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

I'm Alexandra Rogge.

We have great guests today, both of whom have been on the podcast previously.

We're talking about the OECD Working Group and its recent phase four evaluation of the United States

implementation of the OECD Anti-Bribery Convention with Nicola Benucci and Nat Edmonds.

Nicola will be known to most of you as the former director for legal affairs at the OECD,

and last year he joined Paul Hastings as managing director, Investigations and Compliance based in their Paris office.

Nat Edmund spent 10 years as a white-collar prosecutor,

culminating in a stretch as the assistant chief of the FCPA unit

in the fraud section of the U.S. DOJ's criminal division.

He's now a partner with Paul Hastings and chair of the firm's litigation

practice in their Washington office. Nat, Nicola, thank you for joining me.

Pleasure. Pleasure. Why don't we start with an overview of the OECD Working Group?

Nicola, can you just take us through the work of the OECD Working Group, what they do, and particularly

how they review and monitor the effectiveness country by country?

The OECD Working Group is the body which looks at the implementation of the Convention,

groups representative of all the 44 countries which are parties to the convention.

This includes all the OECD countries and seven non-members.

It is the key body in terms of implementation of the convention.

In two ways, the first one is looking at the legislation of the countries

and making, let's say, strong suggestions,

even more than strong suggestions about the need of amendment and even in some cases of new

...