Osgoode Hall Law Journal



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We argue that while Multilateral Development Banks (“MDBs”) and national governments have mechanisms to fight corruption, the objectives and outcomes of these enforcement mechanisms diverge. MDBs are interested in the causes and effects of corruption from a development perspective and, as such, tend to sanction small and medium enterprises and individuals, while national governments are focused on a more punitive outcome, targeting larger multinational corporations. This article examines the enforcement objectives articulated in national legislation, namely the US Foreign and Corrupt Practices Act and its Canadian counterpart, the Corruption of Foreign Public Officials Act, as well as several Canadian cases, on the one hand, and the tools and outcomes of MDBs’ sanctions systems on the other. We conclude that national enforcement efforts and MDBs’ sanctions outcomes intersect in their fight against international corruption in that their results are complementary; the former punishing large-scale offenders while the latter ensuring the integrity of development projects.

Creative Commons License

Creative Commons License
This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 4.0 License.