Welcome to our September Update
A note from our Steering Committee
Welcome to the September edition of the Bribery Prevention Network bulletin. This edition arrives at a significant moment for Australia’s foreign bribery framework — the public consultation on the statutory review of the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 closed on 10 September, marking an important step in assessing how the law is working in practice and what further improvements may be needed. The BPN will continue to monitor and engage with this process closely.
This edition also reflects a busy period for anti-bribery enforcement and policy. We saw a domestic foreign bribery prosecution in Australia, a Goldman Sachs banker convicted under the FCPA, and the OECD issuing a due diligence warning on Türkiye. The BPN also had the pleasure of hosting a panel at APSACC 2026 in Canberra earlier this month, and were honoured to present to the Advanced Foreign Bribery Program in August.
As always, the BPN Hub remains your go-to resource for practical, free guidance on preventing, detecting and addressing bribery and corruption. We encourage you to explore the full library at briberyprevention.com.
|
|
The Attorney-General’s Department has now completed its public consultation as part of the statutory review of the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024. The review assesses whether the Act is meeting its goals in practice and whether further amendments are required.
Public consultations closed on 10 September, with wo resources to support your engagement:
Find out more here.
|
|
Queensland Police Service, with the assistance of the AFP and NACC, extradited and charged a man following investigations into the alleged attempted bribery of a Clean Energy Council (CEC) public official. It is alleged the 39-year-old Chinese national handed the official a bag of tea containing $20,000 cash during a business meeting in Camp Hill, in an attempt to secure approval of foreign solar panels in Australia. The CEC was made aware of the incident promptly by the intended recipient.
The case is a reminder that training and communication on bribery prevention must reach every level of an organisation — not just senior leadership. Employees who know how to recognise and respond to a bribe are a critical line of defence. Explore training resources at briberyprevention.com.
Find out more here.
|
|
The OECD Working Group on Bribery has issued a due diligence warning against Türkiye, following a Phase 4 Follow-Up Report finding that foreign bribery enforcement remains poor. Key concerns include:
- Legislative deficiencies in corporate liability, false accounting, and confiscation
- Inability to fine individuals for foreign bribery
- Ineffective detection of foreign bribery, including lack of whistleblower protection
- No meaningful efforts to investigate and prosecute actual foreign bribery allegations
For businesses engaging with Turkish counterparties, this is a signal to review your due diligence processes. Find due diligence resources at briberyprevention.com.
Find our more here.
|
|
Asante Kwaku Berko was convicted by a federal jury in Brooklyn on all FCPA counts for paying bribes to Ghanaian government officials at multiple levels to secure a power plant development contract.
The conviction is a further signal of sustained US enforcement activity.
Australian companies with US operations or US-dollar transactions should be alert to their FCPA exposure. Find red flag resources at briberyprevention.com.
Find out more here.
|
|
 AFP Optimal Investigation Outcomes Guideline: what it means for your business
The AFP’s Optimal Investigation Outcomes Guideline incentivises corporations to self-report bribery and cooperate with investigations by offering civil, non-conviction-based resolutions under the Proceeds of Crime Act 2002, rather than criminal prosecution. Key takeaways:
- Proactively self-reporting and cooperating with authorities can minimise legal consequences
- A genuine culture of integrity helps prevent issues from arising and supports investigations when they do
- Businesses should implement steps to prevent re-offending and redress harm caused
Read the AFP guideline and explore related resources at briberyprevention.com.
|
|
Other Resource Highlights:
- Understanding ‘adequate procedures’ – a key element in Australia’s foreign bribery law reforms (Allens) Read here
- Anti-corruption ethics and compliance program for business: a practical guide (UNODC) Read here
- Anti-corruption and integrity training: learning how to resist corruption Read Here
|
|
|
BPN hosts panel at APSACC 2026 — 7–9 September, Canberra
The Bribery Prevention Network hosted a panel at APSACC 2026 — Australia’s premier corruption prevention conference — on the topic of ‘Integrity at the public and private interface’.
The panel brought together voices from Allens, the AFP, Westpac Group, and the UN Global Compact Network Australia, to explore how businesses and public sector agencies can work together to strengthen integrity frameworks.
Thank you to the National Anti-Corruption Commission for inviting the BPN to speak alongside leading anti-corruption practitioners from across Australia. We thank our panelists and all those who attended.
Find out more about the BPN panel here.
|
|
BPN presents to the Advanced Foreign Bribery Program — 17 August 2026
In August, the BPN was invited by the Australian Federal Police to present to the Advanced Foreign Bribery Program — a training forum bringing together Five Eyes international enforcement agencies alongside the National Anti-Corruption Commission (NACC) and the Australian Securities and Investments Commission (ASIC).
The BPN presented on its role as a practical tool for foreign bribery prevention in Australia. It was a privilege to share how the BPN supports Australian businesses to prevent foreign bribery, and to engage with the agencies at the forefront of global enforcement.
|
|
The Bribery Prevention Network is a public-private partnership that brings together business, civil society, academia and government with the shared goal of supporting Australian business to prevent, detect and address bribery and corruption and promote a culture of compliance. Read more here.
This newsletter is created for the anti-bribery community, by the anti-bribery community. Do you have news or stories to contribute to our next edition? Contact us at [email protected]
|
|
|
|
