ABSTRACT
The notion that fraudulent enrichment of top State officials through acts of indigenous spoliation is prejudicial to the public interest and therefore a violation of the fiduciary obligation leaders owe to the citizens can be viewed in two ways. In 1997, the European countries were able to secure a comprehensive anticorruption instrument that went beyond the limited goal of protecting only the Communities financial interests when they adopted the Organization for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Public Officials in International Business Transactions. The Criminal Law Convention is different from the OECD Convention in that it attacks corruption from both the supply and demand sides. The Council of Europe opened a second front in the war against corruption when it adopted the Civil Law Convention on Corruption in 1999. The UN Convention breaks new ground with its provisions on prevention, criminalization, asset recovery and international cooperation.
