australian company to be
held criminally liable for the acts of an employee, agent or officer acting
within the actual or apparent scope of his or her employment. In some circumstances this will mean that the current foreign bribery offence
will apply to foreign subsidiaries of Australian companies. Section 12.3 of the
Criminal Code outlines how the fault element of an offence can be attributed to
the company, including by:
- proving that the body corporate's board of directors
intentionally, knowingly or recklessly carried out the relevant conduct, or
expressly, tacitly or impliedly authorised or permitted the commission of the
- proving that a high managerial agent of the body corporate
intentionally, knowingly or recklessly engaged in the relevant conduct, or
expressly, tacitly or impliedly authorised or permitted the commission of the
- proving that a corporate culture existed within the body
corporate that directed, encouraged, tolerated or led to non-compliance with
the relevant provision, or
- proving that the body corporate failed to create and
maintain a corporate culture that required compliance with the relevant
Therefore, dependent on the specific circumstances of a case, it
may be possible to show that an individual in a foreign subsidiary is acting as
an agent of the parent Australian company; and 'if one of the means of
attributing liability above can be established, the Australian parent company
would be liable for the acts of that individual'.
Australia's foreign bribery legislation carries severe penalties
through the Criminal Code. These were strengthened substantially in 2012. The
applicable penalties currently are:
- for an individual:
- imprisonment of up to 10 years; and/or
- a fine of up to 10,000 penalty units, that is, $2.1 million.
- for a corporation, not more than the greatest of the following:
- a fine of up to 100,000 penalty units (or a maximum amount of
- if the court can determine the value of the benefit, the value of the
benefit obtained directly or indirectly and which is reasonably attributable to
the offending conduct, three times the value of the benefit; or
- if the court cannot determine the value of the benefit, then 10 per cent
of the annual turnover of the corporation during the 12 months ending at the
end of the month in which the offending conduct occurred.
The two defences to the foreign bribery offence are that:
- the conduct concerned was permitted or required by a written law in
the foreign public official's country (lawful conduct defence); or
- the conduct amounted to payment of a facilitation payment.
In order for the lawful conduct defence to be made out, it must
be shown that the conduct of the foreign public official was lawful in the
foreign public official's country, subject to a written law in force in that
foreign country or in the part of the foreign country as the case may be. The
source of applicable law will differ according to the nature of the connection
of the officer with the foreign government or public international
In order for the facilitation payment defence to be made out: the
value of the payment must be minor; the payment must be made for the sole or
dominant purpose of expediting or securing the performance of a routine
government action of a minor nature; and as soon as practicable after the
conduct occurred, the payer must make and keep a signed record of the payment
setting out its value, date, the identity of the foreign public official and
any other person directly involved in the payment, and particulars of the
relevant routine government action. The facilitation payment defence is discussed
in more detail in Chapter 7.
Territorial and nationality
Section 70.5 of the Criminal Code outlines the territorial and
nationality requirements of the foreign bribery offence. Specifically, it
applies where the conduct constituting the offence:
- occurs in Australia, or on board an Australian aircraft or an
Australian ship; or
- outside Australia, where at the time of the alleged offence, the
person who is alleged to have committed it is: an Australian citizen; a
resident of Australia, or a body corporate incorporated by or under a law of
the Commonwealth or of a state or territory.
As such, if a company or its subsidiary is not incorporated under
Australian law, then it is not covered by Australia's foreign bribery offence
unless the relevant conduct occurred in Australia or on board an Australian
aircraft or an Australian ship.
Time for commencement of
The time period for commencing a prosecution under any of the
above provisions is the same as for all criminal offences—which pursuant to section
15B of the Crimes Act 1914 means that a prosecution may be
commenced against an individual at any time if the maximum penalty is a term of
imprisonment of more than six months in the case of a first conviction.
Likewise, a prosecution of a body corporate may be commenced at any time if the
maximum penalty is a fine of more than 150 penalty units in the case of a first
Therefore, as the offence carries a maximum term of imprisonment
of 10 years for an individual and a maximum fine of 100 000 penalty units
for a body corporate, a criminal prosecution for the offence of foreign bribery
can be commenced at any time.
False accounting provisions
In 2016 the Criminal Code was amended to insert new false
provisions. This was, in part, in response to recommendations by the OECD
Working Group on Bribery in 2012 that Australia tailor existing false
accounting offences to address foreign bribery as well as increase the maximum
sanctions against legal persons for false accounting.
The new false accounting laws created a criminal offence, punishable
by significant penalties, of intentionally or recklessly falsifying accounting
documents. Specifically, Division 490.1 of the Corporations Act 2001 (Corporations
Act) creates an offence for intentional false dealing with accounting
documents; and Division 490.2 creates an offence for reckless dealing with
accounting documents. Penalties for individuals are 10 years imprisonment
and/or 10 000 penalty units; and for corporate offenders 100 000 penalty
units or three times the value of the benefit if established; or 10 per cent of
12 month turnover if value cannot be established. Offences apply to any
Australian resident, citizen or corporation as well as any employees or persons
engaged to do work for the corporation, in and outside Australia. The
accounting documents themselves need not be in Australia, and can apply to
accounting documents that are kept under Commonwealth law, or kept to record
the receipt or use of Australian currency.
This part of the chapter is separated by the subject matter of
recent developments in anti-foreign bribery legislation and is not in
Amendments to the foreign bribery
In April 2017, the Attorney-General's Department (AGD) released
draft legislation and a public consultation paper outlining proposed amendments
to the foreign bribery offence in the Criminal Code (2017 consultation paper).
In summarising the need for change, the 2017 consultation paper noted:
The Government is exploring possible amendment to this
offence to improve its effectiveness in addressing foreign bribery, and to
remove possible impediments to a successful prosecution...
The offence in its current form poses challenges for typical
cases of foreign bribery, which may involve the use of third party agents or
intermediaries, instances of wilful blindness by senior management to
activities occurring within their companies and a lack of readily available
The 2017 consultation paper outlined the following proposed
amendments to the foreign bribery offence:
- extend the definition of foreign public official to include
candidates for office;
- remove the requirements that the benefit/business advantage must
be 'not legitimately due' and replace it with the concept of 'improperly
influence' a public official;
- extend the offence to cover bribery to obtain a personal
- create a new foreign bribery offence based on the fault element
- create a new corporate offence of failing to prevent foreign
- remove the requirement of influencing a foreign public official
in the exercise of their official capacity; and
- clarify that the offence does not require the accused to have a
specific business advantage in mind, that business or an advantage can be
obtained for someone else.
A detailed analysis of these proposals is contained in Chapter 4
of this report.
A proposed Deferred Prosecution
Agreement (DPA) scheme
In March 2016, AGD released a public consultation paper on a
possible scheme for DPAs (2016 discussion paper); and in March 2017, a second public consultation paper on a proposed model for a
DPA scheme in Australia for serious corporate crime (2017 DPA model).
A DPA is a voluntary, negotiated settlement between a prosecutor
and a defendant. With respect to the consultation paper on the 2017 DPA model, the AGD noted:
The Australian Government is considering options to
facilitate a more efficient and effective response to corporate crime by encouraging
greater self-reporting by companies. A key focus of this consideration is a
possible DPA scheme.
Under a DPA scheme, where a company or company officer has
engaged in a serious corporate crime, prosecutors have the option to invite the
company to negotiate an agreement to comply with a range of specified
conditions. These conditions typically require the company to cooperate with
any investigation, admit to agreed facts, pay a financial penalty, and
implement a program to improve future compliance. A company will not be
prosecuted in relation to the matters that were the subject of the DPA where
the company fulfils its obligations under the agreement.
A breach of the terms of a DPA may result in the prosecuting
agency commencing prosecution or renegotiating the terms of the DPA with the
A detailed analysis of this proposal is contained in Chapter 5 of
Proposed reforms to corporate and
tax whistleblower provisions
The government committed under the Open Government National
Action plan to harmonise corporate sector whistleblower provisions with those
existing in the public sector and to introduce legislation for this, together
with tax whistleblower provisions, by December 2017.
In December 2016, the Treasury released a public consultation
paper on corporate and tax whistleblowing, which concluded in February 2017.
In October 2017, the government released an exposure draft of the
Treasury Laws Amendment (Whistleblowers) Bill 2017 and supporting explanatory
material for consultation. The proposed reforms to the Corporations Act included:
- expanding the protections to a broader class of people;
- expanding the types of disclosures that will be protected under
- allowing disclosures to parliamentarians and the media in certain
circumstances, if preconditions are satisfied;
- imposing new stringent obligations to maintain the confidentiality
of a whistleblower's identity;
- making it significantly easier for a whistleblower to bring a
claim for compensation where he or she has been victimised;
- creating a new civil penalty offence so that law enforcement
agencies will be able to take action against companies where the civil standard
of proof can be met; and
- requiring all large companies to have a whistleblower policy in
place, with penalties for failing to do so.
Amendments currently before
Following the above consultations on proposed reforms, in
December 2017 the government introduced the:
- Crimes Legislation (Combatting Corporate Crime) Bill 2017 (CCC
bill) which implements, in part, the above proposals to amend the foreign
bribery offence and introduce a DPA scheme; and
- Treasury Laws Amendment (Enhancing Whistleblower Protections)
Bill 2017 (EWP bill) which implements, in part, the above proposals to reform
corporate and tax whistleblower provisions.
The CCC bill proposes a number of amendments to the existing foreign
bribery offence, including:
- extending the definition of 'foreign public official' to include
candidates for office;
- removing the requirement that the benefit and business advantage
be 'not legitimately due' and replacing it with the concept of 'improperly
influencing' a foreign public official;
- clarifying that the offence does not require the accused to have
a specific business advantage in mind;
- clarifying that the business advantage can be obtained for
- extending the offence to cover bribery to obtain a personal
- removing the requirement that the bribe influences the foreign
public official 'in the exercise of their official capacity'.
The CCC bill also seeks to introduce a new corporate offence of
failing to prevent foreign bribery and a DPA scheme, which would apply to
foreign bribery and other specified serious corporate offences.
The EWP bill proposes to consolidate, strengthen and broaden the
existing whistleblower protections and remedies for corporate and financial
sector whistleblowers. The proposed amendments include:
- introducing a single concept of 'regulated entity', 'eligible
whisteblower' 'disclosable conduct' and 'eligible recipient';
- providing for an 'emergency disclosure' to a member of Parliament
of a journalist in specified circumstances; and
- expressly allowing for disclosures to lawyers for the purposes of
obtaining legal advice.
The CCC bill and the EWP bill are discussed further in Chapters 4,
5 and 6 of this report.
Assessment of Australia's implementation of international obligations
The organisations that facilitate the international conventions
provide ongoing assessments of member countries' implementation of the
obligations. In general, these bodies have concluded that Australia's
implementation, though improving over time, remains incomplete. The result is
that Australia is seen on the international stage as failing to adequately tackle
the problem of foreign bribery.
Effectiveness of Australia's
implementation of the OECD Convention
There are a number of reports on Australia's implementation of
the OECD Convention which have made recommendations to improve the
effectiveness of Australia's anti-foreign bribery laws. The OECD has published
the following monitoring reports relating to the implementation of the
convention in Australia:
- 1999 – Phase 1 Report;
- 2006 – Phase 2 Report;
- 2008 – Follow-up to Phase 2 Report;
- 2012 – Phase 3 Report;
- 2015 – Follow-up to Phase 3 Report; and
- 2017 – Phase 4 Report.
The Phase 3 OECD Report and follow-up report, as well as the
Phase 4 OECD report are discussed below.
In the 2012 Phase 3 OECD Report, the OECD noted that:
The foreign bribery offence is becoming a priority for the
Australian government. Australia's first National Anti-Corruption Plan aims to
create a 'whole-of-government approach' to corruption; it is expected to be
adopted by December 2012. In February 2012, Australia concluded a proactive
public consultation on the facilitation payment defence. Guidance has been
amended to clarify that the facilitation payment defence is restricted to
payments of a minor value, and to eliminate certain examples that had caused
concerns. The maximum fine against legal persons for foreign bribery was
substantially raised in 2010. The sharing of tax information was enhanced with
the ratification in August 2012 of the Convention on Mutual Administrative
Assistance in Tax Matters and the amending Protocol.
However, the OECD felt that Australia had not done enough to
criminalise, prosecute and penalise instances of foreign bribery:
While the Working Group on Bribery welcomes Australia's
recent efforts, it has serious concerns that overall enforcement of the foreign
bribery offence to date has been extremely low. Only one foreign bribery case
has led to prosecutions. These prosecutions were commenced in 2011 and are
on-going. Out of 28 foreign bribery referrals that have been received by the
Australian Federal Police (AFP), 21 have been concluded without charges.
In the 2015 Phase 3 Follow-up Report, the OECD declared that
Australia had made good progress on addressing a number of important
recommendations. It cited:
- improvements to the Australian Federal Police's (AFP) policy and
- the establishment of the Fraud and Anti-Corruption Centre (FAC);
- the signing of a memorandum of understanding between the AFP and
the Australian Prudential Regulation Authority (APRA);
- the establishment of an AFP Foreign Bribery Panel of Experts;
- engagement by the AFP with state-level law enforcement to
establish guidelines on reporting foreign bribery and to raise awareness of the
foreign bribery offence;
- restructuring of the Commonwealth Director of Public Prosecutions
(CDPP) operating model to ensure sufficient resources are available to
prosecute foreign bribery; and
- development by the AGD of a whole-of-government approach to
The OECD noted that Australia had fully implemented 16 of its
previous recommendations but nine remained partially implemented and eight not
implemented at all. The OECD observed that increased enforcement is required to determine whether
the use of Australia's corporate liability provisions has been enhanced, and
whether false accounting is being vigorously pursued. It also remarked that more could be done with respect to enforcement.
The Phase 4 OECD Report was released in December 2017. It noted that Australia has stepped up its enforcement of foreign bribery since
2012, when the OECD Working Group on Bribery last evaluated Australia's
implementation of the OECD Convention, with seven convictions in two cases and
19 ongoing investigations. However, in view of the level of exports and outward
investment by Australian companies in jurisdictions and sectors at high risk
for corruption, the report found that Australia must continue to increase its
level of enforcement.
In addition to highlighting recent reforms to the AFP and the
CDPP to increase foreign bribery enforcement, the report identifies several
other achievements and good practices, including:
- strengthened whistle-blower protections in the public sector;
- amendments to the foreign bribery offence to address previously
identified weaknesses; and
- the creation of new false accounting offences in the Criminal
The report further makes a number of recommendations to Australia
aimed at strengthening its foreign bribery enforcement. Key recommendations
highlight the need for Australia to:
- address the risk that the real-estate sector could be used to
launder the proceeds of foreign bribery;
- ensure that authorities have adequate resources to effectively
enforce the foreign bribery offence;
- proactively pursue criminal charges against companies for foreign
- enhance its whistleblower protections in the private sector.
Effectiveness of Australia's
implementation of UNCAC
Article 63 of UNCAC set up a Conference of the States Parties to
the UNCAC. The Conference was tasked with improving the capacity of and
cooperation between States Parties to achieve UNCAC's objectives, and promoting
and reviewing its implementation. In turn, the Conference established an
Implementation Review Group of the UNCAC. Since 2010, the Implementation Review Group has
typically met twice a year in Vienna.
States that are parties to UNCAC are required to undergo a review
of their implementation of key chapters of the UNCAC every five years. Australia's implementation of Chapters III (Criminalisation & Law Enforcement)
and IV (International Cooperation) of UNCAC was reviewed in 2012 and found to
be fully compliant.
In relation to criminalisation and law enforcement, Australia was
commended on the following:
- The broad jurisdiction of the foreign bribery offence, applying
both to conduct within Australia, and to conduct by citizens, residents and
- The definition of 'foreign public official,' which extended to
officials designated by law or custom.
- The money-laundering offences, which incorporate elements of
intent, recklessness and negligence, and which go beyond the minimum standards
in article 23.
- Australia's position that no individual is immune from
prosecution for corruption cases, including parliamentarians.
- The development and expansion of the federal non-conviction-based
forfeiture regime in Australia.
- Australia's positive efforts to ensure severe consequences for
public officials who engage in corruption, including the possible forfeiture of
the public sector contribution to the convicted official's pension fund.
However, the following measures were identified to further
strengthen existing anti-corruption measures:
- Continue to periodically review policies and approach on
facilitation payments in order to effectively combat the phenomenon and
continue to encourage companies to prohibit or discourage the use of such
payments, including in internal company controls, ethics and compliance
programs or measures.
- Consider adopting a written policy on parole that sets forth the
factors for consideration.
- The adoption and implementation of legislation currently under
review for the establishment of a comprehensive scheme for public sector
whistle-blower protection and to expedite access to existing protections for
private sector whistle-blowers.
- Continue the consultative process for the development of a
comprehensive national anti-corruption action plan, which will include an
examination of how to make anti-corruption systems more effective.
In relation to international cooperation, the following successes
and good practices were identified:
- The AFP's impressive cooperation measures at both the domestic
and international levels, and their experience and expertise in detecting and
investigating corruption, which could further assist foreign law enforcement
- The existence of a comprehensive range of investigative tools for
fighting corruption in Australia.
- The high quality of databases to track extradition and mutual
legal assistance matters.
Additionally, it was recommended that Australia:
Continue to periodically review policies and legal mechanisms
to provide the widest measure of mutual legal assistance, including taking
statements of suspects or accused persons, in investigations, prosecutions and
In February 2015, the Australian government submitted to the United
Nations Office on Drugs and Crime that since the completion of the 2012 peer
review, it had made significant progress in responding to two recommendations
identified in the final peer review report. The first, the adoption and implementation of legislation establishing a
comprehensive scheme for public sector whistle-blower protection via the Public
Interest Disclosure Act 2013; and the second, the review of policies and
legal mechanisms to provide the widest measure of mutual legal assistance via
the Extradition and Mutual Assistance in Criminal Matters Legislation
Amendment Act 2012 and the Cybercrime Legislation Amendment Act 2012.
In addition, the government drew attention to the AGD's commitment to initiate
a review the operation of amendments to the Australian mutual legal assistance
framework introduced with the Extradition and Mutual Assistance in Criminal
Matters Legislation Amendment Act 2012.
The second cycle of the independent review by the Implementation
Review Group of Australia's implementation of key chapters II (Preventative
measures) and V (Asset recovery) of UNCAC is not yet complete. However, the
reviewing countries and governmental experts list appear to have been decided.
The committee welcomes the release of the Phase 4 OECD report and
suggests that the government prioritise the consideration and implementation of
the recommendations in that report.
The committee notes that Australia has received generally
positive feedback regarding its implementation of the OECD Convention and UNCAC
in its domestic law. The committee emphasises that both the OECD Working Group
on Bribery and the UNCAC Implementation Review Group have made a number of
recommendations that would improve Australia's foreign bribery regime which
have yet to be fully implemented.
The committee notes recent initiatives to close loopholes in the
legislative regime, introduce false accounting provisions and efforts to
address challenges in prosecution and investigation. However, the committee is
of the view that more needs to be done to enhance the effectiveness of
Australia's implementation of the OECD Convention and UNCAC.
The committee recommends that the Australian Government
prioritise the consideration and implementation of the recommendations in the Phase
4 OECD report, and ensure that proposed legislative changes to the foreign
bribery offence and related measures to strengthen Australia's foreign bribery
regime are implemented or enacted consistent with the Phase 4 OECD report.
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