Reed Smith Client Alerts

Authors: Thomas H. Suddath

On January 27, 2016, Transparency International released its 2015 update to its annual “Corruption Perceptions Index” (“CPI”), a vital resource for corporate anti-corruption compliance efforts. The 2015 CPI rates 168 countries and territories around the globe based on expert opinions of public sector corruption. The 2015 CPI is found at

Companies with risk-based anti-bribery compliance programs should use the 2015 CPI to determine where their international operations are at heightened risk for violating foreign anti-corruption laws, such as the U.S. Foreign Corrupt Practices Act (“FCPA”) or the UK Bribery Act. Their compliance and due diligence resources should then be deployed in a way that strategically addresses identified “red flags” for potential corruption.

While the CPI’s focus is limited to geographic corruption risks – it for instance does not factor the increased corruption risks that certain industries carry regardless of location – it is nevertheless recognized by anti-corruption professionals and regulators as a reliable benchmark for anti-bribery compliance.

The 2015 CPI’s map remains weighted toward shades of red, meaning that the majority of the world’s countries are perceived as having a high incidence of corruption.  Indeed, two-thirds of the 168 countries on the 2015 index scored below 50, on a scale from 0 (perceived to be highly corrupt) to 100 (perceived to be very clean). Those low scores are concentrated in Africa, Latin and South America, Asia, and the Middle East.

Brazil, Russia, India and China remain colored a high-risk red, with Brazil experiencing the greatest decline of all countries in the 2015 CPI rankings – dropping seven positions to a rank of 76, tied with India – due to the recent scandal involving the semi-public oil and gas company Petrobras, in which more than 35 people were indicted on corruption, money laundering and racketeering involving an estimated US$3.9 billion.

Markets that are slowly opening to the West, such as Cuba (score of 47, rank of 56) and Iran (score of 27, rank of 130), are perceived as corruption risks. Companies looking to do business in these countries should do so with a keen eye toward identifying corruption-related risks.

Swaths of yellow – representing countries perceived as having relatively “clean” governments – are found in the United States, Canada, Western Europe (except Italy), the United Arab Emirates, Japan, Korea, Singapore, Hong Kong, Australia, New Zealand, Chile, and Uruguay. Even these relatively low-risk countries still carry some risk for corruption – indeed, the 2015 CPI’s top-ranked country, Denmark, scored 91 out of 100, one point lower than the Danish score in 2014.

Transparency International praised the four-year upward trends for Greece, Senegal and the United Kingdom, while citing Libya, Australia, Brazil, Spain and Turkey for significant declines over that period.

Contact any of Reed Smith’s Government Investigations & White Collar Criminal Defense attorneys for additional guidance regarding the 2015 CPI, anti-corruption compliance and due diligence, or other issues about the FCPA, UK Bribery Act or other anti-bribery laws.


Client Alert 2016-032