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Sunday, October 12, 2025

Denmark’s Resistance Toward Anti-Corruption Enforcement - The National Law Review

The Organisation for Economic Co-operation and Development (OECD) recently released a Phase Four Follow-Up Report unveiling Denmark’s shortcomings in implementing the OECD’s recommended anti-corruption and anti-bribery practices. The 2025 report follows the OECD’s alarming findings from 2023.

While the OECD concedes Denmark has made some “notable enforcement progress,” many necessary steps have yet to be satisfied (4). In an overview, the OECD states that Denmark has “fully implemented 6 recommendations, partially implemented 12 recommendations, and not implemented 37 recommendations” (4).

Partial Progression

In the 2023 report, the OECD highlighted key areas for improvement. A notable concern was the lack of awareness surrounding the reporting of foreign bribery among public officials, the private sector, and the general public. In response, Denmark crafted an introductory course for all public employees and conducted advertising campaigns with three trade journals (8). The OECD also commends Denmark for prosecuting its second corporate sanction for foreign bribery, a case initiated by a self-reporter, and for instigating “proactive media monitoring” to detect potential cases (6).

While addressing recommendations, many of these initiatives remain incomplete. For example, it is unclear as to what extent the introductory courses tackle “foreign bribery specifically” and whether detected foreign bribery cases through media monitoring are adequately “recorded” (6; 13).

In a...



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