The Bundling of Foreign Bribery Cases

21 Pages Posted: 7 Apr 2018

See all articles by Branislav Hock

Branislav Hock

University of Portsmouth; Tilburg Law and Economics Center (TILEC)

Date Written: April 6, 2018


This article is the first that discusses how national enforcement authorities have been using bundling, meaning tying or rolling up a number of things together, to settle with corporations over multiple bribery allegations. These settlements rely on some allegedly illegal acts that defendants would likely reject to settle if they were to decide on them separately. In this context, our understanding of what constitutes and should constitute a foreign bribery case is limited. The article shows that anti-bribery bundling is part of a broad trend that allows, in some cases, the United States (US) enforcement authorities to enforce foreign anti-bribery laws extraterritorially. This trend is illustrated on cases in which the US enforcement authorities punished companies headquartered in Europe for their operations outside the US. The article concludes with a discussion of the significant implications the extraterritoriality of bundling has for foreign anti-bribery law theory and policy.

Keywords: extraterritoriality, bundling, foreign bribery, corruption, enforcement, settlement, case

JEL Classification: K00, K14, K20, K33, K42

Suggested Citation

Hock, Branislav and Hock, Branislav, The Bundling of Foreign Bribery Cases (April 6, 2018). TILEC Discussion Paper No. 2018-012, Available at SSRN: or

Branislav Hock (Contact Author)

Tilburg Law and Economics Center (TILEC) ( email )

Warandelaan 2
Tilburg, 5000 LE

University of Portsmouth ( email )

Hampshire PO1 2UP
United Kingdom

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