Countries where bribes were paid have become the primary drivers of major cross-border bribery enforcement, according to a new OECD report that documents nearly two decades of coordinated multinational prosecutions.

The shift in enforcement follows the 2008 Siemens foreign-bribery case, which resulted in the first coordinated multi-jurisdictional settlement for corporate bribery and an aggregate $1.6 billion in monetary penalties for the company. At the time of the Siemens settlement, approximately 70 percent of all foreign-bribery cases were settled by the “supply-side” country from which the bribe payments originated, the OECD said. 

Since 2019, over 85 percent of major cases have involved at least one demand-side enforcing country actively participating in the resolution, typically recovering funds for state entities harmed by the underlying corruption, the intergovernmental group said. 

The OECD’s report, “Sanctioning Foreign Bribery Through Multijurisdictional Resolutions,” analyzes 31 cases and 114 distinct resolutions across 12 countries between December 2008 and March 2026, covering landmark cases including Odebrecht, Airbus, and Goldman Sachs. Total sanctions and confiscation across the dataset reached an estimated $33.7 billion in constant 2024 dollars, or an average of roughly $992 million per case.

Brazil has been the most active demand-side participant, appearing in 17 of 31 cases and receiving an estimated 27 percent of total recovered funds, second only to the United States, which participated in all 31 cases but took a smaller-than-expected 30.6 percent share, reflecting deliberate penalty-crediting arrangements that route funds toward affected countries. 

In the SAP and McKinsey cases, both resolved in 2024, companies repaid tainted revenues directly to South African state-owned enterprises, illustrating how restitution mechanisms are increasingly central to resolution architecture. Compensation or restitution featured in 68 percent of all cases reviewed, according to the report. 

Nearly all of the resolutions were concluded without trial, through deferred prosecution agreements, non-prosecution agreements, leniency agreements, or administrative settlements. The OECD found that the availability of such mechanisms has become a threshold condition for participation: countries lacking them risk being cut out of coordinated cases entirely. 

The report recommends that more jurisdictions adopt flexible non-trial resolution frameworks, engage potential enforcement partners early, and make greater use of penalty-crediting arrangements to avoid duplicative sanctions. Singapore’s formal court approval of its first deferred prosecution agreement in April 2026, just after the report’s data cutoff, was cited as a sign of continued expansion in countries equipped to participate.