TOWARD A NORTH AMERICAN ANTI- CORRUPTION REGIME

The United States’ Anti-Corruption Regime In the United States, a realism about the dangers of corruption goes back to the founding of the country. [...] Additionally, in order to bring some legal certainty, the law provides several guidelines for companies to follow, including: adopting a procedure manual that reflects the responsibilities and tasks of each area of the company, specifying the leadership of the company; creating and distributing a code of conduct to all the members of the company that can be effectively implemented; implementing an. [...] The remaining members include: the head of the 9 Ministry of Public Administration (SFP); the head of the Superior Audit of the Federation (ASF); the head of the Special Prosecutor's Office for Combating Corruption; a representative of the federal judiciary council; the president of the National Institute of Transparency, Access to Information and Protection of Personal Data (INAI); and the presid. [...] The CFPOA was a counterpart to the provisions embedded in Sections 119-121 of the Criminal Code outlawing the corruption of domestic public officials, fraud, and the like.24 Concern about corruption in Canada moved higher up the policy agenda after 2000 thanks to a number of corruption scandals. [...] Similar to the UK, any Agreement is required to undergo judicial review to determine that 1) it is “in the public interest”; and 2) the “terms of the agreement are fair, reasonable and proportionate” before it is allowed to proceed.28 The Canadian regime is also unique with respect to the extent to which it prioritizes and allows for compensation to be paid to victims of the malfeasance in questio.