21.2

Winter

2021

The author wishes to thank her family for their unending love, support, and encouragement, her advisor, Professor Adam Chilton, for his helpful suggestions, and the entire board and staff of the Chicago Journal of International Law for their valuable comments and thorough review.

I would like to extend my gratitude to Professor Aziz Huq for his guidance and to the CJIL Board and Staff for their support. I would also like to thank my family, Veronica Patterson, and Conor McGannon for their encouragement in pursuing this topic.

For their encouraging, thoughtful, and instructive feedback on previous drafts of this article, the author would like to extend sincere thanks to Professor Michael Schmitt, Professor Richard Barnes, Professor Hitoshi Nasu, Professor Mike Williams, Professor Helena Wray, Dr. Edwin Egede, and Professor Andrea Lista. He would further like to thank his master’s degree mentor of many moons ago, Professor Craig Barker, for originally piquing his interest in transnational law and for inspiring him to continue academic research.

I am grateful to Professor Matthew Stephenson, Phil Mason OBE, Branislav Hock, William Thomas, Jordan English, Ashrutha Rai, Sagnik Das, and the participants of Harvard Law School’s 2019 Global Anti-Corruption Lab for their thoughts and feedback on this Article. I am indebted to Zach Heater, Jared Mayer, Neema Hakim, Daniel Sung, Keila Mayberry, Maria O’Keeffe, and the editorial team of the Chicago Journal of International Law for their assistance in the preparation of this Article. An earlier version of this Article was presented at the OECD 2019 Anti-Corruption & Integrity Forum, and I am grateful to those attendees who provided comments and suggestions, including the prosecutors from anti-corruption enforcement agencies in the U.S. and U.K. who provided insight, counterargument, and criticism. The views and opinions expressed in this Article are mine alone, as are any errors.

An earlier version of this Article was presented at the 4th Annual Conference of the Global Business and Human Rights Scholars Association at New York University in September 2018; at a faculty seminar at the University of Connecticut in February 2019; and at the Innovate Rights Conference at the University of New South Wales in May 2019. The current draft was presented at the Academy of Legal Studies in Business Conference in August 2020. The authors are grateful to Justine Nolan, Shareen Hertel, Stephen Park, and Onyeka Osuji for their helpful comments, and to Gianni Garyfallos for his research assistance.

The author is grateful to Bruce Burson, Geoffrey Cantor, Jean-François Durieux, Walter Kälin, Ana Luquerna, and Atle Solberg for their useful comments on earlier drafts of this Article. The views expressed in the Article, and any errors that it contains, remain those of the author alone. The research on which the Article builds was generously supported by Economic and Social Research Council [grant number ES/K001051/1].