Clickbait Compliance and Transnational Corruption

69 Pages Posted: 27 Mar 2022

See all articles by William R. Heaston

William R. Heaston

University of Pennsylvania, The Wharton School

Date Written: March 25, 2022


In the corporate compliance and anti-corruption domains, international standard-setting is in vogue. Recent years have witnessed a flurry of new compliance standards authored by the International Organization for Standardization (ISO), the world’s leading private standard-setter. ISO claims to offer a more effective way to address transnational corruption risks and related compliance challenges, one that boasts the approval of a global committee of putative experts and enticingly purports to accord with international “best practices.” And companies and governments around the world are increasingly taking the bait, with many adopting ISO’s anti-bribery standard (ISO 37001) in particular.

This Article argues that, despite their theoretical allure, this nascent wave of international compliance standards is fraught with pitfalls that call into question their practical utility. Essentially, companies and governments that adopt the standards are buying into a kind of clickbait compliance, which overpromises and is likely to underdeliver in many respects. First, a conceptual analysis of ISO 37001 illustrates that such standards are unlikely to function as anticipated (“clickbait functionality”). Second, an examination of ISO’s growing presence in the burgeoning field of compliance reveals that apparent synergies between the organization’s new standards and compliance laws, practices, and trends are unlikely to materialize (“clickbait connections”). The Article concludes by discussing how ISO’s disjointed and siloed organizational system exacerbates these issues before proposing reforms that would promote a more evidence-based approach to ISO compliance, an approach that may curtail—but will certainly not eliminate—clickbait concerns.

Keywords: Corporate Compliance, Anti-Bribery, International Standards, International Organization for Standardization, ISO 37001

Suggested Citation

Heaston, William R., Clickbait Compliance and Transnational Corruption (March 25, 2022). University of Dayton Law Review, Forthcoming, Available at SSRN: or

William R. Heaston (Contact Author)

University of Pennsylvania, The Wharton School ( email )

3641 Locust Walk
Philadelphia, PA 19104
United States

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