Bribery Beyond Borders
The Story of the Foreign Corrupt Practices Act
How scandal, courage, and world politics redefined corporate ethics—and what the origins of a 1977 law reveal about our ongoing fight against corruption today
By Severin Wirz | 2025
Bribery Beyond Borders
The Story of the Foreign Corrupt Practices Act
How scandal, courage, and world politics redefined corporate ethics—and what the origins of a 1977 law reveal about our ongoing fight against corruption today
By Severin Wirz | 2025
Nearly half a century after its passage, the Foreign Corrupt Practices Act stands at a crossroads with its moral authority questioned and its global influence uncertain.
Bribery Beyond Borders tells the remarkable true story of how the United States became the first nation to criminalize corporate bribery outside its boundaries. Drawing on more than a decade of archival research and in-depth interviews with the journalists, lawmakers, and whistleblowers who made history, Severin Wirz plumbs the depths behind the world’s first global anticorruption law.
Amid the ongoing reshaping of the FCPA and with America’s own commitment to integrity under strain both at home and abroad, this highly detailed narrative reminds readers how an improbable coalition of idealists once turned scandal into statute—and how their vision still animates the global fight against corruption today.
Nearly half a century after its passage, the Foreign Corrupt Practices Act stands at a crossroads with its moral authority questioned and its global influence uncertain.
Bribery Beyond Borders tells the remarkable true story of how the United States became the first nation to criminalize corporate bribery outside its boundaries. Drawing on more than a decade of archival research and in-depth interviews with the journalists, lawmakers, and whistleblowers who made history, Severin Wirz plumbs the depths behind the world’s first global anticorruption law.
Amid the ongoing reshaping of the FCPA and with America’s own commitment to integrity under strain both at home and abroad, this highly detailed narrative reminds readers how an improbable coalition of idealists once turned scandal into statute—and how their vision still animates the global fight against corruption today.
About the author
Severin Wirz is an attorney specializing in U.S. and international anticorruption law. His career spans grassroots advocacy and high-stakes investigations—from advancing collective action initiatives with nonprofit organizations in East Africa to guiding Fortune 100 companies through complex cross-border enforcement matters. He currently serves as Director of Ethics & Compliance at Applied Materials, a leading semiconductor equipment manufacturer based in Silicon Valley. Previously, he was Senior Director of Anti-Corruption Compliance at TIAA, where he led global antibribery efforts across the financial services enterprise.
Severin is a frequent contributor to the field, with published articles on anticorruption compliance and editorial roles in key reference works, including Practicing Under the U.S. Anti-Corruption Laws and the series How to Pay a Bribe: Thinking Like a Criminal to Thwart Bribery Schemes.
Advance praise for Severin Wirz and Bribery Beyond Borders
“The story of the most important U.S. law against corporate corruption reads like a mystery, with suicides and with dirty cash spilling into the coffers of foreign leaders. Never before has the history of the FCPA been told in such detail and with such verve.” —Frank Vogl, author of Waging War on Corruption and The Enablers
“Severin Wirz has produced an exhaustively researched history of U.S. anticorruption law packaged as a thriller. Tracing long-standing concerns in U.S. history about domestic and foreign corruption as well as countervailing concerns about regulatory overreach, he provides an invaluable resource for anyone interested in reimagining the global anticorruption regime.” —Kevin E. Davis, Beller Family Professor of Business Law, NYU Law
“In a world in which corrupt government remains a gargantuan problem, Severin Wirz explores the origins of America’s legal quest to stop it in an absorbing and grippingly told story. Coupling his excavation of the progressive origins of the Foreign Corrupt Practices Act with a call for a pluralistic approach now, Wirz’s investigation of the past is indispensable for reformers present and future.” —Samuel Moyn, Kent Professor of Law and History, Yale Law School
“A meticulously researched and eminently readable history of the U.S. struggle to combat corporate bribery and corruption overseas. Featuring larger-than-life politicians and their rivalries, innovative civil servants, falling foreign governments, suicides, fixers, and schemes to hide and disguise illicit payments, Severin Wirz’s Bribery Beyond Borders reads more like a thriller than a legislative history. A must-read for anyone interested in corporate governance, compliance, and international business.” —Lucinda Low, Board Chair of the Coalition for Integrity and former President of the American Society of International Law
“This couldn’t be a timelier and more important reminder of the significance of the crown jewel of the U.S. anticorruption framework: the Foreign Corrupt Practices Act. If past is prologue, this engaging and meticulously detailed story provides a clear warning of the dangers of returning to a world before rules existed to rein in the worst impulses of the unethical when partnering with the corrupt.” —Gary Kalman, Executive Director of Transparency International U.S.
“Severin Wirz has produced a timely and deeply researched history of the Foreign Corrupt Practices Act. As the global anticorruption landscape shifts, Bribery Beyond Borders lays a historical foundation for thinking critically about the statute’s next chapter. The book’s insights into the FCPA’s origins provide a crucial perspective on current debates over the future of transnational anticorruption enforcement.” —Jessica Tillipman, Associate Dean, The George Washington University Law School
A brief history of the FCPA
Credit: Roger Wollstadt, Creative Commons license (https://creativecommons.org/licenses/by-sa/2.0/)
Eli Black, chairman of the board of United Brands, commits suicide, prompting an investigation by the SEC.
US Sen. Frank Church (D-Idaho) writes an enraged letter to Foreign Relations Committee Chair John Sparkman (D-Ala.) in response to reports that Church’s Subcommittee on Multinational Corporations will be defunded and liquidated by year’s end.
As an outgrowth of the Watergate investigation, the SEC files a civil injunctive suit against Gulf Oil Corp. regarding improper campaign contributions to President Richard M. Nixon — one of many such suits brought by the SEC at the time. Although the SEC also uncovers overseas payments, those are not mentioned in the SEC’s suit. (SEC v. Gulf Oil Corp., Civ. Action No. 75-0324, D.D.C., filed March 11,1975)
The final remaining American troops exit Vietnam, marking the fall of Saigon. The Subcommittee on Multinational Corporations votes unanimously to pursue a full investigation into overseas bribery by US corporations.
US Rep. Stephen Solarz (D-NY) introduces H.R. 7563 and H.R. 7539, the first bills to emerge in direct response to new foreign bribery allegations.
The Subcommittee on Multinational Corporations begins public hearings into Northrop. The company’s CEO, Thomas V. Jones, concedes that Northrop modeled its corruption methods on those established by Lockheed.
The Helsinki Accords are signed by 35 nations. Though non-binding and lacking treaty status, the accords represent an attempt to improve relations between the Communist bloc and the West.
Sen. Frank Church writes to Sen. William Proxmire (D-Wis.) in what would eventually be a failed effort to draw dividing lines in the Senate’s investigation of foreign bribery.
Secretary of State Henry Kissinger asks Attorney General Edward Levi to secure a protective order against the disclosure of the names of people who received bribe payments from Lockheed. That letter is later leaked to the press and ultimately backfires against Lockheed.
New York Times reporting discloses that a source in Washington has identified the recipient of $1.1 million bribe paid by Lockheed as Prince Bernhard of the Netherlands.
CEO Daniel Haughton and COO Carl Kotchian are both forced to resign from Lockheed.
Sen. Frank Church announces his late run for president.
Right-wing dissident Mitsuyo Maeno goes on a kamikaze mission and crashes a small plane into the home of Lockheed’s secret agent in Japan, Yoshio Kodama.
President Gerald Ford establishes the Task Force on Questionable Payments Abroad and names Secretary of Commerce Elliot Richardson as head.
Leading Liberal Democratic Party politician and former Prime Minister Kakuei Tanaka is arrested in Japan, making global headlines and sending shockwaves throughout the Japanese political system.
The Netherlands’ Donner Commission publishes a 240-page report detailing illicit dealings between Prince Bernhard and Lockheed. The reports sells out immediately amid calls for Queen Juliana’s abdication of the throne.
Jimmy Carter is inaugurated as the 39th president of the United States. Democrats now enjoy overwhelming power in both the legislative and executive branches of government.
The Senate passes the FCPA by a unanimous voice vote. Carter, in his first trip overseas, attends an economic summit in London and makes a statement noting his commitment to finding a multilateral solution to foreign bribery problem.
