Denmark must investigate foreign bribery more proactively


21/03/2013 - Denmark’s enforcement of its foreign bribery laws has been weak. Only 13 foreign bribery allegations have surfaced, and sanctions have been imposed in just one case that falls under the Convention. Law enforcement authorities have not been sufficiently proactive, and cases have been prematurely closed without complete investigations. Denmark must take more investigative steps and make greater efforts to gather evidence from abroad.

The OECD Working Group on Bribery has just completed its report on Denmark’s implementation of the Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and related instruments.

The Group made further recommendations, including to:

  • Review the overall approach to foreign bribery enforcement
  • Raise the maximum penalties for foreign bribery and false accounting
  • Clarify the defence of small facilitation payments and discourage companies from making such payments
  • Better protect whistleblowers in the public and private sectors
  • Promptly extend the Convention to Greenland and the Faroe Islands

The report also highlights positive aspects of Denmark’s efforts to fight foreign bribery. These include increases in suspicious money laundering transaction reports; sanctions imposed for failure to report such transactions; mechanisms to obtain tax and bank information; and efforts to raise awareness and to promote corporate social responsibility.


The Working Group on Bribery – made up of the 34 OECD Member countries plus Argentina, Brazil, Bulgaria, Colombia, Russia and South Africa – adopted Denmark’s report in its third phase of monitoring implementation of the OECD Anti-Bribery Convention.


The Report, available at, lists all of the recommendations of the Working Group to Denmark on pages 50-54, and includes an overview of recent enforcement actions and specific legal, policy and institutional features of Denmark’s framework for fighting foreign bribery. As with other Working Group members, Denmark will submit a written report to the Working Group within two years on steps it has taken to implement the new recommendations. This report will also be made publicly available.


For further information, journalists are invited to contact Mary Crane-Charef, OECD Anti-Corruption Division Communications Coordinator, e-mail; (33) 1 45 24 97 04.

For more information on OECD’s work to fight corruption, please visit


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