Albania is not a major arms exporter. It only sold 1.28 million euros worth of arms in 2016 [1].
Albania has ratified the United Nations Convention against Corruption in 2006 but is not a party to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions [2].

Albania has made efforts to comply with the UNCAC convention [1]. In 2015 Albania adopted the Inter-Sectoral Strategy against Corruption and its Action Plan for the period 2015-2017 [2]. The 2015-2017 Action Plan included three measures related to the defence sector, namely to improve the legal framework for procurements that are not subject to the general rules of public procurement; the publication of documents on defence spending in line with the UN and OSCE conventions; and registering all the immovable properties of the Armed Forces to the cadastral offices [3]. The MoD has complied with two of the tasks and is in the process of completing the registration of properties [4]. However, Albania continues to face challenges with curbing corruption which remains prevalent in many areas and has initiated a broad reform of the justice sector that aims to improve the legal framework and the institutional set-up to strengthen the system to prevent and suppress corruption, as well tackling issues such as embezzlement, and obstruction of justice and money laundering [5, 6].

According to SIPRI’s Arms Transfers Database, Algeria has not been a significant defence exporter between 2015 and 2017.
Algeria signed the UNCAS on December 9, 2003, and ratified it on August 25, 2004. It ratified it with a reservation regarding the possibility of extradition to the International Court of Justice.

A UNCAC report of 2016 outlines (1) what Algeria had done to address recommendations of the first review report, which was done in 2014 (2). The 2016 report mentions a couple of measures Algeria has introduced regarding: the protection of witnesses, experts and victims, property protection, improvements in stopping money laundering and mechanisms in the fight against corruption (1). Algeria will be reviewed in Chapters 2 and 5 of the UNCAC Convention in 2019/2020. Therefore, at this time, it is not possible to fully assess whether Algeria entirely complies with the obligations (3).

Angola signed the United Nations Convention against Corruption (UNCAC) on December 10th, 2003. It subsequently ratified it on the 29th, of August 2006 (1), (2). Angola does not export defence sector items.

According to the UNCAC implementation review report of June 2017 (review cycle 1), Angolan authorities have, for the most part, successfully complied with the convention, although it also highlights a lengthy list of implementation challenges, namely in the area of criminalization and law enforcement (Articles 15, 16, 18, 19, 21, 22, 23, 24, 25, 29, 30, 32, 33, 37, 38, 39, 42 of UNCAC), (1).

Among the challenges noted is the absence of any protection mechanism for witnesses and reporting persons, and the lack of criminalization of active and passive bribery of foreign public officials under Angolan law (1).

Argentina is not characterised as an active exporter of defence material. Argentina has signed and ratified the following international agreements: Inter-American Convention Against Corruption (OAS, Organization of American States 1996), [1] the Convention to Combat Bribery of Foreign Public Officials in International Commercial Transactions (OECD, Organization for Cooperation and Economic Development 1997) (as an observer), [2] and the United Nations Convention against Corruption (UN, United Nations Organization 2003). [3] Likewise, Argentina is part of the United Nations Arms Trade Treaty (2013). [4] At the regional level, in the framework of the VIII Summit of the Americas (April 2018), Argentina along with other countries adopted the so-called Lima Commitment “Democratic Governance Against Corruption” in order to promote the strengthening of democratic governance, transparency, and access to information, among others. [5] Internally, the issue falls under the National Commission for the Control of Delicate Exports and War Material, [6] composed of the Ministers of Defence, Foreign Affairs, International Trade, Worship, and Economy. The issue is the responsibility of the Nuclear Regulatory Authority (ARN), the National Space Activities Commission (CONAE), the Institute of Scientific and Technical Research of the Armed Forces (CITEFA), and the National Customs Directorate. [7] Likewise, the body for monitoring compliance with international commitments at the national level is the Anti-Corruption Office, under the Executive Branch.

Argentina is making progress on compliance with the Conventions of the OAS and the UN, while presenting some minor problems regarding the Agreement signed with the OECD. In the case of the OAS, the MESICIC is the monitoring body of the Convention. In its latest report, 2017 Round 5, it declared that Argentina complied with the recommendations made and even pointed out progress through the realisation of training activities for the preparation of public employment profiles and for the selection processes, the adoption of new norms for linking public servants through merit systems, and the adoption of new norms for the acquisition of goods and services by the State. [1] [2] On the other hand, since 2001 there has been a follow-up by civil society organisations, through the Commission for Monitoring Compliance with the Inter-American Convention Against Corruption in Argentina, which was created by the Public Bar Association of the Federal Capital with the support of Transparency International. [3] In relation to the UN Convention, whose last available report is from the 2010-2015 cycle, it makes observations regarding prison policy and issues recommendations on internal regulations, the figure of passive bribery of foreign public officials and public international organisations, and considers that Argentina has complied with the provisions of the Convention. [4] Regarding Argentina’s commitments within the framework of the OECD, some breaches have been observed during 2016 and 2017, especially regarding the criminalisation of companies for international bribery and the prosecution of citizens who commit this crime abroad. It should be noted that by means of Law 27,401 of Criminal Responsibility implemented in November 2017, [5] certain observations made by the OECD are fulfilled, while the law establishes the criminal liability regime applicable to private legal persons, whether they are domestic or foreign actors. [6] The latest OECD report on compliance with the Convention from 2018 indicates the progress made in the area of criminal regulation. [7] Debate has arisen in the media regarding the need for specific internal regulations that incorporate the precepts of international conventions. [8] [9] [10] In this sense, López Biscayart indicates “the need for a legislative reform that declares the imprescriptibly of the criminal actions born of the crimes referred to in the international covenants signed by our country is doubtful, since it can be sustained, as did the recent ruling of the Federal Chamber of La Plata, which, when Argentina assumed the commitment to punish them before the international community, could not invoke domestic legislation of the country (prescription regime) to breach that commitment.” [11]

Article 5 of the Constitution of Armenia [1] states that generally accepted rules of international law and international conventions, once they have been ratified and have come into effect, shall form an integral part of Armenia’s domestic law and shall override any other contrary provision of domestic law. Accordingly, the United Nations Convention against Corruption has become an integral part of Armenia’s domestic law following the ratification of the Convention by Parliament on March 8, 2007, and its entry into force on April 7, 2007, under Article 68 of the Convention [2]. Armenia is not a significant defence exporter, the country provides defence forces to NATO and UN peacekeeping missions (Kosovo, Iraq, Afghanistan), Armenia also has officers in Lebanon; and cooperates with the CSTO and other countries [3, 4]. Armenia is not a signatory to the OECD Convention.

The Mechanisms for the Review of Implementation of the Convention have been established to assists states in implementing the convention. A comprehensive self-assessment and intensive communications were held before a country visit during which the compliance of the Armenian legislation to the convention was evaluated. The report produced for the review cycle of 2010-2015 stated that for the most part, Armenia’s legislation complies with the convention [1]. According to Transparency International’s “Corruption Situation in Armenia and the Struggle Against it in 2016” report [2] the implementation of seven out of seventeen observed challenges regarding the UNCAC can be assessed as “partially implemented” and 12 “failed”. This indicator implies that additional serious steps should be taken to address the challenges more effectively [2].

Australia has signed and ratified both the UNCAC (ratified December 2005) and the OECD Anti-Bribery Convention (ratified October 1999) [1]. Australia is currently the 25th largest defence exporter in the world [2]. However, in early 2018, the Australian government annouced a new Defence Export Strategy to complement a major defence acquisition plan over the next decade [3]. As part of the Strategy, Australia seeks to become a top 10 defence exporter by 2028 through closer partnerships between industry and government and funding mechanisms, among other plans [4], which would represent at least an eight-fold increase in 2018 defence export sales [5]. Ratifying and complying with international anti-corruption instruments becomes more ever more essential with this new Strategy in place.

Reviews of Australia’s compliance with UNCAC and the OECD Anti-Bribery Convention indicate that Australia has been proactive in both facilitating outside reviews and following recommendations to increase its compliance; however, there are long-standing concerns that remain unaddressed and Australia’s track record of investigating and prosecuting corruption is sparse [1]. The 2018 Implementation Review Mechanism review of Australia’s UNCAC chapter II and V compliance was positive overall, but there were 13 recommendations offered [2], compared to 5 recommendations in the 2012 UNCAC chapter III and IV review [3]. Note also that the Review Mechanism is a bench review of legislation rather than de facto compliance. According to Transparency International’s (TI) 2018 Exporting Corruption survey, Australia remains in the ranks of countries with moderate enforcement of the OECD Anti-Bribery Convention. Though several progressive legislative and funding initiatives were highlighted in the survey, TI cited a number of legal regime shortcomings, a lack of accessible foreign bribery enforcement statistics, a relatively small amount of foreign bribery prosecutions, and a lack of mutual aid as inadequacies that made Australia fall short of active enforcement of the Convention [4]. The OECD, in its 2018 Phase 4 report, praised Australia’s progress towards enhancing anti-bribery prevention and enforcement, leading to its first bribery conviction in September 2017. The OECD Working Group also was effusive in its description of Australia as “highly cooperative and forthcoming” [5]. However, the amount of bribery investigations and prosecutions was not as high as would be expected given the size and risk profile of Australia’s export market [5, 6], and there were still several recommendations from the 2012 Phase 3 investigation which were partially or unimplemented. Parliament, too, has been critical of Australia’s compliance with anti-corruption instruments. The Senate Standing Committee on Economics issued a final report on its inquiry into foreign bribery in March 2018, in which it said that “more needs to be done” [6], leading to twenty-two recommendations.

Azerbaijan is not a significant defence exporter despite the leadership’s statements that it has produced many defence products; these are for domestic consumption. It is true that Azerbaijan has developed joint production of defence products with Turkey and Israel, but this does not make the country a significant defence exporter.
Azerbaijan has signed (2004) and ratified (2005) the United Nations Convention against Corruption (UNCAC) (1). Azerbaijan has not signed on to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (2). As of May 2018, the OESC agreement has only been signed by 44 countries. Azerbaijani legislation on bribery offences does not fully comply with international standards, but Azerbaijani legislation has provisions on bribery offences. Azerbaijani legislation is in the line with the requirements of Article 16 of the UNCAC on bribery of foreign public officials and officials of public international organizations (8).
According to the experts Azerbaijan has begun to export military products in 2013. Exports to the foreign countries were $ 123 million in 2013 and $10 million less in the following year: “Exports figures for the year 2016 have exceeded $ 120 million. Azerbaijan exports arms to several countries in Turkey, Russia, Belarus, South Korea, South-East Asia, Saudi Arabia, the United Arab Emirates (UAE), Pakistan and the United States of America (US)” (4).
Azerbaijani president İlham Aliyev said (June 26, 2018) that there are 1200 types of military products produced, at the same time, Azerbaijan has already started exporting military products (5). Defense Industry Minister Yaver Jamalov said in 2017 that the export of Azerbaijani military products is being carried out to the relevant agencies of more than 10 countries. “At present the cost of concluded contracts is 101 million US dollars. $ 57 million of this amount is in force, and the remaining $ 44 million will come into effect after end-user certificates are issued (3)”.
Experts believe that in such a situation Azerbaijan has no domestic and international control mechanisms for arms exports. No accountability, the parliament is not informed about the process. Local NGOs and the media are not informed about the arms export strategy. In this case, the risk of corruption increases considerably (6, 7).

According to Natig EYVAZOV (Prosecutor Organizational and Information Support Department Anti-Corruption Directorate with the Prosecutor General of the Republic of Azerbaijan), “during the period passed since adoption of convention, the fight against corruption remained as one of the key-priorities of state policy, anticorruption reforms, prosecution of corruption offences and implementation of preventive measures has been continued”. (1)
According to an OECD report, Azerbaijan has made progress in preventing corruption in several sectors, such as public services delivery, traffic police and public education, and reforms have started in customs and business licencing. However, the OECD report states, that serious, and complex corruption challenges have yet to be tackled (2). The report urges Azerbaijan to strengthen its central body for the prevention of corruption and implement comprehensive, evidence-based anti-corruption policy, addressing high corruption risk sectors (3). Additionally, the freezing of accounts of independent NGOs, arrests of active critics of shortcomings in the public administration, restrictions on the activities of mass media and foreign donors, have all seriously affected civil society’s capacities to effectively struggle against corruption (4). A Guardian newspaper investigation revealed that at the same time Azerbaijan’s ruling elite operated a secret $2.9bn (£2.2bn) scheme to pay prominent Europeans, buy luxury goods and launder money through a network of opaque British companies (5). The country’s Ministry of Emergency Situations, Ministry of Defence and intelligence service are said to have provided $9 million to the scheme. A Russian arms exports agency, Rosoboronexport, provided $29m, according to the OCCRP (6).

The Kingdom of Bahrain signed the United Nations Convention against Corruption (UNCAC) convention in 2005 and ratified it in 2010 [1]. Bahrain is not a significant weapons exporter.

According to the UNCAC Review Report of Bahrain, two good practices are taking place in Bahrain: campaigns against corruption, and the establishment of an electronic procurement system. However, it mentions 12 challenges in the compliance strategy [1]. Bahrain lacks an anti-corruption strategy that is centralized. It has adopted a few laws including the Criminal Procedure Code (CPC), the Anti-Money Laundering Law (AMLA), the Judicial Authority Law (JAL), the Law on the Regulation of Tenders and Government Purchases (Tender Law), the Financial Disclosure Law and the Civil Service Law (CSL); however, none of these laws apply to the military.

Bangladesh acceded to the United Nations Convention against Corruption (UNCAC) on February 27, 2007, and deposited its instrument of ratification with the United Nations Secretary-General on February 28, 2007 [1]. The Ministry of Law, Justice and Parliamentary Affairs has a special wing headed by a Joint Secretary to coordinate UNCAC matters with the UN. Bangladesh is not a significant defence exporter, according to the SIPRI [2].

As of now, the government of Bangladesh has not undertaken any official analysis regarding its compliance with UNCAC instruments. However, a study conducted by TI Bangladesh in 2011 found that existing laws of Bangladesh are largely in compliance with UNCAC requirements on criminalisation [1]. Application and enforcement are recurring areas in which there have been gaps in the implementation of various commitments made under the UNCAC [2].

Belgium has ratified the OECD convention and the UNCAC convention. It also signed and ratified the UN convention against corruption [1]. Moreover, Belgium does not place in the SIPRI top 25 arms-producing and military services companies in the world, nor in the top 25 of largest exporters of major arms [2, 3].

There is no evidence of negligence on, or opposition to, the implementation and working of anti-corruption instruments. Most recently, the 2020 Review of the implementation of the United Nations Convention against Corruption was published online, with the latest report published in 2020, focusing on chapters II and V [1].

The report acknowledges that Belgium has a sound anti-corruption framework. However, it does express conerns about the independence of a mandated coordinating entity for the plan of action in line with the Convention. This is most notably as a result of organizational restructuring, which endangers BEDA’s (the Office of Administrative Ethics and Ethical Conduct) independence.

In total, the report puts out 14 recommendations on the challenges of the implementation of the Convention. Earlier, the Review of Chapter III and IV was published in 2016. In this report, recommendations were mostly related to fleshing out details in anti-corruption laws [2].

According to the Stockholm International Peace Research Institute – SIPRI’s Facts Sheet (Trends in International Arms Transfer) from March 2018 Bosnia and Herzegovina is not ranked as one of 25 largest exporters of major arms [1]. Bosnia and Herzegovina has signed and ratified the UNCAC Convention. However, Bosnia and Herzegovina is still not a member of the OECD Convention [2].

Per the Draft Country Review Report of Bosnia and Herzegovina (review cycle 2010-2015), there are considerable challenges for Bosnia and Herzegovina in the implementation of the United Nations Convention against Corruption (UNCAC) Convention and they are related to the following articles of the Convention:
1. Article 15: Bribery of national public officials
2. Article 16: Bribery of foreign public officials and officials of public international organizations
3. Article 18: Trading in influence;
4. Article 19: Abuse of functions;
5. Article 21: Bribery in the private sector;
6. Article 23: Laundering of proceeds of crime;
7. Article 31: Freezing, seizure and confiscation;
8. Article 33: Protection of reporting persons;
9. Article 36: Specialized authorities;
10. Article 39: Cooperation between national authorities and the private sector [1].

Transparency International in Bosnia and Herzegovina’s report on the implementation of the UNCAC Convention from 2016, which only considered the following chapters: Chapter II – Preventive Measures, Chapter II – Criminalization and Law Enforcement and Chapter IV – International Cooperation, determined that a great number of articles falling within the listed chapters have only been partially, or not, implemented at all [2].

Botswana acceded to the UNCAC on 27 June 2011 [1]. The country is not a Member of OECD [2]. According to SIPRI Arms Transfer database, Botswana is not a significant arms exporter. No arms exports were made between 2014-2020.[3]

Botswana has substantially complied with the obligations of UNCAC [1]. For example, the establishment of an anti-corruption agency in the form of the Directorate of Corruption and Economic Crime [1]. However, in a UNODC Compliance Review Report (2019), it was highlighted that there is still room for Botswana to improve its compliance [2]. Recently, the government publicly stated that the Minister for Presidential Affairs, Governance and Public Administration, Mr Nonofo Molefhi, claims the government is committed to the implementation of the United Nations Convention Against Corruption (UNCAC), which it ratified in June 2011 [2]. Speaking at a workshop on Botswana’s second review cycle of the UNCAC in Gaborone on May 2, Mr Molefhi emphasised that strong political will on the part of the government had led to the development of robust measures against corruption [2].

Brazil has signed both the United Nations Convention Against Corruption (UNCAC) [1] and the OECD Anti-Bribery Convention [2]. Besides those two anti-corruption instruments, the country is also a signatory of the OAS Convention and the Open Government Partnership [3, 4], as already stated by the 2015 assessment. Brazil ratified these conventions through measures such as the creation of the National Strategy of Anti-Corruption and Money Laundering (ENCCLA) (Estratégia Nacional de Combate à Corrupção e à Lavagem de Dinheiro) in 2003, which is the main articulation arena between the Executive, the Legislature and the Judiciary, from all levels of government (municipal, state and federal level). Every year they establish a set of actions that must be addressed by the participant institutions [5]. The Ministerial Integrity Plans released in 2018 are also part of the ratification of international anti-corruption instruments in the country [6].

The 2017 ‘Follow-up to phase 3 report’, from the OECD Convention, stated enhancements in many areas, such as the enactment ‘of a new Corporate Liability Law (CLL; Law 12846)’, the clarification of ‘the scope of its foreign bribery offence’. It also noted many possible improvements for Brazil’s anti-corruption policies [1]. In spite of the incomplete but constant developments, a recent draft bill was discussed, raising concerns about Brazil’s capacity to fight corruption [2]. It is the Abuse of Authority Bill, that establishes harsher punishments for a list of acts towards citizens accused of crimes before any trials. The opinions regarding this matter are inconclusive, judges and police officers claim the law makes it harder for them to conduct their investigations; while others state that security and justice officers that operate within their legal boundaries will not have problems under the new provisions [3]. There is still no factual evidence of how this law will affect compliance with international anti-corruption agreements. In regards to the UNCAC Convention, Brazil released a report in 2016, presenting the convention and the monitoring tools for its implementation [4].

Burkina Faso signed the United Nations Convention against Corruption on December 10, 2003, and ratified it on October 10, 2006, (1). An update of the implementation of the UNCAC in Africa includes Burkina Faso on the list of countries that ratified the UNCAC (2). Burkina Faso does not export arms (3).

The CNT adopted a law on the prevention and repression of corruption in March 2015, and another one on the creation of the High Authority for State Control and Anti-corruption (ARCE-LA), to ensure compliance with UNCAC (1). The passing of these laws formalizes Burkina Faso’s compliance with the UNCAC. Burkina Faso participated in the Conference of the Parties (CoP) as well (2), (3).

However, Burkina Faso still has the following challenges: The Anti-Corruption Act requires public institutions to adopt codes of conduct, these codes of conduct have not been adopted by certain bodies. The declaration of gifts, donations and other benefits are mandatory for all public officials; however, at the time of the country visit, that system was not yet operational. It is also recommended that Burkina Faso: Ensure greater coherence in its national anti-corruption policy ; Ensure that ASCE-LC has an adequate budget and thus the necessary material resources and specialized staff; adopt and implement a training plan for ASCE-LC staff; Adopt the decree establishing the terms of recruitment of the Comptroller General of the State and the comptrollers of the State; Establish adequate procedures for the selection and training of individuals for public positions that are considered vulnerable to corruption and the rotation, where appropriate, of such individuals to other positions (Arts. 7 (1) (b) and 9); Endeavour to adopt codes of conduct for all public officials and disseminate the content of those codes; Put the asset declaration system into operation; expand the list of persons required to declare their assets to cover all positions vulnerable to corruption; Ensure that the provisions of Act No. 051-2015 on the right to access public information are implemented; adopt legal instruments that enable the national authority for access to public information to fulfil its mandate (Art. 10) (2).

On 10th December 2003, the Government of Cameroon signed the UNCAC. This Convention was later ratified, on 6th Febraury 2006 [1]. Cameroon is not an arms exporter.

According to the review of the implementation of the UNCAC. Cameroon has complied with some of the provisions of the UNCAC [1]. The following areas are sanctioned by the Cameroon Penal Code [2]:
– Bribery and trading in influence (arts. 15, 16, 18 and 21)
– Money-laundering, concealment (arts. 23 and 24)
– Embezzlement, abuse of functions and illicit enrichment (arts. 17, 19, 20 and 22)
– Obstruction of justice (art. 25)
– Liability of legal persons (art. 26)
– Participation and attempt (art. 27)
– Prosecution, adjudication and sanctions; cooperation with law enforcement authorities (arts 30 and 37)
– Protection of witnesses and reporting persons (arts 32 and 33)
– Freezing, seizing and confiscation; bank secrecy (arts 31 and 40)
– Statute of limitations; criminal record (arts 29 and 41)
– Jurisdiction (art. 42)
– Consequences of acts of corruption; compensation for damage (arts 34 and 35)
– Specialized authorities and inter-agency coordination (arts 36, 38 and 39)

According to the UNCAC review, “Cameroon has criminalised the bribery of foreign public officials and officials of public international organisations in Sections 134 and 134-1, read together with Sections 89 and 131-1. Cameroon has partially criminalised trading in influence in section 161 PC. Cameroon has criminalised passive bribery in the private sector in section 312 PC, as well as false declarations and the misleading of contractors by directors and managers of private entities, in section 313 PC. As regards money-laundering and concealment (arts. 23 and 24), Cameroon has criminalized money-laundering in line with the Convention (art. 1, Regulation No. 02/10). Cameroon follows an all-crimes approach to money-laundering whereby all offences under the laws and regulations of Cameroon constitute predicate offences. For prosecution of money-laundering, the predicate offence should constitute a criminal offence in the country where it was committed (art. 1). Self-laundering is punishable (art. 51, Regulation No. 02/10) [1].

According to the UNCAC review, there are some areas Cameroon has not addressed. Acts of indirect bribery are not specifically mentioned in the Penal Code; it is noted that benefits accruing to third parties are mentioned only in section 134 and not 134-1 of the Penal Code. There is an automatic exemption from prosecution for persons who were solicited for bribes and who reported the offence to the judicial authorities but did not render assistance in the investigation (Section 134-2 PC). Case statistics on the implementation are not available. There is no statistical data on the number of criminal investigations, prosecutions and convictions. The sections on embezzlement do not cover the full range of embezzlement, misappropriation and other diversion of property or funds for the benefit of a public official or another person or entity. No case law has been provided to demonstrate that private property is covered. The failure to perform an act, or an omission, in violation of law is not explicitly covered. The criminal offence of illicit enrichment has not been established, although a draft bill on anti-corruption contains relevant provisions [1]. Overall, Cameroon did comply with some of the provisions and did not comply with others. The UNCAC report contains a detail record of the items complied with and not complied with, the challenges and the recommendations made by the UNCAC review commitee.

Canada has signed, ratified, and taken official measures to comply with both these conventions, as well as other regional and similar conventions. [1] [2] [3] [4]

The Canadian government’s conduct was being monitored by the OECD during the prosecution of at least two major companies, one wholly Canadian, the other with a major Canadian presence, the latter of which involved an active cover-up by the Canadian government. [1] [2] The case of SNC Lavalin in particular contravenes several statutes on bribery of foreign officials (including domestic laws such as Canada’s Corruption of Foreign Officials Act as well as the OECD’s Convention on Combatting Bribery of Foreign Public Officials in International Business Transactions) in Libya. [3] [4] [5]

The country signed (December 2003) and ratified (September 2006) the United Nations Convention against Corruption (UNCAC) and the OECD Anti-Bribery Convention (2001). Chile is not a significant defence exporter [1].

The report of the Implementation Review Group of the UNCAC for the period 2010-2015 highlighted that legal reforms adopted were in the direction of complying more precisely with the provisions of the UNCAC [1]. However, an alternative, participatory evaluation coordinated by civil society organisations showed a more nuanced picture, with 74 per cent of compliance in the private sector and diverse levels for indicators in the public sector [2]. On the other hand, in 2015, Transparency International elaborated a report to evaluate compliance and implementation of the OECD convention. From the countries that have signed the convention, Chile was one of the twenty nations that showed minimal or null compliance [3]. Likewise, the report of the OECD Working Group on Bribery tracked progress made by the country since the 2014 evaluation, and it established that the majority of the recommendations from previous evaluations remained to be done in matters of confiscations of proceeds, premature termination of a case lingers, and whistleblower protection. There was an increase in the enforcement of foreign bribery but serious deficiencies in the corporate liability regime.

China is the 5th largest defence supplier in the world [3] but has not signed the OECD convention. [2]

China has ratified the UNCAC [1] and is engaged with its implementation review process. It is also a member of the ADB/OECD Anti-Corruption Initiative for Asia and an observer of the OECD Anti-Bribery Convention Working Group. In addition, China has acceded to the UN Convention against Transnational Organised Crime and is a member of the Financial Action Task Force on Money Laundering, the Eurasian Group on Combating Money Laundering and Financing of Terrorism and the Asia/Pacific Group on Money Laundering.

This indicator has been marked Not Applicable because China is a significant exporter of defence materials and has not signed the OECD Convention.

Given that the UNCAC implementation mechanism is based on self-reporting, compliance reports are not always an accurate representation of the exports.

On 29 March 1996, Colombia signed the Inter-American Convention Against Corruption, whose aim was to prevent, detect, sanction, and eradicate corruption, as well as incentivise, facilitate, and regulate cooperation between States on this theme. [1] This was ratified with Law 412 of 1997, which was approved by Congress and declared enforceable through judgement C-397 of 1998, an instrument which the Constitutional Court of Colombia considered in full compliance with the Rule of Law as stipulated in the Constitution of Colombia, and it was ratified on 9 January 1999. Colombia also signed the United Nations Convention (UNCCD) and validated it through Law 970 of 2005 “By means of which the United Nations Convention Against Corruption was adopted, the Constitutional Court subsequently declared its enforceability by judgment of C-172 of 2006 and finally the country deposited the instrument of ratification on 27 October 2007.” [1] In addition, under Law 1778 of 2016, it ratified its position on OECD conventions, in such a way as to lay down rules on the liability of legal persons for acts of transnational corruption and other provisions on the fight against corruption. [2]

Colombia is compliant with most of its obligations in priority areas defined by the ratified Conventions. On the website of the Secretariat for Transparency, reports, evaluations and laws are published, which show the progress of the country in the fight against corruption. With regard to the fulfillment of obligations derived from the UNCAC, the monitoring report on compliance with Colombia in 2017 highlights the regulatory framework against corruption that the country has, based on Law 599 of 2000 that contains the Penal Code, and which typifies some crimes associated with corruption; Law 906 of 2004 that defines the Code of Criminal Procedure; Law 970 of 2005 that approves the UN Convention; Law 1474 of 2011, known as the Anticorruption Statute, through which reforms were adopted in this matter; and finally, CONPES (National Council for Economic and Social Policy) No. 167 of 2013, which establishes the Comprehensive Anti-Corruption Public Policy. Based on these regulations, the obligations established in the UNCAC have been met. However, there are some limits to the application of the measures, such as the application of the Convention in matters of extradition, categorisation of all the conduct included in the UNCAC, the need for further training of officials in the UNCAC, and the strengthening of international cooperation and mutual legal assistance. [1] In the follow-up report to Phase 2 of the implementation of the OECD Convention in Colombia of February 2018, the advances in institutional and regulatory strengthening to counter bribery and corruption in the country were identified. Among the advances in compliance, the following have been identified: the adoption of Law 1778 of 2016 through which the persecution of international bribes is strengthened, concepts and the scope of sanctions are clarified; institutional adjustments within the Office of the Attorney General of the Nation, such as the creation of the specialised national anti-corruption Prosecutor’s Office (National Anti-Corruption Unit) from Resolution 573 of 2014, the Delegate for Criminal Finance; advances in accounting and auditing, with the adoption of International Financial Reporting Standards (IFRS) for all types of businesses, except microenterprises; From the Secretariat of Transparency (of the Presidency) various activities have been promoted with the participation of all public sectors to raise awareness of measures against corruption; and sanctions for international bribery have been increased. According to the report, Colombia has adopted a much more proactive stance on “detecting and investigating foreign bribes including the use of Mutual Legal Assistance,” [2] although it insists on the need to improve statistics associated with corruption crimes, particularly those related to money laundering and accounting fraud. Finally, regarding the implementation of the provisions of the Inter-American Convention Against Corruption, in the report prepared by the OAS Follow-up Mechanism (MESISIC) of 2017, it specified that Colombia has complied with a series of recommendations in relation to the Department of Public Service as well as the typification of acts of corruption. According to said Report, Colombia has made progress on issues such as the issuance of standards such as the single regulatory decree for the civil service; the system for public contracting SECOP I and SECOP II (which allow for transactions), among other actions. In any case, the report identifies a series of improvements in order to fulfillment the agreement, such as to: (i) reduce the duration of the selection processes by the National Civil Service Commission (CNSC); (ii) avoid contracting through the provision of services; (iii) implement the special career of the Office of the Attorney General of the Nation, among other recommendations. [3]

Côte d’Ivoire signed the United Nations Convention against Corruption (UNCAC; CNUCC) on December 10, 2003, ratifying and publishing it on December 6, 2011. The country deposited its instrument of ratification with the UN Secretary-General on October 25, 2012, (1), (2).

Partly as a result of UNCAC signature and ratification, Côte d’Ivoire has instituted several laws and decrees related to fighting corruption in different sectors (1).

They include the following:
• Act No. 2013-875 of December 23, 2013, ratifying Order No. 2013-660 of September 20, 2013, on preventing and combating corruption and similar offences (Order No. 660), which broadly reflects the provisions of the Convention that establish corruption offences
• Act No. 2013-661 of September 20, 2013, establishing the powers, composition, organization and functions of the High Authority for Good Governance (HABG)
• Act No. 2005-554 of December 2, 2005, on combating money-laundering
• Act No. 2014-337 of June 5, 2014, establishing a code of transparency in the management of public finances.

Côte d’Ivoire is still working on implementing all the UNCAC provisions. The compliance issues that remain outstanding are regularly discussed during government compliance (mise-en-oeuvre) sessions, which are routinely relayed by Ivorian media.

As per the UNCAC Implementation Review Group (8th session, 19-23 June 2017), a meeting held in Vienna in 2017 to review individual country compliance with UNCAC, the country report for Côte d’Ivoire contained a very long list of outstanding issues, including the following:

“3.3. Challenges in implementation
In order to further strengthen existing measures to combat corruption, it is recommended that Côte d’Ivoire:
• Conduct a comprehensive review of the current Extradition Act of 1927 in order to ensure that
– The requirement that a corruption offence be punishable by two years of imprisonment in order for that offence to be extraditable does not hamper the ability of Côte d’Ivoire to carry out extradition in relation to offences established by the Convention (Art. 44, para. 8)
– Sentences imposed in other States are enforceable in Côte d’Ivoire if the person is not extradited on the ground that he or she is one of its nationals (art. 44, para. 13) (1).
– Fiscal offences, although extraditable under the ECOWAS Convention on Extradition, are also extraditable beyond the ECOWAS region (art. 44, para. 16)
• Establish the obligation to consult with requesting States or allow them to present their opinions and provide additional information before requests for extradition are refused (art. 44, para. 17)”
[See the full list of outstanding issues on p. 13-14 of the country report] (1).

The US State Department maintains that although Côte d’Ivoire has signed and ratified UNCAC, it is not a signatory party, for example, of the OECD Convention on Combating Bribery, which is considered more applicable for commercial trade issues (2). On September 22, 2015, then Minister of State Hamed Bakayoko, took part in a UN-sponsored workshop to examine Côte d’Ivoire’s progress toward implementing UNCAC (3). The Council of Ministers informed about a meeting that President Ouattara held on February 17, 2016, with the government cabinet to inform about the implementation of a review mechanism for UNCAC and to report on Côte d’Ivoire’s participation at a UNCAC convention in St. Petersburg, Russia (4). On October 1, 2018, iMatin, a digital news platform, reported that an NGO (Social Justice) had organized a workshop in Abidjan, financed by Transparency International, to discuss a report about the implementation of UNCAC in Côte d’Ivoire. Attendants included civil society organizations, media and lawyers, as well as Diamouténé Oumar Doh, the representative of the High Authority for Good Governance (Haute autorité pour la bonne gouvernance, HABG) (5).

Denmark has signed and ratified the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions [1] as well as the United Nations Convention against Corruption [2]. Denmark is not a significant defence exporter [3].

In a 2015 review, OECD found that full implementation and enforcement of the OECD convention was incomplete [1]. Similarly in 2015, the United Nations identified a comprehensive list of issues regarding implementation and enforcement of the UN convention [2]. There is no evidence of newer reports and investigations into implementation of the two conventions. The Council of Europe’s Group of States against Corruption (GRECO) has continuously concluded that Denmark’s implementation of corruption preventing measures, such as a code of conduct for members of Parliament, remains unsatisfactory [3].

Egypt is not among the 56 arms exporters listed by the Stockholm International Peace Research Institute (1), and therefore cannot be considered a significant defence exporter. It ratified the UNCAC in 2005 (2).

Egypt has failed to achieve to meet many of the improvements that the UNCAC requires, despite passing some anti-corruption laws (1), (2), (3). At the implementation level, anti-corruption policies in general and the UNCAC in particular still face immense challenges in making the fight against corruption an effective reality. Egypt’s poor performance on most corruption indicators is evidence of that (4). Even the official national anti-corruption strategy highlights the weak implementation of the UNCAC (5), (6).

Estonia is not considered a significant defence exporter. For example, in 2016 Estonia exported 724 small arms and 2 light weapons, according to the data provided by The Arms Trade Treaty Annual Report. [1] At the beginning of 2017, there were around 25 companies in the defence field. However, a plan to increase Estonia’s defence export has been put forward by the government and it has been included in the national defence strategy. The Ministry of Defence has proposed to increase Estonia’s defence export to 25 million euros by 2019. [2] In 2015 Estonia’s export turnover was insignificant – 13 million euros. Estonia signed the UNCAC Convention in 2010 and it entered into force on 12 April 2010. [3] Estonia was one of the last EU countries to sign the Convention. [4] In December 2004, Estonia also joined the OECD WGB and ratified the OECD Convention. [5]

There is little evidence that compliance with UNCAC is examined. There has been a review of the implementation of Articles III and IV of the Convention when it comes to Estonia. [1] These include: “Criminalization and law enforcement” (Article III) and “International cooperation” (Article IV). According to the latest report published in 2012, based on the review of the third and the fourth article, Estonia is reported to comply with both chapters. [2] There is no other recent evidence. The reviews of Article II and Article V are planned to be finalised soon.
There is some further evidence that Estonia has complied with the obligations. For example, the Ministry of Justice developed an anti-corruption strategy for 2013-2020 that is partly based on the UNCAC Convention. Estonia also stated when joining the Convention that it will consider it as the basic document in law-making. The 2013 convention report stated that Estonia, amongst other countries, was “commended on some specific successes.” [4]
Based on the available information and the information provided by a senior official at the Ministry of Justice, most of the obligations in priority areas have been complied. [5]

Finland signed the UNCAC Convention on December 9, 2003, and ratified it on June 20, 2006. [1] OECD Convention was signed on December 10, 1998, and entered into force on February 15, 1999. [2] According to SIPRI, Finland is not one of the 25 largest exporters of major arms and has not extensively exported during the period 2016-2020. [3,4]

The second cycle of the UNCAC review process is ongoing and the states reviewing Finland have not yet submitted their report. [1] All in all, the second cycle is largely behind its initial schedule to be finished by 2021. [2] The review of the first cycle (completed in 2011) is available on UNCAC website. According to it, “[i]n Finland there is general consensus about the very low level of corruption in the country, which is explained by a combination of social, cultural and institutional factors. The current debate focuses among other things on the extent to which actions by public officials are influenced by a less manifest and blatant behaviour known as “old boys’ network”, where favours are exchanged on the basis of informal relationships. Additionally, over the last few years some indications emerged of a rise in reported corruption cases. A number of allegations are currently being investigated.” [3] This description of the state of affairs is still valid in 2020.

The OECD Anti-Bribery Convention monitoring is in its phase 4 – the report on Finland was published in 2017 and the two-year follow up report on 2019. According to those reports:

“Finland’s commitment to combatting foreign bribery appears to have increased” since the phase 3 follow up report, but there are “grave concerns about Finland’s 100% acquittal rate in foreign bribery cases”. Therefore, Finland is urged to take further steps, “including implementing the Working Group’s recommendations, to reduce this acquittal rate and ensure the foreign bribery offence is applied as intended and consistently with Article 1 of the Convention”.
“Regarding outstanding Phase 3 recommendations, Finland has implemented recommendations 1 on training for law enforcement; recommendation 2 on the foreign bribery offence; recommendation 3 on the statute of limitations; recommendations 8a, b, and c on accounting; recommendation 10 on ODA, and recommendation 12 on public advantages. Recommendations 4 on false accounting, recommendations 5(e)-(g) on awareness raising, recommendation 6 on reporting, and recommendation 7 on whistleblower protection remain unimplemented”. [4]

The 2017 phase 4 report gave Finland 15 further recommendations, of which the 2019 follow up report stated: “Finland fully implemented 2 recommendations, partially implemented 7 recommendations, and did not implement 6 recommendations. Overall, Finland has shown limited progress in addressing the Working Group’s concerns. Nonetheless, the Working Group notes that Finland has taken steps to amend its Criminal Code on sanctions and to develop a guidance specifically targeting SMEs. Other reforms are also ongoing and seem to be pointing to the right direction, including in relation to institutional arrangements.” [5] It is worth noting that the views of OECD and Finland differ on the gravity of the compliance issues [6].

France is a significant defence exporter and ratified the UNCAC in 2005. [1] It transposed into law the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions in 2000. [2]

Although France has brought the OECD Anti-Bribery Convention into force, the OECD has criticised the very small number of corruption prosecution cases since the Convention was implemented, but has acknowledged efforts to guarantee the prosecutor’s independence. [1]

Germany has signed up to and ratified both the UNCAC Convention and the OECD Convention. The UNCAC Convention was signed on 9 December 2003 and ratified on 12 November 2014 [1].

The key dates of Germany’s accession to the OECD Anti-Bribery Convention are as follows:
10 November 1998: Deposit of instrument of ratification;
15 February 1999: Entry into force of the Convention;
15 February 1999: Entry into force of implementing legislation [2].

Germany is now in Phase 4 of the monitoring process. The Phase 4 Monitoring Report (21 June 2018) details Germany’s achievements and challenges in respect to implementation and enforcement of the OECD Anti-Bribery Convention, as well as progress made since the Phase 3 evaluation in 2011 [3]. Please also see the ‘Regelungen zur Integrität’ (Rules on Integrity) published by the Ministry of the Interior, Building and Community [4].

Germany has also acceded to:
the UN Convention against Transnational Organised Crime;
the EU Convention on the Fight against Corruption involving Officials of the European the Communities/Member States of the EU;
the EU Council Framework decision 2003/568/JHA;
Resolution (99) 5 of the Committee of Ministers of the Council of Europe; and
Resolution (97) 24 of the Council of Europe.

Germany has complied with most of its obligations in the priority areas covered by the two conventions it has ratified, but has some minor issues of compliance with both of them. Germany’s Phase 4 report was adopted by the OECD Working Group on Bribery (WGB) on 14 June 2018. According to the report by the OECD Working Group on Bribery, Germany continues to demonstrate a high level of anti-bribery enforcement, having prosecuted and sanctioned 328 individuals and 18 companies in foreign bribery cases since 1999. The country is commended for its focus on holding culpable individuals liable, however, as companies are held liable in only a quarter of the concluded foreign bribery cases, there are concerns that there is insufficient enforcement against companies [1].

The 44-country OECD Working Group on Bribery has completed its Phase 4 evaluation of Germany’s implementation of the Convention on Combating Bribery of Foreign Public Officials and related instruments. The report praises Germany’s position as one of the top enforcers of the Anti-Bribery Convention, as well as its pragmatic approach to prosecuting and sanctioning individuals for foreign bribery. This strong enforcement record results from Germany’s use of various alternative offences and a wide range of procedures, such as non-prosecution arrangements. However, the Group raises concerns about the low rate of corporate enforcement, as well as an inconsistent approach to holding companies liable across the different Länder (federal states) in Germany. The report also mentions that the sanctions imposed on both individuals and companies are not always sufficiently deterrent and that whistleblower protection needs to be reinforced.

The report also notes a number of positive developments, such as the recent commitment stated in the Coalition Agreement to increase the maximum punitive fine for companies. The Working Group also welcomed the broad use of investigative techniques and tools by German investigators in foreign bribery cases, including coordinated investigations with tax authorities and Joint Investigative Teams in multi-jurisdiction investigations, as well as the effectiveness of the tax authorities in the detection of foreign bribery [1].

However, the Group made a range of recommendations to Germany, instructing it to:
– Review its overall approach to holding companies liable for foreign bribery and proceed with the 2018 Coalition Agreement to review the principle of prosecutorial discretion.
– Introduce clear and transparent guidance on the procedures and criteria attached to self-reporting by companies when concluding a foreign bribery case.
– Consider introducing a system of resolutions for companies as part of its efforts to increase enforcement against companies.
– Ensure, at both the Federal and Länder level, the consistent compilation of statistics related to the monitoring of the enforcement of German legislation implementing the OECD Anti-Bribery Convention.
– Ensure that sanctions imposed for foreign bribery or related alternative offences are always sufficiently deterrent, particularly for large companies.

In accordance with the standard procedure, Germany submitted a written report to the Working Group on its implementation of all recommendations and its enforcement efforts in December 2020. This report was presented to the WGB in March 2021 and has been made publicly available. Germany reported that a draft Corporate Liability Act (‘Corporate Liability Act’, ‘Act’ or ‘CLA’) was introduced to Parliament (Bundestag) in September 2020. The draft act, if adopted, would overhaul the current corporate liability system under the Administrative Offences Act (OWiG) and introduce a hybrid criminal and administrative corporate liability system for corporate criminal offences in Germany. This act has not yet been adopted by the German Parliament. In its follow-up report, the WGB concludes that in 2019 and 2020, Germany maintained its leading position among the parties to the Anti-Bribery Convention in investigating, prosecuting and sanctioning foreign bribery cases, but once again raises ongoing concerns around Germany’s enforcement of its corporate liability system and its protection of whistleblowers, among others [2].

With regard to UNCAC, the country report for the first review cycle (2016) is not published, nor is the country report for the second review cycle (2018). The executive summary for the second cycle has been published and outlines ongoing issues, as well as preventive anti-corruption measures and efforts to combat money laundering [3]. There is also a report by Transparency International which includes recommendations relating to the implementation of the UNCAC [4].

Ghana signed and ratified the United Nations Convention against Corruption (UNCAC) in 2004, and 2007 respectively (1), (2). Ghana also signed the African Union Convention on Preventing and Combating Corruption in 2007 (3), and the ECOWAS Protocol on the Fight against Corruption in 2001.

Ghana adopted the Anti-Money Laundering Act (Act 749) in 2008, which was amended in 2014 (Act 874), the Whistleblower Act (Act 720) in 2006 (1), and the National Anti-Corruption Action Plan (NACAP) in 2014 (2). Ghana has also passed the Witness Protection Act, 2018 (Act 975) (3). More recently, the Right to Information Act, 2019 (Act 989) was passed by Parliament in March 2019 and signed into law in May 2019 (4).

Although Ghana has signed and ratified most of these treaties, compliance with most of its obligations in priority areas has largely been lacking (5), (6), (7). Following the sixth session of Implementation Review Group of the United Nations Convention against Corruption, Ghana has been encouraged to: clarify and align its investigation and prosecution powers as well as responsibilities to ensure efficiency, effectiveness and independence of the persecution function in corruption cases (UNCAC, Chapter III); and facilitate international cooperation, particularly in extradition procedures (UNCAC, Chapter IV) (8).

Greece is not currently a significant defence exporter. There is a small defence industry consisting of problematic state-owned companies and small private firms. The Greek Parliament ratified the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the UN Convention against Corruption in 1998 and 2008 respectively. Greece has also signed and ratified the EU Convention against corruption involving public officials since 2000 [1, 2, 3].

In March 2016, Greece successfully underwent a preliminary compliance check by the OECD. Greek companies operating abroad were praised for their cooperation in anti-corruption efforts. In July 2019, however, the OECD Working Group on Bribery conveyed its serious concerns that certain legislative steps taken by the Greek government may be in breach of the OECD convention [1]. On 11 June 2019, the Greek Government amended the Criminal and Criminal Procedure Codes. Consequently, the main active bribery offence was reduced from felony to the less serious of offence of misdemeanour. However, the new Government led by PM Mitsotakis changed the criminal code so that bribery was once again made a felony [2, 3].

The country has signed and ratified the UNCAC convention. Although Hungary is not a significant defence exporter, it is among those 43 states that have signed and ratified the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. The Convention went into force on March 1, 1999 [1].

According to OECD reports and follow-up reports that are available (latest is from 2014), Hungary complies with its obligations in priority areas covered by both conventions [1]. The compliance with the UNCAC report was reviewed in 2013 when Transparency International prepared a detailed report to support the work [2]. In September 2018, the UN decided on the work plan and review of the upcoming assessment that will take place no earlier than 2020. Hungary’s self-assessment of the UNCAC will be reviewed by Moldova and Jamaica [3].

India is a signatory to United Nations Convention Against Corruption (UNCAC) and ratified it in May 2011 [1][2][3]. India has been actively participating in the Review process in accordance with the Resolution 3/1. The Second cycle of the review started in 2016. It is assessing the implementation of Chapter-II on Preventive Measures (Article 5-14 of UNCAC) and Chapter-V on Asset Recovery (Article 51-59 of UNCAC). It is due in the 5th year of the second cycle [4].

India is not a member of the Organisation for Economic Co-operation and Development (OECD) but is one of the non-member economies the OECD has working relationships with. India is defined as a Key Partner after the 2007 OECD Council Resolution on Enlargement and Enhanced Engagement and is included in OECD analysis and statistical databases. India has also been a member of the OECD Anti-Corruption Initiative for Asia and the Pacific since 2001 and has endorsed the ADB/OECD Anti-Corruption Action Plan for Asia and the Pacific. India is not a signatory to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (Anti-Bribery Convention) [5].

The Prevention of Bribery of Foreign Public Officials and Officials of Public International Organisations Bill was introduced in Lok Sabha in 2011 to comply with international standards. As of date, the Bill has not been passed [6]. India is not a significant defence exporter [7].

In July 2018, the government passed the Prevention of Corruption (Amendment) Act, 2018, which amended and brought significant changes to the Prevention of Corruption Act, 1988 to bring the legal framework in conformity with current international practices of UNCAC. India widened the definition of criminal misconduct to include the briber giver [1][2]. As alluded to above, India has been actively participating in the Review process. It underwent a review by Uganda and Kazakhstan. The report was received in March 2017, it has yet to be made publicly available [3].

India has an institutional and legislative framework for fighting corruption including an independent Central Vigilance Commission, Central Information Commission, Comptroller and Auditor General, the Judges (Inquiry) Act ,1968 and a number of legislations including the Whistle Blowers Protection Act , 2014; the Lokpal Act, 2013; the Prevention of Money Laundering Act, 2002; the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 and the Benami Transactions (Prohibition) Amendment Act, 2016 [4][5].

The government has taken a number of steps to address corruption in recent years including abolishing the system of attestation or authentication by government servants for submission of certificates by those seeking jobs or for other government facilities, abolishing personal interviews for recruitments to lower level posts in the Federal Government and its organisations to help eliminate scope for subjectivity and corruption in the selection process and demonetisation of high value currency to eliminate black money and corruption in 2016. The latter was deemed controversial by some. The government still maintains it was an effective measure [6][7][8].

Pursuant to the G20 Anti-Corruption Action Plan for 2017-2018, India participates in the meetings of the G20 Anti-Corruption Working Group which monitors implementation and enforcement of the OECD Anti-Bribery Convention. India was included in the G20 Self-Assessment Report on Combating the Bribery of Foreign Public Officials [9].

India participates in selected OECD Committees and their subsidiary bodies. India became the first Key Partner country to join the OECD Network on Fiscal Relations across Levels of Government in 2013. India is an important contributor to a range of OECD standard-setting activities. It adheres to twelve OECD legal instruments. India signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting in June 2017 [10].

It has also participated in efforts to develop inclusive and progressive legal instruments for corporate governance and competition on equal footing with OECD Member countries. The OECD values India’s contribution and believes accession to the Anti-Bribery Convention can enhance India’s efforts to combat transnational bribery [11].

Indonesia is currently ranked 24 in the Stockholm International Peace Research Institute’s (SIPRI) database of 100 largest arms-exporting countries, with a total export value of USD 110 million in 2017-2018, which is slightly lower than in 2016-2017, when it was ranked 23 [1]. SIPRI recorded that, in the past decade, Indonesia exported to the Philippines (ships), Senegal (transport aircraft) and Vietnam. Indonesia also exported small arms and light weapons to countries such as the USA, Thailand, Singapore (munitions) and Chile (smoke warheads) [2]. The annual figure of Indonesian arms export across 2010-2018 remains puny, around USD 25 million [3]. Indonesia signed the UN Convention Against Corruption (UNCAC) on December 18, 2003 and ratified it through Law No. 7/2006 [4]. Indonesia has not signed the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Regardless, Indonesia is a signatory to bilateral Mutual Legal Assistance (MLA) treaties with several OECD Convention members such as Australia, Korea and other countries in the Southeast Asian MLAT, such as Hong Kong, China, Malaysia, Philippines, Singapore and Thailand. There are some requirements in the OECD Convention that Indonesia has met, for example, there have not been any instances of bribery of foreign public officials and the country has not received any incoming extradition of MLA requests involving the offence. Illicit enrichment is also not an offence in Indonesia per se; it is only a crime if it amounts to money laundering and the enrichment derives from criminal activities.

Indonesia received 32 recommendations from two rounds of UNCAC assessments, but so far, only eight recommendations have been resolved [1]. In later reviews, Indonesia addressed 13 out of 21 recommendations. Among the most important recommendations that have not been fulfilled is the Revision of the Corruption Criminal Law, the Criminal Code Law, Asset Deprivation Law, Extradition Law and Reciprocal Legal Aid Law in Criminal Issues. Areas that are in dire need of improvement include legal cooperation and harmonisation of national legislation in the prevention and eradication of criminal acts of corruption. Late last year, Indonesia’s Corruption Eradication Commission (KPK) called on all stakeholders to implement UNCAC’s recommendations [2].

Iran has signed up to and ratified the United Nations Conventions against Corruption (UNCAC). The country exports weapons within its region; however, it does not declare its exports to the UN Register on Conventional Arms [1]. Iran currently remains under an arms embargo; therefore, its exports are considered illicit. Iran is not listed in the top 25 arms exporters by Stockholm International Peace Research Institute (SIPRI), but again it does not report its arms exports [2, 3]. It is classified by Transparency International Defence & Security (TI-DS) as a significant defence exporter. Iran has not signed up to the Organisation for Economic Co-operation and Development (OECD) Convention.

Review Cycle 1 for Chapters III and IV of the Convention has taken place [1]. Iran has made efforts to comply with both Chapters III and IV; however, it needs to overcome several challenges towards implementation [2]. For example, with regards to bribery and trading in influence (Arts. 15, 16, 18 and 21), the review states that “[a]ctive and passive bribery of foreign officials and officials of public international organizations are not currently covered but draft provisions are being considered” [2]. Review Cycle 2 for Chapters II and V is not yet published.

Iraq is not a defence exporter. The country’s legislature approved and ratified the United Nations Convention against Corruption UNCAC, on March 17, 2008, in Law. No. 35 (1), (2). Iraq has been repeatedly urged by the UN to implement its instruments in a move towards good governance and to satisfy the stipulations of the convention. At the national level, Iraq’s Accountability and Justice Act (3) is the most significant anti-corruption instrument, passed by the council of representatives in 2008, “criminalizing the major forms of corruption”; “active and passive bribery attempted corruption, extortion, money laundering and abuse of office” (1). Iraq’s anti-corruption watchdog, the Commission of Integrity acts under article 6 and 36 of the UN Convention Against Corruption (2). At its 13th meeting, the conference of the states parties to UNCAC, in November 2017, Iraq sponsored the amended draft resolution for “Strengthening mutual legal assistance for international cooperation and asset recovery” (3).

The UNCAC covers the following areas that signatories are required to engage and ultimately fulfil; prevention, criminalization, international cooperation and asset recovery. Compliance is compromised by several factors. Two of the most critical factors are, firstly, the failure of institutions to act as a check on power and, secondly, the poor and biased application of the rule of law (1). Provisions and penalties exist (2), but the real challenge noted by a UNDP-advisor is the ability of the existing leadership to transform “the political model from hegemonic imbalance and institutional fiefdoms” to one that respects diversity “with democratic oversight and accountability preventing the use of the security sector for suppression” (3). Iraq scores 11.6 out of 100 for its legal environment; fourth to last in the region (4). The culture of bribery and deployment of intermediaries as a conduit for unlawful payments undermines the quality of services provided and job performance. Furthermore, we see that UNCAC compliance is compromised. Many analysts and legal experts, among those interviewed, note that the anti-corruption laws laid out in the penal code only apply to the public sector and fail to include war crimes and human rights abuses (5). The political elite’s involvement in organised crime has fostered a culture in which existing checks and laws are weakened and the law does not allow for countervailing actions against the elite (6). These failures culminated as one article put it “a head-on confrontation with institutionalised corruption” as protesters called for the fall of the government (9). This was summarized further by an adviser to current PM, Laith Kubba as unconventional, “Iraq has 10 blocs who have real power via armed groups, they have banks, TV stations, MPs and the corruption merges with those blocs”.

Iraq has shown an openness to work and accept assistance in the form of policy guidance from the International Community. The inauguration of the Supreme Anti-Corruption Council (SCC) represents an important expression of commitment to the ground covered by the UNCAC. Decisions adopted by the SCC are not limited to defence but have seen the referral of cases of corruption to the judiciary (8) although coverage of the mechanisms and outcomes are demonstrably opaque. Colossal revenue loss remains an issue, which suggests a minimal impact from the UNDP asset recovery framework (7), it has not been a sufficient enough mechanism for the recovery of billions, due to the politicisation of corruption matters and investigations which the National Integrity Commission (COI) undertakes, hence recent calls from the KRI COI for Baghdad to appoint a court for prosecuting corruption (8).

In light of the evidence presented, there is little question that the behaviour of Iraq’s ruling class has fostered a culture of corruption.

Israel is a member to both the UN Convention against Corruption (UNCAC) (1) and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (2); UNCAC: Signature: 29 Nov 2005; Ratification/acceptance: 4 Feb 2009; OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions: Deposit of instrument of ratification/acceptance: 11 March 2009; Entry into force of the Convention: 15 February 1999; Entry into force of implementing legislation: 21 July 2008 (3) According to SIPRI, Israel was the eighth largest exporter of major arms between 2016-2020 (4).

Officially, “Israel strengthens the Battle against Bribery and Corruption” (1). In a 2017 assessment regarding compliance with the OECD Convention, the Working Group commended the government for the “considerable progress” it had made in addressing the WG’s concerns over implementation of the convention (2). Particular progress was made in relation to enforcement of anti-bribery rules and the sanctioning of offenders and in strengthening tax regimes and anti-money laundering rules (2). This has also been noted by civil society studies which have identified Israel as on of only four countries with “active enforcement” of foreign bribery regulations (3). Moreover, in October 2019 the Israeli State Attorney’s Office published new guidance regarding the criminal indictment and sanctioning of corporations whcih sets out the main elements necessary for assigning criminal liability to a corporation and instructs prosecutors to ensure that suspicions of corporate criminal liability are properly investigated (4). However, progress remains to be made in other areas. For exmaple, while Israel’s Defence Export Controls Agency did raise awareness of the foreign bribery offence through its compliance guidance, it has not establish formal guidelines on conducting due diligence on applicants, including the use of international debarment lists or provide sufficient training of its officials on foreign bribery risks. In addition, the country has not adopted an express policy permitting procurement authorities to deny contracts on the basis of a foreign bribery conviction. Israel has also not encouraged its public procurement authorities to consider applicants’ internal controls and compliance programmes or to refer to international debarment lists. Finally, Israel has not implemented the Working Group’s recommendations to amend specific articles in the Israeli Penal Law which apply to crimes committed abroad. In particular, Israel is still at the stage of developing draft legislation to address the dual penalty requirement regarding sanctions as well as the dual criminality limitation on Israeli criminal jurisdiction. Similarly, Israel has not amended the monetary threshold that applies to its anti-money laundering offence , although a bill that would reduce the threshold to approximately EUR 10 000 has passed the first reading in the Knesset. The Working Group will further assess Israel’s implementation of the Convention and its enforcement efforts during Israel’s Phase 4 evaluation, which is scheduled for June 2023 (p. 4). (2)

Related to UNCAC, some challenges in implementation are described on page 8-9: “While noting that Israel has a robust criminal justice system and is in large part in compliance with the provisions of the Convention against Corruption, the reviewers identified a few challenges in implementation and/or grounds for further improvement (depending on the mandatory or optional nature of the relevant Convention requirements): • To promote the goals of article 20, Israel could consider giving the State Comptroller, the legal advisor of the Knesset or some other appropriate body or person authority over the asset declarations of Members of the Knesset. • With respect to articles 23 and 24, it is recommended that Israel finalize the process of the adoption of the amendments to Schedule 2 of the PMLL, lowering the threshold for the price of the “prohibited property” and removing the differentiation between different kinds of such property. • Consider including all Convention against Corruption offences as predicate offences for the purpose of money-laundering, including in particular Sections 244 (Obstruction of justice), 245 (Subornation in connection with an investigation), and 246 (Subornation of testimony) of the Penal Law. • Israel is encouraged to proceed with the reform of the regime governing the criminal liability of legal persons, which appears to be conducive to further deterrence and prevention. • It is recommended to pursue legislation of a bill aimed at including corruption among the offences that allow the use of special investigative techniques such as wiretapping against Members of the Knesset. • Israel might consider looking more closely into the matter of out-of-court settlements in regards to corruption offences related to securities, in order to ensure adequate predictability by establishing predetermined criteria. • Israel is encouraged to continue to strengthen measures to raise awareness of public sector reporting and protection mechanisms. • Israel may wish to consider entering into international agreements or arrangements concerning the potential provision of preferential treatment by the competent authorities of one State to a cooperating person located in another. • Israel is encouraged to continue strengthening measures with a view to increasing reporting of corruption offences by private persons.” and page 12: The following points are brought to the attention of the Israeli authorities for their action or consideration with a view to enhancing international cooperation to combat offences covered by the Convention: • It is recommended that Israel adapt its information system to allow it to collect data on the type of MLA and extradition requests, the time frame for providing responses to these requests, and the response provided, including any grounds for refusal. • Israel is encouraged to actively promote a policy of acceding to or concluding new bilateral and multilateral agreements or arrangements to carry out or enhance the effectiveness of extradition. • Israel should consider adopting more specific guidelines or regulations regarding the procedure of transferring criminal proceedings among States parties. (5)
Since the publication of this report some progress has been made. Regarding out-of-court settlements in corruption offences related to securities, the State has signed two such agreement in recent years – in the cases of Siemens and Teva (6). Regarding MLA, a new data system regarding all incoming and outgoing requests for mutual legal assistance, including those that address foreign bribery offences has been established. This system enables an immediate and ongoing follow-up of such requests and of the actions taken in response to them. The system also enables compilation and analysis of relevant descriptive statistics (7).

Italy is one of the major defence exporters worldwide [1]. It has signed and ratified the UNCAC [2], the Group of States against Corruption (GRECO) of the Council of Europe [3], the EU Convention against corruption involving public officials [4], the OECD Anti-Bribery convention [5]. Nonetheless, even though Italy is part of the Council of Europe’s Criminal Law Convention [6], it has signed, but not ratified, the Additional Protocol to the Convention [7].

According to the last UNCAC Country report of 2019, there is room for improvement in the implementation of the convention. Among the advised improvements there are the following. For what concerns the implementation of art. 5 and 6 of the Convention, programmes and measures for public officials are not always fully applied. When it comes to the sanctions related to the violation of the administration-specific code of conduct by the civil servants, the national authority against corruption (ANAC) is developing guidelines for their management. Regarding accounting and auditing system, within public administration there is at the moment no internal control and audit system. Nonetheless, Italy is taking steps towards the development of a harmonised system. [1]

As far as recommendations from GRECO are concerned, the 2018 GRECO evaluation report states that actions dealing with recommendations to improve corruption prevention in the parliament are not satisfactory, while those to address potential corruption in the judicial system have been developed. [2]

The 2017 European semester country specific recommendations, identified the need for the country to reduce the trial length in civil justice, and to complete reforms of the public sector in order to fight corruption [3].
When it comes to the OECD Anti-Bribery Convention, the last available country report on the implementation of the convention is dated 2014, therefore it is not possible to properly assess Itlay’s compliance to the Convention [4]. However, the Country Fact Sheet of the Government at a Glance 2019 [5] indicates that Italy made some improvements, particularly regarding the performance of public procurement. To note, is the adoption in 2017 of Law 23 June 2017, n. 103 that significantly extended time barring periods for crimes related to bribery [6]. During the legislative process, the OECD Working Group on Bribery on Italy’s implementation of the Anti-Bribery Convention welcomed the legislative initiative [7].

Japan signed the United Nations Convention Against Corruption in December 2003, and in 2006 the National Diet of Japan gave approval of its ratification that would enter into force once appropriate domestic legislation had been enacted. On June 15, 2017, the National Diet of Japan adopted domestic legislation that enacted the treaty. On July 11, 2017, the National Diet of Japan ratified said treaty. [1] Japan deposited its instrument of ratification of the OECD Anti-Bribery Convention in 1998, and its domestic implementing legislation of the convention entered into force on February 15, 1999. [2]

The OECD recently (July 2019) stated that, “Japan continues to demonstrate a particularly low level of anti-bribery enforcement. Since 1999, it has only prosecuted 5 foreign bribery cases and sanctioned 12 individuals and 2 companies.” [1] However, in the same statement, the OECD also noted some positive developments: “At the same time, the Working Group notes a number of positive developments since its previous evaluations. Most notably, Japan’s 2017 amendment of its Act on Punishment of Organised Crimes and Control of Crime Proceeds (AOCL) introduced the possibility to confiscate the proceeds of foreign bribery and criminalised the laundering of the proceeds of foreign bribery, thus closing a significant loophole in Japan’s implementation of the Convention. Japan also introduced a new Agreement Procedure in June 2018, which could potentially enable Japan to more effectively investigate and conclude foreign bribery cases. Finally, Japan’s ODA agency (JICA) has developed and enforced a rigorous debarment policy for companies implicated in foreign bribery offences, which constitutes a potentially powerful tool in the sanctioning of the foreign bribery offence.” [1]

Jordan signed the UNCAC convention on 9 December 2003, and ratified it on 24 February 2005 (1)(2)(3).

Since its ratification, Jordan has exerted major efforts for compliance with UNCAC. In 2006, the government established the Anti-Corruption Commission and an Ombudsman Office, which carried on their work until 2016, when both entities merged together to constitute the Integrity and Anti-Corruption Commission [1]. The Commission drafted and published its 2017-2025 strategy during a press conference by the Prime Minister [2, 3]. Jordan has also amended a number of laws in order to comply with the UNCAC [4]. The country has also submitted a number of reports to the UNCAC. Despite the fact that changes were made to the legal frameworks preventing corruption, there is little evidence on how issues of corruption are being dealt with, and how cases are being treated.

Kenya is not a significant defence exporter, and it has not signed the the OECD Convention. However it was actually the first country to sign and ratify the United Nations Convention against Corruption (UNCAC) Convention in December 9, 2003. [1]

However, in order to strengthen the criminalisation strategy of fighting corruption, a task force appointed by the Attorney-General to advise the President on appropriate interventions for enhancing the fight against corruption recommended that the country signs and adopts the OECD Anti-Bribery Convention, in order to criminize corruption committed by foreign public officals.

Kenya has signed several conventions, including the UNCAC. A task force appointed by the Attorney-General to advise the President on appropriate interventions for enhancing the fight against corruption noted that, among other challenges, there was generally a slow implementation of various anti-corruption strategies. Second, there is a slow enactment of policies of enabling legislation. [1]

However, under the UNCAC, the only major area not complied with is legislation on Whistleblower protection. In addition, the country review report of Kenya on the implementation of UNCAC noted that while Kenya has signed and ratified the convention, that there is a need for the country to strengthen data collection systems for reporting on the investigation, prosecution and adjudication of corruption across institutions. [2]

The Kosovo institutions have not signed up to the international anti-corruption measures, more specifically to the United Nations Convention against Corruption [1], or the Organisation for Economic Co-operation and Development Convention on Combating Bribery of Foreign Public Officials in International Business Transactions [2, 3].

Given that Kosovo has not signed or ratified any relevant conventions, this sub-indicator is not applicable for Kosovo [1].

Kuwait signed the UNCAC in December 2003 and ratified it in February 2007 (1), but it did not sign up to the OECD convention (2), as it is not a high-profile defence exporter. Like other Gulf countries, Kuwait’s military is small, with about 15,000 only (3) in active duty, and it is not a producer of military equipment, and it is not a major imports of arms either, (5) even though it has increased the number of purchases in recent years in the wake of the Arab Spring revolts, which politically destabilised the region and eventually led to the current rift between Qatar and Saudi Arabia and other Gulf states — a conflict where the threat of military action by Saudi Arabia against Qatar has been been seriously discussed, and which Kuwait is trying to resolve as a mediator, according to officials and news reports (4, 6 and 7).

Kuwait has taken many steps to comply with UNCAC standards, especially the ones listed in Chapter IV, according to the UN’s 2015 implementation review (1). In recent years, it has streamlined its extradition and mutual legal assistance procedures with other states, offering frameworks for bilateral cooperation agreements, increasing its cooperation with networks such as Interpol, and expediting extradition requests.

It also established the ACA in 2016 (2), whose job is to gather, investigate and refer to the prosecution corruption complaints from all Government sectors, including its defence and security agencies, according to the UN’s 2016 review (1).

ACA requires all civil servants to disclose their personal finances, which applies to all defense and security sector employees, and it issued Law no. 23 of 2013 (3), which requires banks in Kuwait to ask for and retain more information from their clients to prevent money-laundering, according to state media (4).

But Kuwait has not taken similarly positive steps since 2016, and the steps that it took did not yield results. The public has yet to see their effects. As far as local media, journalists and activists are concerned, no senior official has served time or paid a fine for corruption or negligence — and that is not for a lack of both. In May 2018, the head of the ACA, Abdel Rahman Al-Nimsh said that IMF studies showed that bribery alone costs the country at least 2.2 billion USD a year (5).

Moreover, Kuwait still has not determined its position on bribes offered to foreign officials or occurring in the private sector. And its Public Tenders Authority does not have the right to audit and monitor purchases of “defence materials” made by Kuwait’s military, police or KNG (according to article 2 of Law no. 29 of 2016, the public tenders act) — that task goes to a special committee formed by an executive order from the Prime Minister, and the heads of the agencies making the purchases are the ones who choose the members of this committee (6).

Latvia is not a significant defence exporter. [1] It signed the UNCAC Convention on May 19, 2005, and ratified it on January 4, 2006. [2]

The latest Review of implementation of the UNCAC available (2014) identified both successes and good practices, as well as challenges in the implementation of the convention. [1] [2]
Among good practices were underlined the fact that the criminalisation of trading in influence has a broad scope, that there is a comprehensive legal framework for the protection of witnesses, the competencies and function of KNAB as a specialised anti-corruption authority, and the implementation of legislation on international cooperation in criminal matters. Among the challenges were highlighted several aspects of incomplete legislation regarding anti-corruption. [1] As for the OECD Convention, a 2017 Implementation report mentions that Latvia has taken substantial steps to implement the Recommendations. Overall, out of 44 Recommendations, 26 are fully implemented, 13 partially implemented and 5 not implemented. It also explains that the Corruption Prevention and Combating Bureau (KNAB) should make additional efforts to increase its ability to detect and investigate foreign bribery, and to prevent, detect and comply with laws on corruption and related offences. [3] A particularly important step is also the enactment of the Whistleblowing Law, which protects whistleblowers in the public and private sectors, therefore implementing more recommendations for the year 2018. [4] In this way, Latvia took the necessary steps to encourage and facilitate whistleblowing across the spectrum, promoting transparency and fairness in all work sectors.

In 2009, the Lebanese government signed and acceded to the United Nations Convention Against Corruption (UNCAC) (1). Furthermore, Lebanon is not a defence exporter and, at the time of the research, is not an OECD member and has not signed the organization’s convention (2).

Though Lebanon has enhanced its anti-corruption legal framework and has passed significant laws to improve transparency including the access to information (2017), transparency in oil and gas (2018), and the protection of whistleblowers (2018) (1). Nevertheless, the country still faces gaps in its legal framework in compliance with the UNCAC. For example, Trading in Influence (UNCAC Art. 18) is not criminalized by Lebanon’s Penal Code (LPC). The private sector bribery section in the LPC does not cover all the sections in UNCAC Art. 21. Similarly, Art. 23, 24, and 25 are partially adopted by LPC. On the other hand, Lebanon’s LPC is in line with Art. 15 (a,b), 17, 19, 20, and 22. For instance, Art. 670, 671, and 673 criminalize embezzlement of property in the private sector (UNCAC Art. 22) (2).

Lithuania has signed and ratified both the UNCAC Convention and the OECD Convention on Combating Bribery of Foreign Public Officials in International Business [1,2]. Lithuania is not a significant exporter in the field of Defence.

Lithuania has complied with most of its obligations.
With regards to the OECD Convention on Foreign Bribery, there have recently been several legislative amendments, namely:
• Sanctions for corruption-related offences have been increased.
• Amendments to the Penal Code that enabled the prosecution of foreign persons in absence of corruption related offences [1]
• Amendments clarifying definitions and outlining that legal entities which are state- or municipal-owned and state- or municipal-controlled are not considered state- or municipal institutions, and therefore fall within the ambit of the Penal Code.
• Widening of the object of crimes of bribery and graft. Before June 2017, prosecutors had to prove the exact acts of omission agreed by the culprits, whereas now the article explicitly addresses more lenient information needed for prosecution.
• As of November 2017, the Penal Code prescribes an obligation to announce in full the sentencing verdict of a legal person (a person on trial?) for crimes of bribery, trading influence and graft through media.
• On November 2017, legal persons came under the remit of Article 226 regarding the crime of ‘trading influence’ (Article 226 of the Penal Code).
• Approval of the Law on Whistleblowers’ Protection by Parliament on 28th November 2017, which came into force on 1st January 2019. Governmental Decree that sets the framework for reporting channels had to be enacted before this date [2,3].

Lithuania has taken significant steps to strengthen its legislative framework to combat foreign bribery. Yet further efforts are recommended to ensure effective enforcement of anti-bribery laws regarding corporate liability and to impose sanctions on foreign bribery, including confiscation, according to a 2017 report by the OECD Working Group on Bribery [4].

The latest review of Lithuania’s compliance with UNCAC suggests that the country has complied with most of its obligations in priority areas covered by the Convention [5].

Malaysia is a member of a number of notable anti-corruption institutions and is signatory to a number of relevant anti-corruption treaties. Malaysia became a signatory of the United Nations Convention Against Corruption (UNCAC) on December 9, 2003 and subsequently ratified the Anti-corruption Convention on September 24, 2008. [1] [2] Although it is not a member or key partner of the OECD, [3] Malaysia formally endorsed the ABD/OECD Anti-Corruption Initiative for Asia Pacific Action Plan on November 30, 2001 and became a member. [4] Additionally, through the Malaysia Anti-Corruption Commission (MACC), Malaysia is a part of the South East Asia Parties Against Corruption (SEA-PAC) mechanism, the Economic Crimes Agencies Network (ECAN) [5] and the Anti-Corruption Agency (ACA) Forum. [6] Other relevant anti-corruption institutions which Malaysia is also a member of include the Asia Pacific Group (APG) on Money Laundering, [7] the Asia Pacific Economic Cooperation (APEC) Anti-Corruption and Transparency (ACT) Working Group/Experts Task Force, the International Association of Anti-Corruption Authorities (IIACA), the Offshore Group of Banking Supervisors, the Egmont Group of Financial Intelligence Units, the International Anti-Corruption Academy (IACA), INTERPOL and ASEANAPOL. [8] The Strategic Trade Act 2010 which was initiated by the Ministry of International Trade & Industry (MITI), drafted by AG’s chambers and approved by the cabinet in 2010, was also adopted mainly to comply with WMD, UN Security Council 1540. [9]

The most recent review by the UNCAC Implementation Review Group on Malaysia’s compliance to UNCAC was published on May 28, 2013 and included Chapter Three, Criminalization and Law Enforcement, and Chapter Four, International Cooperation. [1] The report highlighted numerous successes and good practices on anti-corruption and provided recommendations to furthen strengthen anti-corruption measures. In July 2017, the MACC brought together the Institute for Democracy and Economic Affairs (IDEAS), the Center to Combat Corruption and Cronyism (C4) and Transparency International Malaysia (TI-M) as representatives of CSOs to participate in the review process of Malaysia’s implementation of Article 13 of UNCAC. The CSOs emphasised structural problems that limited civil participation against corruption. [2] The addition of Section 17A(4) and 41A in the MACC Amendment Act 2018 [3] introduces corporate liability for corruption offences: Section 17A(4) will provide commercial organisations with the defence of having had in place adequate compliance procedures when charged with an offence under Section 17A(1) of the MACC Act 2009 [4] and Section 41A provides for admissibility of documentary evidence. Malaysia has also stepped up its anti-corruption efforts through the establishment of the Special Cabinet Committee on Anti-Corruption (JKKMAR) and the Governance, Integrity and Anti-Corruption Centre (GIACC); the formulation of the National Anti-Corruption Plan [5] in which practical goals based on initiatives to be taken by every government and private agency to address corruption issues are set for the next five years; and the reopening of investigations into the 1MBD scandal, which saw former Prime Minister Najib Razak criminally implicated. [6] [7] Furthermore, Malaysia has seriously committed to anti-corruption as can be seen in the formation of the Council of Eminent Persons (CEP), [8] the 1MDB Special Task Force, [9] the Institutional Reform Committee, [10] the Special Committee on the Malaysian Agreement 1963, [11] the JKKMAR, the GIACC, and the National Anti-Corruption Plan. Even so, it is important to note that by many accounts Malaysia has dodged concerns on the role and power [12] [13] of the CEP and refused calls for transparency. [14] [15]

The country has yet to industrialise and thus does not have any kind of domestic defence manufacturing industry to speak of. It does not manufacture firearms or any kind of heavy, sophisticated military equipment, neither for export nor for domestic use. Mali ratified the UNCAC in 2008.

In 2014, the government enacted a law that requires all civil servants, including military personnel, to declare their assets.² ⁴ However, members of parliament and their children are not covered by the law. State employees were supposed to comply with the law by 2017, but following strike action by civil servants, the government agreed to suspend the application of the law and revise the text.⁵ The government has subsequently limited the application of the law to certain categories of civil servants, meaning that now only about 1,500 will have to declare their assets.⁴

Mexico is not a major arms exporter, and it signed the United Nations Convention against Corruption on 9 December 2003 and ratified it on 20 July 2004. [1] [2]

In compliance with the United Nations Convention Against Corruption, Mexico created the National Anti-Corruption System in 2015. In fact, some civil society organisations have joined the efforts of a global network of civil society organisations whose purpose is to promote the ratification, implementation, and monitoring of said Convention. Since then, attempts have been made to comply with priority areas of the Convention. One of the transversal axes of the new administration is the fight against corruption and the improvement of public management, which is reflected in the National Development Plan (2019-2024). [1]

However, Mexico maintains high levels of corruption, but issues such as money laundering, bribes, illicit enrichment, etc. are still of concern. The Office of the United Nations High Commissioner for Human Rights, for example, recently expressed “concern about the high levels of corruption and impunity that persist in the State party [Mexico],” and also for “the lack of adequate protection against people who denounce or investigate cases of corruption.” [2] [3] [4]

According to the National Institute of Statistics and Geography through the National Survey of Victimization and Perception on Public Security, after insecurity, corruption is the issue that most worries Mexicans. The 2018 Survey shows a significant statistical change in the levels of perception of corruption in defence and security authorities with respect to the previous year. [5] [6]

Montenegro is not a significant defence exporter. The country has ratified the UNCAC Convention [1] but not the OECD Convention. [2]

The last publicly available official assessment of compliance with UNCAC was published in 2013, and the second round is currently ongoing. [1] Even though Montenegro has undergone significant legal changes in this area, the legislation is not fully in compliance with the Convention. For example, the government refuses to criminalise illicit enrichment of public officials, despite recommendations by the international community, [2] prominent foreign experts, its own Parliament and civil society. [3]

The UN Convention Against Corruption was signed by Morocco on 9 Dec 2003 and ratified on 9 May 2007 (1).

Morocco is neither a member of the OECD nor a full participant in the OECD Working Group on Bribery in International Business Transactions. It therefore cannot ratify the OECD Anti-Bribery Convention (2)

Morocco is not a significant defence exporter: it is not part of the top 10 arms exporters (3)

There has been formal compliance from the Moroccan side to the international treaties the country has signed and ratified. Additionally, there has been an increase in the number of corruption cases brought to court. Nevertheless, corruption remains a widespread phenomenon within public administration including in the defence sector according to academics and NGOs. The Moroccan Penal Code dedicated section IV to corruption and influence meddling (Art 248 to 256-1) (1). Article 36 and 167 of the 2011 constitution are dedicated to the fight against corruption (2). In compliance with Article 6 of the 2003 UNCAC, a Central Authority for the Prevention of Corruption (Instance centrale de prévention contre la corruption, ICPC) (3), was created on March 13, 2007. On 13 December 2018, King Mohammed VI appointed Mohamed Bachir Rachdi as the president of a National Instance of Probity, Prevention and Fight against Corruption (Instance Nationale de la Probité, de la prévention et de la Lutte contre la Corruption, INPPLC). Furthermore, Morocco approved on 28 December 2015 a National Strategy for the Fight Against Corruption. The strategy aims to promote integrity and reduce corruption by 2025. It covers various areas, focusing on those related to the institutional and legal aspects. The implementation of this strategy was officially launched on 3 May 2016. A National Anti-Corruption Commission (CNAC) (chaired by the Head of Government and consisting of ministerial departments, relevant governance institutions, the private sector and civil society) is responsible for overseeing and monitoring the implementation of this strategy (4).

Myanmar is not a significant defence exporter and it has signed up to and ratified the United Nations Convention against Corruption (UNCAC). Myanmar signed the UNCAC on December 2, 2005, and ratified it on December 20, 2012. The Convention entered into force for Myanmar on January 19, 2013. The Anti-Corruption Law was enacted on August 7, 2013, and the Myanmar Anti-Corruption Commission (ACC) was established on February 25, 2014 [1].

Myanmar implements its obligations under the UNCAC through a variety of laws, including the 2008 Constitution, the Anti-Corruption Law of 2013 and the Anti-Money-Laundering Law of 2014. Myanmar underwent the second cycle of review of the implementation of the UNCAC in May 2019. The review team looked at the existing legal institutional framework and the overall effectiveness of current measures. The results of the review will be handed to the Myanmar government and the executive summary will be made public [1]. However, local media outlets reported that Myanmar has some issues of compliance with the UNCAC. Criminal liability of companies for corruption offences and the establishment of foreign bribery is essential to ensure compliance with the UNCAC. But these provisions are lacking in Myanmar. In Myanmar, companies can only be held accountable for money laundering and not for corruption [2]. The military and its enterprises enjoy immunity from anti-corruption jurisdiction according to the Constitution [3]. In terms of the armed forces, ceasefire capitalism and organised crime are common forms of corruption in Myanmar [4]. There are significant deficiencies in tackling corruption.

The Netherlands ratified both the OECD Anti-Bribery Convention and the United Nations Convention against Corruption (UNCAC) in 2001 and 2006 respectively [1,2]. In 2018, the Netherlands exported 750.93 million euros’ worth of arms, making it a significant arms exporter [3].

The Netherlands has had minor issues regarding compliance with both the OECD Anti-Bribery Convention and the United Nations Convention against Corruption. In 2015, the OECD Working Group on Bribery concluded that, though a number of recommendations provided by the OECD in 2012 had been implemented, some recommendations had not yet been implemented [1]. This was the last year a formal review of Dutch compliance with the Anti-Bribery Convention was published by the OECD. In 2017, a country review of the Netherlands was issued by the United Nations Office on Drugs and Crime (UNODC), which highlighted some minor recommendations [2]. For example, the UNODC review urged the Netherlands to reconsider its establishment of the offence of illicit enrichment and encouraged the realisation of a bill that would increase the possibilities for the collection and submission of bank information for domestic bribery investigations [2]. Despite these minor issues, the Netherlands, by and large, complies with the provisions set out in both agreements.

On 3 December 2015, New Zealand announced that it had ratified the UNCAC through making the necessary changes to 15 acts of the Organised Crime and Anti-Corruption Legislation Bill by Parliament [1]. Despite New Zealand not being a significant defence exporter, it has signed and ratified the OECD Convention [2]. This represents significant progress since the last Transparency Index.

New Zealand has complied with most of its obligations and regularly ranks amongst the least corrupt countries. Nonetheless, there are instances of bribery involving public officials. Potential loopholes or risk areas have been addressed through the likes of BEPS Multilateral Instruments, including for example the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting [1, 2, 3, 4]. The 2016 Phase 3 follow-up report found that New Zealand had taken considerable steps to fully implement 21 of the 29 recommendations of the Phase 3 Working Group. Of the remainder, seven were partially implemented and one not implemented [5].

As concerns UNCAC, Country Review Report of New Zealand’s Cycle 1 UNCAC review has been published [6]. Cycle 2 review is currently in progress but has been disrupted by COVID-19 [7]. The details of the last review (2017) can be found online [7]. In 2016, Potential examples of non-compliance were found in the Panama Papers, with a focus on New Zealand Trust Laws, but there is no evidence that these are within defence and security sectors [8, 9].

Niger is not a defence exporter. The Parliament of Niger ratified the United Nations Convention against Corruption through Act No. 2008-26 of 3 July 2008, and it was signed by the President of the Republic through Letter No. 15/PRN of 22 July 2008. The Convention was published in the Official Journal through Decree No. 2008-301 of 11 September 2008 (1,2). 

The UNCAC obliges the state parties to implement a full range of anti-corruption measures affecting their laws, institutions and practices. These measures aim to promote the prevention, detection and sanctioning of corruption, as well as the cooperation between state parties. The UNCAC establishes obligations for governments concerning preventive measures in different public sectors, and it also provides for punitive measures for behaviour considered as bribery or illicit enrichment of a public official. It has also provisions regarding international cooperation between law enforcement authorities, asset recovery, technical assistance and mechanisms for implementation. The Implementation Review Mechanism (IRM) is a peer-review process that assists state parties to implement the Convention effectively. For Niger, the latest review was conducted by the UNODC experts in 2016, resulting in a report, the executive summary is public and was published online (1).
According to the document, Niger complied with most of the obligations in priority areas covered by the Convention: “In general, Niger has undertaken substantial efforts of reform aimed at implementing the provisions of the Convention. The drafting of a bill containing relevant amendments to the Criminal Code on combating corruption is particularly noteworthy. This bill was submitted during the country review and has proved to be in full compliance with the Convention. Its adoption will provide a response to the comments made below concerning challenges in implementation. Furthermore, the establishment of HALCIA and the Information and Verification Office of the Ministry of Justice have been highlighted, as well as preventative and awareness-raising initiatives on corruption issues. Effective inter-agency coordination and cooperation at a national level have also enabled various authorities involved in the fight against corruption to define their roles and actions more clearly” (1).
Among the challenges identified by the UNODC review, a better law reinforcement was needed. The Niger government adopted the anti-corruption bill on 6 December 2016 and HALCIA has become more effective in the identification and seizure of assets (2).
For example, in April 2017 the government of Niger has recovered more than USD 5 million in bank accounts, real estate and property (3). Furthermore, in January 2018, the Council of Ministers adopted a decree project on the policy document regarding National Strategy against Corruption and its Action plan/Stratégie Nationale de Lutte contre la Corruption et son Plan d’action (4,5). However, in the context of insecurity on Niger borders, the spread of smuggling, drug trade and illicit arms circulation since 2011, compliance to the UNCAC is facing numerous challenges.

Nigeria signed and ratified the UNCAC on December 9, 2003, and October 24, 2004, respectively (1).

Nigeria is not an exporter of arms, and therefore not a member of the OECD convention (2). Nigeria has also ratified the Ecowas tax administration treaty which aims to improve the exchange of tax-related information between ECOWAS member states. Nigeria is a party to the African Union Convention on Preventing and Combating Corruption [AUCC] which was adopted in Maputo on July 11, 2003, to fight rampant political corruption on the African continent.

A first cycle review was conducted between the 7-9 April 2014 (Chap III & IV), a second review cycle (Chap II & V) has also been conducted (1). There are a few issues concerning the implementation of domestic law which have been identified. It does appear that some of these issues have been adequately addressed by the Federal Government of Nigeria, for example, Anti-Corruption and Transparency Monitoring Units have been set up in State Ministries, Departments and Agencies (MDAs). A National Anti-Corruption Strategy was launched in April 2017 (2). However, the problems of coordination between the different anti-corruption agencies continue to exist (2). Limited resources and funding have created communication challenges. Implementation challenges exist with the mandate of the preventative bodies due to the interference of other branches of government. This often manifests in institutional resistance, political interference, and the unwillingness of public officials to comply with the law. Inadequate financial resources also limit the effectiveness of agencies. No candidate or political party has been sanctioned for violating the laws or rules on political funding/campaign finance laws, this is because the Independent National Electoral Commission (INEC) does not have the power to prosecute. Power to prosecute lies with the Attorney General of the Federation (AGF) and no requests for prosecution has been forwarded to the AGF.

North Macedonia signed the United Nations Convention against Corruption (UNCAC) on August 18, 2005 and ratified it on April 13, 2007 [1]. The Convention entered into force domestically on April 13, 2007. According to the Constitution, “the international agreements ratified in accordance with the Constitution are part of the internal legal order and cannot be changed by law” [2]. Notably, the country is not a significant exporter of defence and regularly prepares annual reports on arms exports before submitting these to the South Eastern and Eastern Europe Clearinghouse for the Control of Small Arms and Light Weapons (SEESAC) [3]. North Macedonia is also mentioned in the EU Council’s annual report on exports of military technology and equipment [4].

North Macedonia has formally adopted most of the legislation endorsed by the United Nations Convention against Corruption (UNCAC) and has also signed a number of other corruption-related conventions, additional protocols and agreements [1]. These all contribute to the internal legal order of the country. Renowned international reports have noted North Macedonia’s advanced anti-corruption legal system, although recognise challenges in its implementation [2]. The 2018 country report by the European Commission reinforced this perspective by explicitly stating: “the legislative and institutional framework is in place. Yet, the capacity of the institutions to effectively tackle corruption has shown structural and operational deficiencies” [3]. The 2018 findings from the formal peer review process aimed at evaluating compliance with UNCAC provisions (through the Implementation Review Process) are aligned. While successes and good practice in implementing chapter III of the Convention are highlighted, challenges remain with regards to implementation, especially regarding bribery in the private sector, illicit enrichment, protection of whistleblowers etc [2].

Norway ratified the OECD Convention in 1998 and the UNCAC in 2006 [1, 2]. The country is also among the largest exporters of major arms, ranking 17th between 2014-2018 [3].

Norway’s monitoring reports to the OECD on the implementation of the convention are published online [1], with the latest report published in June 2018. The report acknowledges that Norway has a robust legal framework that has supported active anti-bribery enforcement [2]. However, it also argues that, since the previous report in 2011, Norway has made some significant amendments which could weaken enforcement. Most notably, the report refers to the amendments in the Penal Code narrowing Norway’s jurisdiction over criminal offences committed abroad. In addition, the follow up evaluation published in 2013 concluded that, out of 8 recommendations put forward by the 2011 report, 5 had been fully implemented, 2 implemented partially, and 1 not implemented at all [3]. In this regard, although the 2018 report acknowledges that Norway has made progress in enacting the legislation called for in 2011, it found it necessary to reiterate the recommendation which was evaluated as not implemented. As for the recommendations evaluated as partially implemented in 2013, the working group will follow up on these issues. In total, the 2018 report puts forwards 5 recommendations and specifies 7 issues which need to be followed up. Norway is expected to submit a written report in June 2020 on the implementation of all recommendations and its enforcement efforts. The latest publicly available UNODC’s report on Norway’s compliance to UNCAC covers the period 2010-2015 [4]. While it identifies areas of improvement, particularly in international cooperation, it indicates that Norway has been largely compliant with the convention. A new evaluation cycle focusing on Chapters II and V of the UNCAC is in progress.

Oman is not a significant defence exporter and has ratified the UNCAC Convention in January 2014 (1), (2). In August 2016 Oman ratified the OECD Convention on Combatting Bribery of Foreign Officials in International Business Transactions (2).

Oman has compliance issues, although there is some evidence to suggest it has made initial attempts to formalise obligations from the UNCAC convention. One formal UNCAC consultation was conducted by the Implementation Review Group of the UNCAC in April-May 2015 (1). This review focused on the implementation of Articles 15-42 of Chapter III and Articles 44-50 of Chapter IV of the UNCAC based on self-assessment from Oman in review cycle 2010-2015 (2). The implementation review group’s document includes a list of 26 recommendations for the Omani government to comply with the convention, and these specifically highlight issues related to bribery, physical enforcement, imprisonment and the rights of victims and whistleblowers (2). There is a reference to the review concerning ratified legislation, where a dedicated team working on the implementation of UNCAC cooperates with the State Financial and Administrative Audit institution to review the implementation (1). Since 2015, there has not been a second review of Oman’s compliance (3). Oman has largely failed to comply with the UNCAC convention in light of the review completed in 2015.

The Palestinian Authority signed and ratified the UNCAC in 2014, as part of its efforts to gain international recognition(1). The Anti Corruption Commission has issued several statements on this issue, trying to apply all UNCAC articles and instruments, as much as it can, because the PA is not a sovereign state yet (2). However, Palestine is not a defence exporter and does not import any heavy weaponry.

This indicator has not been assigned a score due to insufficient information or evidence.

There has not been any report or information about compliance relating to the ratified agreement (1), (2).

The Philippines is not a significant defence exporter and signed the UNCAC on December 9, 2003 and ratified it on November 8, 2006 [1, 2]. The country is not a signatory of the OECD convention [3] but has signed (although not yet ratified) the OECD Multilateral on Mutual Administrative Assistance in Tax Matters [4].

At the first review cycle of UNCAC conducted by Bangladesh and Egypt in August 2012, the Philippines was found compliant in 55 out of the 66 provisions on criminalisation and law enforcement and in 48 out of 54 provisions on international cooperation. The Philippines has also subsequently set up several consultation groups in order to address issues of compliance from the previous review cycle [1, 2, 3, 4]. The second review cycle (2016-2021) examining Chapter II on Preventive Measures and Chapter V on Asset Recovery has not yet been conducted by the reviewing countries (Niue and South Africa) [5].

Poland has adopted both the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions of 21 November 1997 (ratified by Poland in 2000) [1] and the United Nations Convention against Corruption of 31 October 2003 (ratified by Poland in 2006) [2]. Poland has adopted also: the Council of Europe Criminal Law Convention on Corruption of 27 January 1999 (ratified by Poland in 2002), the Council of Europe Civil Law Convention on Corruption of 4 November 1999 (ratified by Poland in 2002), and the Council of Europe Convention on Laundering, Search, Seizure and Confiscation of the Proceeds from Crime and on the Financing of Terrorism of 16 May 2005 (ratified by Poland in 2007). Poland is not a significant arms exporter (c. 500 M euros per year) [3].

Poland has several issues of compliance with the OECD Convention and UNCAC. Regarding the OECD convention:

“Poland must make urgent progress on carrying out key recommendations of the OECD Working Group on Bribery that remain unimplemented… Poland still needs to take urgent steps to ensure companies can be held responsible for foreign bribery, even if the persons who perpetrated the offence are not convicted. In addition, Poland must increase the fines for companies in order to ensure foreign bribery is punishable by effective, proportionate, and dissuasive sanctions. The Working Group is disappointed by Poland’s failure to take measures to ensure that the “impunity” provision in the Penal Code that applies to foreign and domestic bribery cannot be applied to the bribery of foreign public officials. This provision allows perpetrators of bribery to automatically escape punishment by notifying the law enforcement authorities of the offence before the authorities learn about it from other sources” [1].

Regarding the UNCAC most of the essential provisions are implemented, for example, those relating to the bribery of the national officials, abuse of functions or embezzlement of property in the private sector [2]. Other provisions, such as the whistle-blower protections are only partially implemented. There is no comprehensive law on whistleblowing, but the Act on Counteracting Money Laundering and Terrorism Financing introduces an obligation to create whistle-blower protection mechanisms in the financial sector. The act came into force in July 2018 [3].

Portugal is a significant defence exporter, and has signed up to and ratified both the United Nations Convention against Corruption (UNCAC) [1] and the Organisation for Economic Co-operation and Development (OECD) Convention [2].

The most recent evaluation report on UNCAC compliance dates from 2018. The single evidentiary piece is the executive summary of Review Cycle II on Chapters II and V [1]. Reviewers issued nine recommendations on preventive measures and five on asset recovery. There is no evidence of UNCAC Coalition-sponsored updates to the 2013 Civil Society Review [2].

With regards to the OECD’s Anti-Bribery Convention, the most recent report remains the 2013 Phase 3 Report [3]. The country issued a written follow-up report [4] on implementation of recommendations which suggested full implementation, but the Working Group suggested that Portugal had not implemented Recommendation 7 or sub-recommendations 1(a), 1(c), 3(b), 4(a), 6(a), 7 and 10(b), while sub-recommendations 13(a)-(i) remained outstanding pending the 2022-scheduled Phase 4 evaluation [5].

The most recent evaluation of Portugal’s anti-corruption commitment and implementation is the Group of States against Corruption (GRECO) Fourth Evaluation Round Report [6] and the follow-up Compliance Report [7]. In the latter, GRECO finds that “GRECO concludes that minor improvements have been demonstrated by Portugal towards the fulfilment of recommendations found to be not implemented or partly implemented in the Fourth Round Compliance Report; only one of the fifteen recommendations has been implemented satisfactorily or dealt with in a satisfactory manner. Of the remaining recommendations, eight have now been partly implemented and six remain not implemented.”

Qatar signed the UNCAC Convention on December 1, 2007. It was ratified on January 30, 2007 through an Emiri Decree No. 17. The convention came into force for Qatar on March 1, 2007. [1] Qatar has not signed the OECD Convention, as it is not considered a first-hand arms exporter.

According to the Implementation Review Group of the UNCAC, Qatar has failed to fulfil its obligations, as stipulated in the UNCAC. [1] The observations of the Implementation Review Group were relevant to Bribery and Trading in Influence (arts. 15, 16, 18 and 21) and Extradition; transfer of sentenced persons, and transfer of criminal proceedings (arts. 44, 45 and 47). The Implementation Review Group’s document includes a list of recommendations for the Qatari government to follow, so that they comply with the convention. These specifically highlight issues related to bribery, physical enforcement, imprisonment and the rights of victims and witnesses. [2] According to our sources, Qatar has advanced in its effort to amend its laws to meet all UNCAC terms. According to our source, Qatar does not partake in many corrupt activities. [3] In addition, the ACC is newly established and tries to match its work with international standards. [4]

Russia is one of the significant arms exporters [1] and it ratified the OECD Anti-Bribery Convention in 2012 [2].

The OECD Working Group on Bribery has repeatedly warned Russia about its continued failure to implement key legislative reforms to enable it to effectively investigate, prosecute and sanction the offence of foreign bribery [1]. In November 2018, Russia issued a report following the recommendations dated 2012. Progress updates were only provided for 3 of 8 recommendations [2].

In April 2013, Saudi Arabia ratified the United Nations Convention Against Corruption (UNCAC) (1). However, like many of the signatories of the convention (including the USA), Saudi Arabia does not consider itself bound by Paragraph 2 of Article 66 of the convention, which provides for universal jurisdiction of the International Court of Justice to pursue violations of the convention; nor does it consider the convention to be the legal basis for extradition with other parties to the convention, which is provided for in Paragraph 5 of Article 44 (2). Saudi Arabia is not a member of the OECD and has not signed the OECD Anti-Bribery Convention. The Convention is open to accession by any country, which is a member of the OECD or has become a full participant in the OECD Working Group on Bribery in International Business Transactions (3).

According to the report by the Implementation Review Group for UNCAC published in June 2018, Saudi Arabia has committed itself to pursue zero-tolerance against corruption and has made significant efforts in the field of corruption prevention. Saudi Arabia has made progress in several areas. This includes simplifying administrative procedures across government departments; developing a comprehensive programme on corruption prevention; implementing various forms of professional and specialised training to counter corruption and strengthen integrity in the public sector; establishing a Standing Committee in Nazaha, the country’s main anti-corruption body, in September 2016 to follow up and monitor the implementation of Saudi Arabia’s national anti-corruption strategy. The report also outlines several challenges and recommendations for Saudi Arabia in terms of implementation of the Convention’s stipulations to bring the country more in line with international good practices, including in the areas of public procurement, management of public finances, and anti-money laundering (1). In August 2017, Saudi Arabia held a joint workshop together with the United States to review their experiences in implementing UNCAC (2), (3).

Serbia signed up to UNCAC in 2003 and ratified it in 2005 [1]. It is not considered a significant arms exporter, according to SIPRI [2].

Serbia is involved in the peer-review process on the implementation of UNCAC. It has passed the first review cycle (chapters of the Convention on Criminalization and Law Enforcement and International cooperation) in 2014, the results of the second cycle (Preventive measures and Asset recovery) are not available yet [1]. The first cycle findings show that Serbia has predominantly complied with the UNCAC provisions in terms of the basic legal and institutional framework; however, there are still certain aspects to be further developed and considered [2].
Besides the UNCAC review mechanisms, many other evaluations and reports indicate poor efforts in tackling corruption issues in Serbia. Council of Europe’s anti-corruption body GRECO recently highlighted that Serbia failed to implement all of the recommendations made in 2015, regarding corruption prevention among parliamentarians, judges and prosecutors [3]. The European Commission Progress Report for 2017 points out that Serbia has some level of preparation in fight against corruption; however, progress has been tracked concerning the legislative framework, whereas the problems in implementation remain [4].

Singapore is a signatory to the United Nations Convention against Corruption (UNCAC) Convention [1] and other international anti-corruption instruments (ADB/OECD Anti-Corruption Initiative) and is very active in regional and global cooperation in this area [2]. It is not considered a major arms exporter [3].

Singapore has complied with UNCAC obligations. According to an independent assessment conducted by UNODC, members have noted the country’s efforts in raising awareness and creating a culture of zero tolerance towards corruption through interagency co-operation and co-operation with the private sector to combat corruption [1, 2].

South Africa is both a signatory and a ratified member of both the UNCAC [1] and the OECD Conventions [2].

South Africa has a track record of general compliance with these conventions, particularly that of the OECD Convention. [1] However, certain instances of corruption and vulnerability to bribery have emerged in recent years (2014-2018) [2].

South Korea was the 11th largest exporter of major arms worldwide between 2014 to 2019, according to the Stockholm International Peace Research Institute (SIPRI). [1] South Korea signed the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transaction. The convention was ratified and came into force in 1999. [2] [3] The Act on Combating Bribery of Foreign Public Officials in International Business Transactions was passed by the South Korean National Assembly and was implemented in 1999 in accordance with the ratification. [4]

The 44-country OECD Working Group on Bribery, which completed its Phase 4 evaluation of Korea’s implementation of its Convention, argues that “South Korea must enhance detection and reinforce sanctions to boost foreign bribery enforcement”. According to the report, enforcement of its foreign bribery law has weakened since 2011 and “the enforcement rate does not correspond to the significant level of exports and outward investment by South Korean companies in countries and sectors at high risk for corruption”. [1] The report also focuses on positive aspects of South Korea’s anti-bribery legal framework, which contains legislation closing the loophole regarding bribes given to third-party beneficiaries, as well as interventions for whistleblower reporting and protection. [2] [3] [4]

South Sudan ratified UNCAC in 2015. [1] It is not an arms exporter as no manufacturing of any type takes place in the country. It imports its weapons from abroad and is not a member of the OECD.

South Sudan’s dedication to fighting corruption is non-existent and there is no sign that it complies with the requirements of UNCAC in an effective manner. Such measures include effective preventive measures against various forms of corruption. [1] It has consistently ranked on the lowest rungs of the Transparency International corruption index since independence. The data can be accessed on the Transparency International webpage for South Sudan. [2] State institutions that are supposed to offer accountability have been effectively stymied in various ways: the appointment of cronies to head these institutions, allowing conflicting legislation to exist on the law books, and starving these institutions of the funds required for their operations. [3] Corruption is rampant and at the highest level of the government. Investigations by the USA-based Sentry investigative team show egregious corruption that points to the highest office of the land. [4] The constitution stipulates an annual auditing of government business and the public release of audit reports. However, since 2008, audit reports have not been released to the public, for obvious reasons: they show corruption at the top-level of government. The audit reports on the auditor chamber’s website are for pre-independent South Sudan. In other words, since the country became independent, the public has not seen an audit of government finances.

The Anti-corruption Commission is largely toothless, its head an appointee of the president. In cases where it has completed investigations and handed them over to the Ministry of justice for prosecution, the result has been the burying of these reports. [3] There is no whistle-blower protection and as such public servants angered by the corruption leak documents to the various social media groupings of the South Sudanese, especially WhatsApp groups. Not a month goes by without a document showing significant corruption being leaked to the public on these groups. [5]

Spain has signed and ratified both the United Nations Convention against Corruption (UNCAC) [1] and the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials in International Business Transactions [2]. The country is a significant defence exporter, the 7th in the Stockholm International Peace Research Institute (SIPRI) world ranking of arms exporters for 2019 [3], the last document entered into force in 2000.

The last report from OECD Convention on Combating Bribery about Spain is from 2015, the Working Group Report highlights that just a few recommendations have been fully implemented by Spain, showing strong concerns about the Spanish government response, because Spain fully implemented only four recommendations, ten were partially implemented, and 21 were not implemented [1]. In particular, the OECD underlined the low level of foreign bribery enforcement in Spain; that the country has not taken steps to ensure that bribery-related accounting offences are effectively investigated and prosecuted, and note some technical deficiencies in Spain’s Penal Code. Its modification in 2015 does not include political or public bribery [2].

Sudan is ostensibly not a significant defence exporter, compared to all other countries around the world. It signed on to the UN Convention Against Corruption (UNCAC) on January 14, 2005, and ratified it on September 5, 2014 [1]. However, it should be noted that Sudan is considered to be a significant defence exporter to other African countries. In a phone interview, an expert on Sudan’s defence sector said, in reference to the Small Arms Survey and Conflict Armament Research organisations, that Sudan is the third biggest arms exporter in Africa, but nearly all of the transactions are completed through informal (non-official) channels, in which components of Sudan’s defence forces are the primary partners in defence sector deals. ‘There is a lot of corruption in this export business. None of that is even talked about right now. Even civil society is not talking about it… They are all adaptations of Chinese, Russian and Iranian weapons, and Sudan makes some fix wing aircraft, Armoured Personnel Carriers (APC), drones, helicopters, tanks, artillery and armoured boats’ [2].

The above-mentioned expert went on to cast doubt on the sincerity of military leaders, especially Hemedti’s sincere commitment – or lip service – to combatting corruption and other issues that the international community and some Sudanese civil society organisations are insisting must be addressed by the transitional government; the expert emphasised that Hemedti has hired a strategic communications company in Canada to help manage his public image and perceptions of his actions, noting that Hemedti’s forces even have an office for children’s rights, women’s rights and human rights, ‘which are of course propaganda offices, and they recruit people who are not from the tribe or clan, who are real human rights workers – and who have credibility – to speak on his behalf. Even Hemedti will do an anti-corruption unit if he needs to’ [2]. Sudan is not a signatory to the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials in International Business Transactions.

Sudan has largely failed to comply with its obligations under the UNCAC, especially within its security sector. A formal anti-corruption law was approved in 2016 and former President Bashir established an anti-corruption commission. However, as summarised by a 2020 CIPE report, ‘[I]t soon became clear that the main motive behind these measures was burnishing Al-Bashir’s image before the international community… Al-Bashir’s commission failed to make any significant changes and did not present a single criminal case for prosecution’ [1]. Sudan’s Constitutional Declaration established the ‘Empowerment Elimination, Anti-Corruption and Funds Recovery Committee’ to ‘disempower’ beneficiaries of corruption during former President Bashir’s tenure, but these largely politically motivated efforts have so far almost entirely avoided targeting military officials and military elements that are still active in the new government. As of October 2020, an independent anti-corruption commission had not yet been formed [1]. There is no evidence that codes of conduct have been developed or that public servants or military personnel have been required to agree to follow such codes. Complaints of unethical behavior by public sector personnel can be submitted to an Ombudsman, but no such independent watchdog appears to have the authority to investigate complaints in the security sector. Despite the guidance in the Procurement Act of 2010, public procurement activities are generally not transparent and the public has little visibility into security sector business [2]. Corruption-related criminal law enforcement is almost never executed with respect to security sector business unless such activity is politically motivated [2]. The extent to which Sudan complies with the International Cooperation and Asset Recovery chapters of the UNCAC is unclear.

Sweden is a significant defence exporter. According to SIPRI data [1], Sweden was the 15th largest defence exporter in the world in 2019. Measured per capita, Sweden tends to be in the global top three, and ranked 1st in 2011 [2]. Sweden has signed up and ratified the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions in 1999 [3]. It then signed the UNCAC in 2003 and ratified it in 2007 [4].

Sweden has until recently seen major issues of compliance with the OECD convention. The OECD Working Group on Bribery has since 2012 repeatedly urged Sweden to reform its laws to enable the investigation and prosecution of companies that bribe foreign public officials to obtain advantages in international business. In October of 2017, OECD released a statement that Sweden’s legal provisions on corporate liability did not meet the requirements set out in the convention. As a result, ‘the [OECD] Working Group is concerned about how effectively Sweden is able to investigate and sanction companies that bribe foreign public officials to obtain advantages in international business, such as foreign government procurement contracts in the building, transportation and information technology sectors’ [1]. This prompted the OECD to release another statement two months later that Sweden’s progress towards combatting foreign bribery was ‘insufficient to warrant Phase 4 evaluation’ [2], thus stalling further implementation of the convention until at least 2019. In June of 2019, a High Level Mission of the OECD Working Group on Bribery travelled to Stockholm to meet with a number of high-level state officials and once again push Sweden to ‘urgently implement reforms to boost fight against foreign bribery’ [3]. Later in 2019, the government proposed an update of three different laws in a bill which was voted through parliament and entered into effect in January 2020 [4]. OECD is yet to proceed with the implementation of the convention and the Phase 4 evaluation.

Switzerland is a major arms exporter and ranked 14th most important exporter for between 2015-2018 [1]. Switzerland signed on to the UN Convention Against Corruption (UNCAC) on 10 December 2003 and ratified it 24 September 2009 [2, 3]. For the OECD Anti-Bribery Convention Switzerland ratified on 31 May 2000, the convention entered into force on 30 July 2000. The implementing legislation for the OECD convention was in force by 1 May 2000 [4].

Switzerland still has some implementation issues when it comes to the OECD Anti-Bribery Convention. Despite its efforts to implement the convention the Phase 4 Report by the OECD Working Group on Bribery in International Business Transactions has found that some of the recommendations from the Phase 3 report in 2011 are still not implemented [1]. Some of the main remaining issues that were included in the recommendations were the lack of legal protection for whistleblowers in the private sector, the effectiveness, proportionality and dissuasiveness of sanctions for foreign bribery, the not sufficiently systematic publication of foreign bribery cases, and the lack of reform of the legislation on mutual legal assistance [2]. The UNCAC Implementation Review Mechanism only completed the first cycle with Switzerland (i.e only articles on criminalization and law enforcement and international cooperation). In general, implementation of the convention seemed satisfying. Some procedural shortcomings were pointed out like the statute of limitations for some transgressions or the requirements for persecuting cases of bribery of foreign officials. At the time of the report, the latter only included acts that are contrary to the duties of the foreign public official [3]. The Department for Foreign Affairs reiterates Switzerland’s commitment to the implantation of UNCAC and highlights initiatives in support of that implementation, namely the Lausanne process on stolen asset recovery [4].

This indicator has been marked ‘Not Applicable as, currently, Taiwan is not a member of the United Nations (UN) or its suborganisations [1]. Based on the “United Nations Convention against Corruption”, Taiwan issued the “Act to Implement United Nations Convention against Corruption” in 2015 [2].

This indicator has been marked ‘Not Applicable as, currently, Taiwan is not a member of the United Nations. Taiwan published the “ROC’s Initial Report under the United Nations Convention against Corruption” on March 30, 2018 [1]. Taiwan held the review meeting for this report, between August 21 and August 24, 2018, with wide-ranging and in-depth discussion with representatives of Taiwan government agencies and NGOs, and five international review committee members in order to advance anti-corruption reforms in Taiwan [2].

Tanzania is not a significant arms exporter. [1] Tanzania ratified the UNCAC in 2005. [2]

The UNODC have highlighted that not all elements of UNCAC have been rolled out in Zanzibar, particularly on asset recovery. [1] They have also noted that only some offences are fully criminalised under Tanzanian law. For example, embezzlement and the attempt to commit an act of corruption are not fully covered by the law. [1]

Thailand is not a significant defence exporter. According to the SIPRI, Thailand exported arms valued about 2,000,000 USD during 2016-2017 [1]. Thailand is a signatory to the United Nations Convention Against Corruption (UNCAC) but not the OECD Anti-Bribery Convention [2]. The country became a signatory to the UNCAC on December 9, 2003 and ratified the UNCAC on March 1, 2011. However, it has yet to enact the full array of domestic laws necessary to fulfill its obligations under the UNCAC, although recent legal developments, for example the anti-corruption law, have pushed Thailand closer to a position of compliance. Moreover, Thailand is not yet a signatory to the OECD Convention, although the National Anti-Corruption Commission (NACC) reports that Thailand has been cooperating with members of the OECD Anti-bribery Convention on international bribery cases [3]. Thailand has also acceded to the ICCPR and is a member of the ADB/OECD Anti-Corruption Initiative for Asia-Pacific [4,5].

Thailand has implemented anti-corruption interventions as part of its obligations under the ratified UNCAC. For instance, it introduced the Organic Act on Counter Corruption (No. 3) B.E. 2558 (2015) on July 10, 2015 [1]. Under the NCPO, the Organic Act on Counter Corruption B.E. 2542 (1999) (OACC), which is Thailand’s primary anti-corruption legislation, has recently been amended. The amendments to anti-corruption legislation have also brought Thailand closer to its international obligations under the UNCAC, which Thailand ratified in 2011 (last updated in 2015) [2,3]. Thailand has cooperated with the review processes required by the UNCAC and is now in its second review [3]. Additionally, the Anti-Money Laundering Act NO.5 (2015) has been amended and a new law has been issued requiring increased transparency in licensing [4].

Tunisia is not a significant defence exporter (1). Tunisia signed the UNCAC on 30 March 2004 and ratified it on 23 September 2008 (2)

There are shortcomings in complying with some parts of the Convention. In 2014, 16 gaps were identified by the team responsible for self-assessment of the implementation of the UNCAC in Tunisia, including the non-criminalisation of corruption in the private sector and the non-protection of whistleblowers. A civil society shadow report confirmed the 16 gaps and added specific recommendations to address the weak areas in the legal framework (1). Since then, multiple laws have been adopted to remedy these gaps: protection of whistleblowers (2), declaration of gains and interests and illicit enrichment (3), and access to information (4). However, some gaps persist, such as the non-criminalization of corruption in the private sector.

In the period 2016-2020, Turkey was the thirteenth largest exporter of major arms in the world as according to SIPRI [1].Turkey signed the United Nations Convention against Corruption (UNCAC) on December 10, 2003, and ratified it on November 9, 2006 [2]. The Convention entered into force for Turkey on May 18, 2006. According to Article 90 of the Constitution of Turkey, international agreements duly put into effect have the force of law. In the event of a conflict between international agreements duly put into effect and domestic laws concerning fundamental rights and freedoms, the provisions of the international agreements shall take precedence. Turkey’s legal system is based on civil law. Judicial decisions, though not legally binding, are strongly adhered to by the courts.

Turkey is a member of the Financial Action Task Force (FATF) [3] and a party to the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the OECD Working Group on Bribery [4]. Turkey ratified the OECD Convention on July 26, 2000, and it entered into force on January 11, 2003 [4]. Turkey has been assessed on its implementation of the OECD Convention, as well as by the Group of States against Corruption (GRECO) [5] and the Financial Action Task Force (FATF) [3].

The most recent UNCAC Compliance Review for Turkey was published in 2015 [1] and not a single report/review has been published since the beginning of the presidential system. According to the 2015 review, Turkey has not made its self-assessment checklist public nor consulted with civil society organisations (CSOs) during the review process. Moreover, the country did not respond to Transparency International Turkey’s requests for information. The review also emphasised that Turkish law generally addresses the requirements of the UNCAC. There are elaborate domestic laws in place that are intended to combat corruption but in practice, there are shortcomings, especially regarding judicial enforcement when laws are violated. The review then suggested that, in cases where Turkish domestic laws are compatible with the UNCAC, effective enforcement is in need of improvement as it is indispensable for successfully curbing corruption. Capacity-building initiatives should therefore be undertaken to strengthen the investigation and prosecution capacity of the relevant authorities; coordination between various law enforcement agencies should also be improved.

With regard to the OECD Convention, on March 14, 2019, the OECD issued a warning about Turkey’s continued failure to implement key aspects of the OECD Anti-Bribery Convention and to enforce its foreign bribery laws [2], stating that ‘the Working Group on Bribery will send a high-level mission to Ankara in 2020 unless Turkey takes concrete action by October 2019’. So far, no information has been found through open-source research about the arrival of the OECD Working Group on Bribery in 2020. Please also note that the OECD’s warning is due to the fact that Turkey has not yet enacted legislation to address long-standing recommendations, notably to reform its laws on liability of legal persons for the bribery of foreign public officials.

The warning continues: ‘Turkey’s corporate liability framework does not clearly cover state-owned and state-controlled enterprises, and the prosecution or conviction of a natural person is a necessary basis for sanctioning a legal person. Furthermore, sanctions for legal persons are not sufficiently effective, proportionate and dissuasive. The Working Group also remains seriously concerned about Turkey’s low level of foreign bribery enforcement. Despite the size of the country’s economy and its geopolitical importance, there has not been one foreign bribery conviction in the 16 years since the entry into force of the Convention in Turkey. In addition, the Working Group is highly concerned that foreign bribery investigations and prosecutions may be influenced by considerations of national economic interest, the potential effect upon relations with another State or the identity of the natural or legal persons involved, contrary to Article 5 of the OECD Anti-Bribery Convention’ [2].

Uganda signed and ratified the United Nations Convention Against Corruption (UNCAC) on September 9, 2004. Uganda is not a major defence exporter [1]. Much as the country is a signatory to this convention, the army has allegedly been involved in corruption scandals such as the Auditor General’s Report of 2017 [2] on alleged corruption in the procurement of land at Kashenyi-Entebbe by the Uganda People’s Defence Force (UPDF). As such, Uganda is neither a major arms exporter nor an importer [3].

Though the United Nation Office of Drugs and Crime 2017 Report on the state of implementation of the UNCAC does not specifically address Uganda’s implementation status, some of the highlights of the report indicate that military officers are also public officers and they must comply with anti-corruption systems. As a result, state parties must address bribery, specify penalties and also include asset recovery. In Uganda, there is a lack of transparency by the defence ministry during scrutiny and consideration of the budget because some budget lines are considered classified. This undermines the overall goal of promoting integrity, transparency and accountability in the sector [1]. However, corruption is a major problem in Uganda [2, 3], and the country has put in place some laws and policies such as the Penal Code Act, Prevention of Corruption Act, code of conduct for public officials, and also established anti-corruption bodies such as the office of the Auditor-General, the Inspectorate of Government and Directorate of Public Prosecutions. However, the compliance reports from Transparency International (2007) noted that the government seems to be failing in combating the vice, particularly political and private sector corruption. For instance, In 2016, Ugandans believed the Uganda Police Force was the most corrupt institution, according to a survey carried out by the Uganda Bureau of Statistic (UBOS), a government agency. The UBOS National Service Delivery Survey of 2015 based on 10,101 Ugandan respondents put the police at 75 per cent as far as bribery, fraud and extortion were concerned [4]. The IGG, which by law, is mandated to investigate corruption-related cases named 80 most corrupt institutions in Uganda [5]. The list indicated that the vice is widespread and required concerted efforts to address it. From the above explanations, while many efforts are being made to fight corruption in government, there are still weaknesses in implementing some of these laws largely due to institutionalised corruption in government.

Ukraine is a major arms exporter [1] and has both signed and ratified the UNCAC, which came into force in 2010 [2]. However, Ukraine did not sign or ratify the OECD Convention, the most relevant document in this case [3].

This indicator is scored Not Applicable, as Ukraine is a significant defence exporter and the OECD Convention is the relevant document. It is worth noting that the last UNCAC assessment was carried out in 2012 [1] before the events of 2014, that is why its findings cannot be seen as representative. Since 2014 Ukraine has made significant progress in anti-corruption, it created new anti-corruption bodies, adopted a new law on the prevention of corruption, declared its intention to create an anti-corruption court and is about to start the State Bureau for Investigations [2]. Although the created anti-corruption infrastructure started functioning and has produced positive results [3], there are some gaps both in legislation and in state authorities’ activities which limit the positive effect of the recent anticorruption reforms.

The UAE is a signatory to the United Nations Convention against Corruption, the United Nations Convention against Transnational Organised Crime, and the Arab Anti-Corruption Convention, but is not a signatory to the OECD (1). The UAE is considered a major arms exporter, as well as a second-hand exporter of arms, as weapons purchased by the UAE are shipped to Yemen and Libya. The UAE has also become the third-largest weapons importer in the world. Most of these imports are from the United States, followed by France, Russia, Italy, and Sweden (2). The UAE signed the UNCAC on August 10, 2005, and ratified it on February 22, 2006. The UAE’s ratification, however, came with reservations on articles related to arbitration. Even though the country has signed up to the UNCAC, it has not ratified all the relevant instruments within the convention.

This indicator is marked Not Applicable because the UAE has not ratified the OECD Convention, which is the relevant instrument in this case, considering the UAE’s status as a significant defence exporter.

The UK is a significant defence exporter and it has signed and ratified the OECD Convention, as well as the UNCAC [1, 2].

In March 2019, the United Kingdom (UK) presented its written follow-up report to the OECD Working Group on Bribery (Working Group), outlining the steps taken to implement the recommendations received and to address the follow-up issues identified during the previous evaluation in March 2017. In light of the information provided, the Working Group considered that the UK has fully implemented 16 recommendations, partially implemented 18 recommendations, and not implemented 10 recommendations [1]. Furthermore, the Working Group concludes that ‘despite an increased level of enforcement of foreign bribery laws, the total number of finalised and ongoing cases relative to the UK economy remains relatively low’ [1]. A recent Transparency International report which assesses enforcement of the OECD Anti-Bribery Convention has rated the UK as an ‘active enforcer’ of anti-bribery legislation [2].

Additionally, as a signatory to the Council of Europe Criminal Law Convention on Corruption, the UK is subject to evaluation by the Group of States against Corruption (GRECO) and the Committee of Experts on the Evaluation of Anti Money Laundering Measures and the Financing of Terrorism (MONEYVAL). In 2021, GRECO’s latest evaluation report on the UK’s progress towards implementing recommendations towards ‘preventing corruption and promoting integrity in central governments and law enforcement agencies’, found that five of the twelve recommendations were implemented satisfactorily, four partly, wjile three are yet to be addressed [3]. The report concludes that ‘further progress is necessary to demonstrate an acceptable level of compliance with recommendations’ over the next 18 months [3].

The United States signed and ratified the UNCAC Convention (in December 2003 and October 2006 respectively) [1]. The US is a significant defence exporter and has both signed and ratified the OCED Convention (in December 1998 and February 1999 respectively) [2].

According to the Review of the Implementation of UNCAC in 2012 [1], the US has significantly strengthened its overall anti-corruption measures. Only a few minor recommendations were noted and no issues were raised with compliance.

With regard to the OCED Convention, the US phase 4 peer review will be taking place in December 2019 [2]. The most recent monitoring report is therefore from 2012, which stated that the US had fully implemented most recommendations and had three further recommendations to implement [3]. 

Venezuela signed the United Nations Convention against Corruption in 2003 and ratified it in 2005. Given that the country does not export weapons or defence equipment [1] is not part of the OECD Convention. Since signing, Venezuela has received evaluations from the Implementation Review Group subsidiary to the United Nations Convention against Corruption. Results of the latest review were published in 2016 [2].

The latest evaluation of the implementation of the United Nations Convention against Corruption highlighted some of the advances that have been made in terms of the adoption of legislation criminalising offences like bribery of public officials, the maintenance of procedures for public procurement, and the enactment of the Anti-Corruption Law (LCC) and the Organic Law against Organised Crime and Funding of Terrorism [1]. However, problems in the effective implementation of such legislation prevent confirmation of an adequate implementation of the Convention.

Venezuela has not approved a law allowing improved processes for accessing public information, nor is there any intention on the part of government entities to guarantee the constitutional right allowing citizens access to this kind of information [2]. Even regulatory bodies such as the CGR and internal comptrollers such as the Comptroller General of the FANB (CONGEFANB) do not make their reports public.

Likewise, regarding the criminalisation of offences, the 2014 Anti-Corruption Law [3] does not detail different forms of bribery, nor does it address influence-pedding and other behavior associated with conflicts of interest. Although in 2016 the National Assembly approved a reform of the law, strengthening the penalisation of this criminal conduct [4], the law has not been implemented by public authorities or the judiciary.

Zimbabwe is not a significant defence exporter. Zimbabwe signed the United Nations Convention against Corruption (UNCAC) Convention on 20 February 2004 and ratified it on 8 March 2007. UNCAC entered in force for Zimbabwe on 7 April 2007.

Zimbabwe has complied with a number of the articles in the UNCAC provisions in the legislative framework of Zimbabwe addressing certain aspects of the UNCAC [1]. Though, in practice, enforcement remains poor, particularly when it relates to prosecuting corruption cases involving high-profile politically connected individuals [1, 2]. There has been progress with the development of the National Anti-Corruption Strategy (NACS), which was set to be launched in 2020. The NACS covers key aspects of the UNCAC, such as protection of whistle-blowers and victims of corruption, recovery of assets and proceeds from corruption crimes, and compensating damages inflicted on Zimbabwe and corruption victims (individuals or institutions) [3].