Beyond the lag. How to predict and understand evolutions towards good governance?

This paper tries to forecast good governance evolutions by drawing on the time trends of Index of Public Integrity’s sub-components1. Previous work has showed these to be powerful determinants of control of corruption: judicial independence, freedom of the press, administrative burden, trade openness, as well as the proxies of budget transparency and e-citizenship are considered. Their de- terminants power proves weaker across time than across countries, as the first sections of this paper shows. Based on their trends, we identify several leaders and backsliders. However, more often than not the progress of countries on some items is offset by regress on others. This makes it difficult to understand country trends based only on quantitative measures. We therefore combine this appro- ach with other elements to produce a pilot forecast:

1. Ten years trends of determinants of corruption/the public integrity framework (components of the Index for Public Integrity, IPI), or their related proxies, when not available.

2. The IPI evolution since 2015

3. Qualitative elements, such as recent windows of opportunity (such as elections won with an anticorruption mandate) and implementation gaps (distance between formal treaties/conventions signed and their implementation)

4. The potential critical mass demanding good governance and its digital empowerment at the present moment (e-citizens), as well as other proxies or good governance demand.

This forecast thus blends numerical and qualitative indicators. N=124 countries for which data was available.

Shifting Anti-Corruption Global Legal Policy: The Case for International Human Rights Law

Corruption is known to undermine democracy, erode the rule of law and hinder human development, inter alia, through the violation of human rights. Yet, recognition of these links has not manged to permeate the international anti-corruption toolkit. Efforts to curb corruption have culminated with the enactment of a few international treaties, amongst which the United Nations Convention against Corruption (UNCAC) stands out as the only norm with true global reach. Despite its significant membership, UNCAC has often been described as ‘toothless’ for its faulty implementation worldwide. The model it embraces, primarily based on criminal liability, has not been successful in combatting corruption precisely where it is most aggressive and ingrained. This paper sets out to explore whether a shift in global legal policy from a model anchored in criminal law to another based on international human rights law would be desirable for the anti-corruption agenda of highly corrupt countries. Employing a legal external normative approach and a qualitative review of selected reports, our analysis suggests that an anti-corruption framework based on criminal law is ill-suited for the reality of countries where the rule of law is weak or inexistent. It also indicates that international human rights law provides an adequate theoretical basis for the establishment of a direct link between individuals who are most affected by the consequences of corruption and the international legal order. It further sheds light on how a rights-based approach could potentially address the gaps left by the criminal law model. Finally, it engages in an argumentative effort to conceive an individual claims mechanism rooted on the recognition of an emerging (human) right to freedom from corruption in customary international law. Our main contribution to the literature lies in providing a structured argument for how criminal law could never be adequate to satisfactorily address corruption in highly corrupt countries in the first place, and in exploring the feasibility and desirability of a framework underpinned by international human rights law.

Has FIFA reduced its corruption risks? Lessons learned from a reform attempt

The field of sports governance is relatively new and underresearched. While research exists on the accountability of international organizations and the control of corruption at national level, there is little on the link between the two specifically in regards to international organizations. This paper addresses this gap by jointly using Grant and Keohane’s ‘Seven Mechanisms of Accountabi- lity in World Politics’ to evaluate FIFA’s accountability and Mungiu-Pippidi’s equilibrium model to evaluate the organization’s control of corruption. The policy recommendations are presented in the form of three scenarios, varying by intensity of intervention, to conclude that changing a large organization practically free from formal accountability mechanisms needs far more radical refor- ms than the ones already undertaken to be significant. For FIFA to fix its corrupt culture, it needs far stronger accountability mechanisms in place to control corruption1.

Beyond the Hype: Distributed Ledger Technology in the Field of Public Administration

Following the increasing attention the topic received over the last years, this paper is looking at the use of distributed ledger technology (DLT) in public administration and, in particular at its most prominent example: Blockchain technology. While offering a gentle introduction to the topic, the paper establishes an overview of the attributes and potential use cases of DLT in the context of public administration and bureaucracies. As a technology establishing a decentralised, high-trust data management system, DLT has potential to be used for the storage of administrative data and for increasing the effectiveness and efficiency of administrative data management. While potential uses are wide-ranging, this paper offers a simple typology of these. Furthermore, it offers a critical view of the challenges and drawbacks that the technology currently poses to public officials looking at using DLT in their processes. Ultimately, this paper takes the view that DLT can be a potentially valuable tool for public administrations to make use of, but the drawbacks and difficulties associated with this technology are often not discussed or acknowledged as often or as thoroughly as needed, giving a false picture of how easy it would be for governments to use this technology successfully.

Optimizing anticorruption: the long arm of the law vs.the invisible hand of the market?

Over the past three decades, the study of corruption across several disciplines has greatly increased. Despite the progress on knowledge, anti-corruption scholars and practitioners deplore the lack of progress in the fight against corruption as measured by rankings such as the Corruption Perception Index (CPI). Mungiu-Pippidi (2015), for example, identifies a maximum of ten countries that have managed to reduce corruption significantly in the past 20 years. This leads to the question on whether there is a gap between corruption theory and practice, and if so, what can explain it? This chapter reviews the relevant literature to argue that what looks like a possible disconnect between theory and practice is the product of lack of conceptual clarity and insufficient cross-pollination between different strands of academic literature. It considers two of the main streams of literature, that in favor of less government intervention with anti-corruption policies based on incentive manipulation rather than repression and that in favor of government intervention and legal deterrence. It thus attempts to bring some clarity to the debate around the effectiveness of market and legal solutions for anti-corruption by combining the latest findings and lessons learned from the anti-corruption literature with the main theories of change originated from the economic literature. In addition to the theoretical discussion, I run a few tests of the theories I discuss to substantiate my argument.

Control of Corruption During the Post-Conflict: Promoting Good Governance in Colombia

This research is focused on the Colombian Government’s flagship post-conflict and statebuilding policy from 2009 to 2015, known as the “Consolidation Policy”. The Government’s policy aimed to transform the governance in post-conflict regions from a social order functional to the armed conflict to such a social order that would promote good governance and inclusive governmental institutions.

The analysis sheds light on the limitations and achievements of the policy on the control of corruption and examines the extent to which it shaped the governance order of post-conflict regions in the short term using a mixed methods approach including a differences-in-differences estimation and semi-structured interviews. The analysis is based in the Equilibrium Theory of Control of Corruption, which identifies policy-actionable variables that promote good governance and the control of corruption. This theory was operationalized in the context of post-conflict Colombia. This research determined the changes produced by the Government policy on the control of corruption by comparing control and intervention municipalities. The analysis revealed a mixed effect on the control of corruption where the intervention occurred. The results showed that the Consolidation Policy was associated with more civil society collective actions, at least in a group of municipalities, and an increase in local government accountability to citizens. On the contrary, there seems to be no association of the policy with increments in local government procurement transparency, or disciplinary sanctions to local civil servants by the Office of the Inspector General, one of the state control agencies

The research identifies the main issues that limited the Consolidation Policy’s mixed effect on the control of corruption. First, instead of a quick-impact approach, this research recommends a gradualist, long-term approach that combines insecurity reduction and empowering citizen group’s to keep corruption in check. Second, given the limitations of the Colombian State to regulate governance in conflict affected areas, civil society should be a central partner in the initiatives of good governance promotion.

Electoral accountability of corrupt politicians: Conditioning factors revisited

In the past years, a growing literature has examined the impact of corruption accusations on voting behavior and found that, although incumbents appear to suffer some vote share loss after being associated with corruption scandals, a vast majority of them gets reelected nonetheless. If voters do not exercise electoral accountability against corrupt politicians as effectively as democratic theory would expect, what conditions explain this pattern? Which factors favor or hinder their decision to remove corrupt incumbents from office? The literature suggests a number of contextual factors and voters’ attitudes that may condition corruption voting, but most studies examine them in a fragmented way. This paper seeks to address this gap in the existing scholarship on the topic by building a comprehensive model to test the validity of five central hypotheses discussed in previous works. Original corruption data from randomized audits in 383 Brazilian municipalities are used in the analysis. The results provide partial evidence for only two of the hypothesized mechanisms: (a) electoral accountability of corrupt incumbents is weakened by recent positive assessments of their performance in office, in particular in terms of improvements in economic conditions, and (b) voters appear to punish more strongly politicians facing more corruption accusations, but this is conditional on the timing of the audit.

Building Good Governance in Greece, a European Missed Opportunity?

Corruption has risen on the European agenda considerably from the last European elections and is
likely to play a prominent role in the 2019 campaign for European Parliament. But while pro-European
parties will advocate for a stronger Europe and populist parties might try to blame all corruption on Brussels
and mainstream parties, a deeper understanding on the linkage EU-national government in curbing
corruption becomes imperative. This paper uses the case of Greece to discuss the impact of Europe about
governance quality in EU Member States and asks if the new European elections find both Greece and
Brussels more prepared to deal with corruption. The conclusion is that EU driven reforms in Greece remain
scattered, fragmented, not locally “owned” or driven by any group whose interest good governance would
serve. Meanwhile, the groups opposing change are well articulated. Greece’s genuine good governance
congregation has yet to coalesce, and the 2019 European and legislative elections are a good opportunity,
especially if civil society would not allow parties to instrumentalize anticorruption but engage them to
promise the still missing good governance reforms during electoral campaign and then monitor them.

Immunity or Impunity? The effects of immunity provisions on national levels of control of corruption

Immunities or jurisdictional privileges provide persons or groups of persons some degree of protection against civil or criminal rules that do not apply to all citizens. However, immunities can also be used by public officials as a shield from liability for criminal offences, including corruption. For this reason, international bodies have been pushing, over the past two decades, for a set of legal standards to ensure that immunity does not translate into impunity. The international standards and best practice can be summarised in the following four recommendations promoted globally:

1) Reducing the range of officials provided immunity;
2) Reducing the scope of criminal offences for which immunity can be invoked;
3) Introducing clear guidelines and procedures for lifting immunities;
4) The specification of a time limit for the duration of legal protection.

This study tests empirically whether these legal standards are associated with better control of corruption in practice. The results show weak to no evidence that the set of international standards recommended to countries around the world are associated with better control of corruption. The only evidence of this association, albeit only significant at the 90% level of confidence, is that immunity provisions for MPs which are aligned with international standards are associated with lower levels of bribery. Furthermore, case studies from Greece and Belgium have shown that impunity can be countered without legal changes and that a practice of impunity can be observed even in countries that have robust legal frameworks.

Whistleblower Protection Legislation and Corruption

Following the “Snowden effect” and more recent whistleblower scandals, such as the Panama Papers, Luxleaks, Cambridge Analytica or the Danish Tax Fraud, the number of whistleblowing cases and laws for the protection of whistleblowers in Europe and around the world has significantly increased as a tool to combat corruption, fraud and organizational wrongdoings. This paper provides a theory-based and empirical analysis of the theory of change behind whistleblower protection legislation as an anti-corruption policy tool. By introducing a new indicator developed in collaboration with ERCAS and based on international best practices on whistleblower laws – the Whistleblower Index (WI) – the report shows that there is only a slightly upward interaction between stronger whistleblower laws, as of the WI, and slightly higher levels of WGI’s Control of Corruption. It also did not find a statistically significant change in WGI’s Control of corruption after the introduction of a specific whistleblower protection law. Based on the empirical analysis carried out for this study, whistleblower protection legislation only seems to be effective in deterring corruption and organizational wrongdoings in a governance system based on ethical  universalism and absence of captive media.

Crony Capitalism in the European Union: Subjective or Objective?

Long before the Panama leaks, nearly three quarters of Europeans (73%) had already endorsed the belief that bribery and connections are the easiest way to obtain public services in their respective countries. Furthermore, pan-European surveys revealed that nearly 7 out of 10 Europeans agreed that corruption was part of the business culture in their country (66% of respondents) and that favoritism and corruption hampered business competition (68% of respondents). But are such perceptions accurate, or do they reflect the general pessimism in times of austerity, uncertainty and growing inequality? This paper uses survey data to deconstruct perceptions of corruption, but also as a premiere uses fact-based data from new research projects on corruption and procurement to understand how much is real and how much is noise in the growing public perception of crony capitalism in Europe. The paper finds that individual perceptions are not disconnected with reality. Although people whose self-ascription places them in the lower part of a status scale are more inclined to perceive generalized corruption, most of the variance at both national and individual level is explained by fact based variables, for instance the number of non-competitive tenders per country.

This paper will be published in a forthcoming edited volume with Oxford University Press. Please cite as Mungiu-Pippidi, M. and Kukutschka, R. M. B (2018). Can a Civilization know its own institutional decline? A Tale of Indicators. In H. Anheier, M. Haber, and M. Kayser (eds), Governance Indicators: Approaches, Progress, Promise. Oxford: Oxford University Press.

How Does Political Finance Regulation Influence Control of Corruption? Improving Governance in Latin America

In this paper, we address the question of how political finance regulation affects control of corruption in Latin America from a quantitative perspective. We present a Political Finance Regulation Index with panel data from 180 countries over 20 years (1996-2015). This index was developed using the IDEA Political Finance Database, and once created, was applied to assess the relationship between political finance regulation and control of corruption.

In order to do this, we use the equilibrium model of control of corruption developed by Mungiu-Pippidi (2015). We also included judicial independence and public investment, considered as a constraint and an opportunity to corrupt, respectively. Lastly, we use control variables for level of development.

Results show that, in Latin America, increases in political finance regulation are related with a deterioration of control of corruption. This relationship is statistically significant in the panel estimations. Inversely, the negative relationship between regulation and control of corruption becomes positive in countries with high levels of judicial independence. In a similar way, increases in opportunities to corrupt, represented by levels of public investment, have a significant and negative effect in control of corruption.

Corrupt Contracting: Partisan Favouritism in Public Procurement. Hungary and the United Kingdom compared.

For politicians seeking to use a clientelist approach to achieve political and private gain, i.e., to prolong their hold on power and maximize personal profit, control of government contracting is a key tool. We theorise that politicians wishing to exploit government contracting for such ends will seek to increase their influence over three stages of public procurement – policy formation, implementation and monitoring – but that their efforts can be constrained by institutional controls and checks. We examine these influence strategies and institutional constraints by comparing one young democracy and one mature democracy, Hungary and the United Kingdom. Developing new procedural and outcome indicators of corruption risk in contracting, we use a change of government as a natural experiment to analyse partisan favouritism in procurement. We find that, in Hungary, where political influence is systematic and far-reaching, 50-60% of the market is dominated by favoured companies, compared to only 10% of the UK market.

Measuring Control of Corruption by a New Index of Public Integrity

While the last twenty years saw the invention of corruption rankings, allowing comparison over countries and the shaming of corrupt governments, such measurements are largely based on perceptions of experts, lacking both specificity and transparency. New research, based on a comprehensive theory of governance defined as the set of formal and informal institutions determining who gets what in a given context, allows more specific and objective, although indirect measurements of control of corruption. Such measurements focus on the institutional framework which empowers public integrity and eliminates many current anticorruption tools, while validating others. Most importantly, it provides a broader specific context which can empower reforms based on evidence and a clear measure to determine status and progress of corruption control.

This research was made possible by support of the EU FP7 ANTICORRP project (Grant agreement no: 290529) at the Hertie School of Governance.

Case study report on control of corruption and EU funds in Ukraine

This report analyses the European Union (EU) – Ukraine relationship by looking at the impact of EU conditionality regarding the anti-corruption framework on the use and distribution of EU funding between 2007 and 2014. It shows that, historically, the EU concern with good governance in Ukraine has been materialised in the form of numerous anti-corruption conditions attached to transnational aid flows. Despite important improvements at institutional levels – particularly the set-up of the National Anticorruption Bureau, the Ukrainian practices and everyday routines have not changed fundamentally. Assessing the impact of EU funding in such a context marked on the one hand by pervasive corruption and on the other hand by a profound desire for change, can be a challenging task, especially due to the fact that a large share of international aid received has been directed to budget support, thus making it impossible to asses if it has been affected by corruption. Using secondary data analysis and interviews with key stakeholders, the report shows that the efficiency of EU assistance could be improved by increasing the levels of control, enhancing transparency and establishing a closer relationship with international partners who are more experienced in tackling EU funding fraud and grand corruption.

EU governance promotion in Tunisia: Lessons from the Arab Spring

This report explores the intersection between European Union assistance to Tunisia and the development of that country’s good governance and anti-corruption framework, both during times of stability under the authoritarian rule of former President Ben Ali and during the turbulent transition period that ensued after the Arab Spring. The report furthermore analyses the changes in funding priorities during the period 2007–2013, as well as the concomitant development and application of the EU’s conditionality framework. It argues that the EU’s use of the instruments at its disposal, as well as the incentives that were on offer, were not always helpful in pushing forward good governance and anti-corruption reforms, and indeed may even at times have been harmful to them.

Case study on EU aid and anti‐corruption and governance in Tanzania

Tanzania boasts one of the highest rates of economic growth in Sub-Saharan Africa. In the last decades it also established one of the most harmonised donors frameworks. However, the relationship between Tanzania and its donors has deteriorated significantly in recent years following several high-level corruption cases and slow progress on more complex governance reform. In response, the EU has reformed the composition of its development assistance modalities, which predominantly entailed a reduction in Budget Support, and has stopped committing further aid to Tanzania for the time being. These events indicate considerable limitations to the effectiveness of the EUs (and other donors’) measures to induce good governance through existing modi of development cooperation.

Improving governance in Kosovo: Evaluating the Impact of EU Conditionality through Policy and Financial Assistance

This paper seeks to evaluate the impact of EU policy and funds aimed at improving governance and controlling corruption in Kosovo. It examines the interrelation between EU conditionality as expressed in different policy documents and the financial assistance provided by the EU to Kosovo in the area of rule of law. The focus is on the period since 2007, although the paper begins with a brief overview of the conflict in Kosovo and its aftermath. The paper then tracks how the anti-corruption discourse features in policy documents and funding priorities, highlighting the EU conditionality mechanisms applied and the development assistance provided. It evaluates conditionality in the light of Kosovo’s anti-corruption performance during this period. The paper draws conclusions as to the effectiveness of EU policy and financial assistance in the area of anti-corruption, with a view to informing the ongoing policy debate on how to strengthen EU leverage in improving anti-corruption efforts in aspiring member-states, particularly in a post-conflict context.

The EU Good Governance Approach in Ghana: the growing focus on anti‐corruption measures

Ghana is a strategic country for the European Union’s promotion of peace and good governance in West Africa. However, recent economic challenges have exposed public finance management deficiencies and a crisis of confidence in the ability of the government to deal with increasing deficits; unemployment; and a dramatic energy crisis. Corruption practices are seen as a key factor impeding on the development of the country with recent scandals exposed in the media raising the awareness of the public. With the support of international partners, the government launched its own anti-corruption framework in July 2014, the National Anti-Corruption Action Plan (NACAP), while the EU in Ghana started the Ghana Anti-Corruption, Rule of Law and Accountability (Ghana-ARAP) Programme in January 2016. This report examines how the Ghana-EU Partnership is structured, the state of governance in Ghana, and how the EU has or has not been inducing change in governance practices to fight corruption. The study includes a review of the different aid modalities and recommendations for positive change in Ghana, in terms of both development assistance and anti-corruption strategies.

Case study report on control of corruption and EU funds in Egypt

The European Neighbourhood Policy has without a doubt emphasized the importance of good governance, which became a priority objective in the 2007-2013 EU-Egypt country strategy paper. Within this framework, the EU has conditioned its aid on Egypt’s commitment to reforms. However, in practice, the “softly softly” approach that has seen the EU be too flexible on tying its aid to reforms in the face of the Egyptian resistance to conditionality, has proven to be an extremely opaque and ineffective process. While corruption has been a major governance challenge for Egypt, the EU – only directly addressing the issue in a small-scale decentralized project – did not implement any specific anti-corruption mechanism for oversight or monitoring despite having over 60 per cent of its funds channelled to Egypt’s national treasury through sector budget support. The 2011 Egyptian revolution incontestably led the EU to reflect upon its policies and to pledge stronger commitment to the promotion of good governance and the fight against corruption. But in the highly volatile political environment that followed, the EU’s focus on refining its policy instruments has prevented it from acting in a timely fashion and, once again, the implementation of reforms has lagged far behind Brussels’ outstanding declarations. As the present paper suggests, the EU’s approach has been, in essence, heavily bureaucratic and far less strategic. One fair assumption regarding the EU’s lack of enthusiasm in genuinely addressing corruption – and good governance – would be that the issue has never truly impacted on the core of EU–Egypt relations, which have remained grounded on economic, stability and security concerns.

Improving governance in Bulgaria: Evaluating the Impact of EU Conditionality through Policy and Financial Assistance

The paper examines the impact on Bulgaria’s anti-corruption performance of the interrelation between EU policy conditionality and EU financial assistance, with a focus on post-accession developments. Although the EU never formally linked EU assistance to progress on anti-corruption, the disbursement of funds has tended to peak around critical deadlines for accession progress, e.g. the signing of the accession treaty in 2005, and the expiration of the Cooperation and Verification Mechanism’s (CVM) safeguard clauses in 2010. Both years also marked the lowest levels of corruption experienced by Bulgaria’s citizens. This suggests that the combined effect of EU anti- corruption conditionality and development assistance on governance in Bulgaria was positive – but temporary.

Moreover, the 2015 CVM monitoring report suggests that, eight years after EU accession, Bulgaria still faces three key governance challenges – combatting high-level corruption, building an institutional approach to anti-corruption, and judicial independence. In 2014, public experience of corruption reached its highest level since the first comparable research in 1998. The lack of anti-corruption conditionality or credible enforcement mechanisms since 2010 has seen Bulgaria backslide in the fight against corruption. The current EU approach and development assistance for anti- corruption reforms have been insufficient to put Bulgaria on a virtuous circle path to open access order (or a good governance model), and has not been able to compensate for the lack of domestic political commitment to anticorruption reform. The paper’s findings suggest that the EU and Bulgarian anti-corruption stakeholders need to find new strategies for bringing about lasting governance change.

The Impact of EU Conditionality on Corruption Control and Governance in Bosnia and Herzegovina

This paper seeks to evaluate the impact of EU policy and funds aimed at improving governance and controlling corruption in Bosnia and Herzegovina. It examines the interrelation between EU conditionality as expressed in different policy documents and the financial assistance provided by the EU. The focus is on the period 2007-13. It tracks the way in which the EU pursues democratic conditionality in BiH, and examines cases that are deemed successes as well as those deemed failures. It also considers how conditionality relating to the provision of EU funds is affected. It evaluates conditionality in the light of BiH’s anti-corruption performance during this period. The paper draws conclusions as to the effectiveness of EU policy and financial assistance in the area of anti-corruption, with a view to informing the ongoing policy debate on how to strengthen EU leverage in improving anti-corruption efforts in aspiring member-states, particularly in a post-conflict context.

EU Aid and the Quality of Governance

Using a panel dataset on 103 developing countries, this paper empirically analyzes the impact of the European aid flows on quality of governance in aid recipient countries. The analysis employs aggregated Official Development Data as well as disaggregated project level data. The results show that while bilateral aid from the largest European donors does not show any impact, multilateral financial assistance from the EU Institutions leads to an improvement in governance indicators. These findings thus suggest that European development assistance can help to promote good governance if aid is allocated at the EU supranational level rather than at the national level of the member states.

Uncovering High-Level Corruption: Cross-National Corruption Proxies Using Government Contracting Data

Measuring high-level corruption and government favouritism has been the object of extensive scholarly and policy interest with relatively little progress in the last decade. In order to address the lack of reliable indicators, this article develops two objective proxy measures of high-level corruption in public procurement: single bidding in competitive markets and a composite score of tendering ‘red flags’. Using publicly available official electronic records of over 2.8 million government contracts in 27 EU member states plus Norway in 2009-2014, it directly operationalizes a common definition of corruption: unjustified restriction of access to public contracts to favour a certain bidder. Corruption indicators are calculated at the level of contracts, but produce aggregate indices consistent with well-established country-level corruption indicators. Due to the common EU regulatory framework, indicators are consistent over time and across countries, while WTO regulations underpin global generalisability. Indicator validity is supported by correlations with well-established perception-based corruption indicators, and novel micro-indicators such as prices and supplier registration in tax havens. The utility of the novel indicators is demonstrated by using them to explain the effect of deregulation on corruption risks at the country level. In order to facilitate wide use of the data and indicators by researchers, journalists, NGOs, and governments, they are made publicly available at digiwhist.eu.

Multi-Nationals and Corruption Systems: The Case of Siemens

Scholars tend to agree and evidence has shown that domestic businesses adapt to the local type of corruption, but little is known whether large multinational corporations also adapt to the local forms of corruption. Institutionalist theories of corruption and of international political economy would suggest that this would be the case, but the hypothesis has not, to our knowledge, been systematically tested. This paper, drawing on investigative materials about the activities of one such multinational, the German corporation Siemens AG, examines how it used corruption and bribery to advance its business around the world. We extrapolate from the logic of four “syndromes of corruption”, as Michael Johnston terms them, to develop specific hypotheses about the kind of behavior multinational corporations would be expected to exhibit when doing business in each of the four kinds of syndromes. We examine and compare Siemens’ activities in the United States, Italy, Russia and China. We find that Siemens did adapt to the local corruption form (or “syndrome”) and used, among others, different types of intermediaries to approach the local elites. The evidence from these case studies supports the institutionalist argument that multinationals distinguish between corrupt environments and further supports the argument that there exist different types, or syndromes, of corruption.