Welcome back to the podcast, bribes, swindle, or steel.

I'm Alexandra Rogge, and today I'm speaking with James Klotz.

James is partner with Trace's partner firm in Toronto, Miller Thompson, LLP, where he oversees

the firm's anti-corruption and international governance group.

He's also a past chair of Transparency International Canada.

James, thanks so much for joining me.

My pleasure.

There is a general sense that Canada has been pretty sleepy on the anti-bribery enforcement

front.

Do you agree with that?

This is your chance to defend Canada.

Well, clearly, there have not been a lot of prosecutions in Canada, and Canada has been faulted for this in the past by the OECD.

By 2012, we only had one serious prosecution to come out of our law, the Corruption of Foreign Public

Officials Act, since's enactment in 1999.

And that compared with over 100 at the time in Germany and over 200 in the U.S.

But since then, the Canadian government stiffened up the CFPOA, as we call the Act, with amendments,

increasing the penalties, adding in books and records offense, widening the jurisdiction,

and eliminating the exemption for facilitation payments. But that done, Alexandra, Canada has only

produced in total three notable convictions, has only a few known cases in the pipeline, and we don't

actually know how many ongoing investigations there are.

In fact, since the CFPOA's enactment,

Global Affairs Canada has released an annual report

...