U.S. companies seeking new business opportunities abroad, which can help create jobs at home, need bright lines and clear standards to help them administer anti-corruption programs in foreign business operations and in connection with new acquisitions abroad. But today those lines are blurry, and enforcement standards are set too often on a

case-by-case basis. That creates an environment where companies face the twin uncertainties of trying to prudently manage their anti-corruption risks without knowing with sufficient clarity what conduct U.S. enforcement authorities may rule runs afoul of the law and warrants sanctions.