Episode 441 — Severin Wirz on his New Book, “Bribery Beyond Borders: A History of the FCPA”

On the Corruption, Crime and Compliance podcast, host Mike interviews Severin Wirtz, an in-house compliance lawyer (now at a semiconductor company, formerly at Trace International and a law firm where he cut his teeth on the Bonny Island FCPA case) about his new book, Bribery Beyond Borders, a history of the Foreign Corrupt Practices Act that took him nearly fifteen years to research and write. Wirtz argues the FCPA is usually reduced to a footnote of Watergate, when in fact it emerged from decades of prior anti-bribery legal tradition, Cold War fears that corrupt American multinationals (like ITT in Chile) were undermining democracy and fueling Soviet propaganda, and a narrow, contingent political path through Congress — driven by figures like Senator Frank Church, SEC enforcement chief Stanley Sporkin (who leaked findings to Congress after being blocked by Kissinger’s State Department), and later William Proxmire, with Ford and even Carter only lukewarm supporters until the “Watergate babies” swept into Congress. The conversation moves to today’s landscape: the Trump administration’s 2025 pause on FCPA enforcement, the DOJ’s new “national interest” enforcement standard, debate over prosecuting foreign officials who receive bribes (Wirtz is wary of the precedent), the emerging cartel-linked corruption cases like the Mexican Vitol/Scolar-type matter, and Wirtz’s view that the statute is at an “inflection point” moving from a post-Cold War globalist rationale toward a new argument centered on fair competition and America’s geopolitical brand versus China. Both agree corruption concerns are cyclical and likely to resurface domestically before circling back to FCPA enforcement. The book is available through Corporate Compliance Insights (publisher) and major retailers.

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