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The Organization for Economic Cooperation and Development (OECD) Convention is an unusual international agreement in that it seeks to coordinate disparate legal and ethical systems in order to arrive at a minimum standard with respect to an important form of white collar crime. It obliges signatory countries, which now include all 30 OECD member countries plus a growing number of non-members, to make the bribery, corruption, extortion, and/or insiders trading of a foreign public official a crime under their laws. Why is this such a difficult policy to implement?

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