On February 11, 2025, Transparency International (TI) published its annual Corruption Perceptions Index (CPI) for 2024. TI observes that corruption remains “a dangerous problem in every part of the world, but change for the better is happening in many countries” noting 148 countries out of 180 covered as part of the CPI have “stayed stagnant or gotten worse [since 2012].”
The CPI ranks perceptions of public-sector corruption in 180 countries and territories from a variety of sources, reflecting the views of experts and businesspeople. TI ranks countries and territories with scores ranging from 0 (highly corrupt) to 100 (very clean).
As part of this year’s CPI, TI has also focused its analysis on the intersection between corruption and global efforts to combat climate change, flagging areas such as bribery, undue influence, and conflicts of interest as impediments to “effective climate action.”
In its assessment of the CPI scores, TI observed that (1) two-thirds of countries and territories globally scored below 50, and (2) the average score across the Asia Pacific region (APAC) dropped to 44, after stagnating for several years at 45.
Top scoring countries globally feature traditional strong performers in APAC such as Singapore (84; ranked 3rd), New Zealand (83; ranked 4th), Australia (77; ranked 10th), Hong Kong (74; ranked 17th) and Japan (71; ranked 20th). TI did not spare criticism for some of the CPI’s top performers, however. For example, TI flagged CPI-top performing countries and territories that host major financial centres, including those in APAC (e.g., Singapore and Hong Kong), as being “vulnerable to corrupt financial flows.”
For the APAC region specifically, TI provides a grim score card noting that “governments across APAC are still failing to deliver on anti-corruption pledges.” That said, it reserved some praise for countries including Vietnam (40; ranked 88th) and South Korea (64; ranked 30th) that have significantly improved in their CPI scores in the last 10 years (although Vietnam’s score dropped two points between 2022 and 2024).
Despite TI’s criticisms that may be primarily targeted at stagnating or poorly performing countries, we observe several jurisdictions in APAC (albeit mainly top CPI performers) have made headway in the last year to strengthen their foreign anti-bribery frameworks.
For example, Australia’s Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 introduced a criminal offense of corporate “failure to prevent” foreign bribery, which came into force in September 2024 along with accompanying Guidance on Adequate Procedures to Prevent the Commission of Foreign Bribery (reported in our September 2024 Top 10 Anti-Corruption Developments). Similarly, Japan’s 2024 amendments to its foreign anti-bribery laws and publication of revised Guidelines for Prevention of Bribery of Foreign Public Officials demonstrates the country’s commitment to addressing foreign bribery risks (commentators including the OECD Working Group on Bribery have historically critiqued Japan for poor legislative and enforcement measures against foreign bribery).
Ones to Watch
China
As with previous years, China remains a country of interest for multinational companies with operations there, despite continued headwinds for the Chinese economy. Recovering from a dip in its 2023 CPI score (42; ranked 76th), China increased its CPI score by one point to 43 while retaining the same ranking.
The Chinese government appears committed to cracking down on corruption at all levels, including within the ruling party, “dispelling any notion that China is losing its grip on graft.” China’s Central Commission for Discipline Inspection (CCDI) declared in January 2025 that a record of 58 “tigers,” or senior officials were subject to probes in 2024, with 47 of these individuals serving at the vice-ministerial level or above. In the last year, President Xi highlighted the need for the ruling party to “turn the knife inward” to address one of its biggest threats—corruption—while recognizing the crackdown against rampant graft may have led to “bureaucratic inertia” among officials who, fearing punishment, are unwilling to act or make decisions.
In 2024, Chinese authorities continued intense efforts to combat corruption and “malfeasance” in sectors such as finance and energy. In particular, there has been a significant increase in legislative and enforcement activity within the life sciences industry. According to reports, the anti-corruption campaign focusing on healthcare professionals or HCPs, academics, and pharmaceutical company executives has led to 40,000 individuals being punished and 2,634 referred for prosecution. The Chinese government has also enhanced regulatory oversight, issuing the Compliance Guidelines for Healthcare Companies to Prevent Commercial Bribery Risks, which came into effect on January 10, 2025 (we provided our analysis on the finalized guidelines). These guidelines will serve as an important point of reference for healthcare companies operating in China. Additionally, the guidelines indicate that Chinese enforcement resources will focus on key bribery risk areas for such companies including fees-for-service payments, payments to third-party healthcare organizations, and discounts and rebates provided to distributors.
In the year ahead, we expect that China will continue to enhance measures, both from a legislative and enforcement perspective, to address corruption and misconduct across key industries and at all levels.
Indonesia
Indonesia, Southeast Asia’s largest economy, continues to provide significant promise for foreign investors, with a new president, Prabowo Subianto (who took office in October 2024) aiming to achieve eight percent economic growth by 2029. In 2024, the resource-rich country’s foreign direct investment was approximately USD 55.33 billion, up 21% on a yearly basis. However, reports suggest that the country continues to struggle with endemic corruption, with some observing that foreign investors remain wary of expectations of bribes by public officials. The country saw a marked CPI score increase by three points from 34 (ranked 115th) in 2023 to 37 (ranked 99th) in 2024, although TI flagged the country’s energy sector as being “full of examples of individuals close to political elites exploiting it for personal gain.”
As highlighted in our previous years’ CPI coverage, Indonesian enforcement agencies continue to face criticism about their credibility and effectiveness in combatting corruption. It remains to be seen whether President Prabowo, who has vowed to tackle corruption with renewed vigour (telling government ministries recently to “clean up, or be cleaned out”), will deliver on his promises. Unconventional initiatives by the Prabowo administration to potentially pardon graft convicts and suspects who agree to return stolen assets to the state have been met by sharp criticism. Some argue that such measures weaken principles of accountability and transparency.
As Indonesia continues its march to “developed nation” status by 2045 and courts foreign investment, we expect existing and new investors will have to carefully navigate inherent challenges in the jurisdiction, including bribery and corruption risks.
India
India’s economy continues to expand at breakneck rates, with expectations that the country will maintain its status as the “fastest-growing large economy” for the next two years, outpacing both its global and regional peers.
Through various initiatives, including Prime Minister Narendra Modi’s longstanding “Made in India” campaign and increased leveraging of public-private partnerships, we anticipate continued growth and development in key sectors such as infrastructure (across, for example, railways, roads, telecommunications, and urban infrastructure), power (India is the third-largest producer and consumer of electricity worldwide), and healthcare (with public and private components supporting the world’s most populous country).
Unsurprisingly, these sectors traditionally pose bribery and corruption risks through frequent interactions with government officials and significant reliance on third parties. In India’s case, these risks may be heightened through unique circumstances that include complex governance and administration (e.g., India has various levels of governance at the central, state, and local levels) and the involvement of state-owned enterprises (referred to as Public Sector Undertakings in India) as key drivers in some of these sectors.
India’s CPI score stagnated for several years between 2020 – 2022 (scoring 40) but has since fallen year-on-year (scoring 39 in 2023 and 38 in 2024), ranking 96th out of 180 countries and territories. Its falling score suggests that the country needs to do more to tackle public sector corruption (although some have lauded India for efforts in tackling money laundering and terrorism financing). Having once described corruption as being akin to termites that have “completely hollowed out the systems of the country and its capabilities,” Prime Minister Modi continues to face critics alleging that Indian investigation and enforcement authorities are being used as political weapons against opponents and critics.
Corporates pursuing opportunities in India must remain vigilant to the risks of bribery and corruption that could potentially create legal, reputational, and other operational risks for their businesses and investments in the country.
The Road Ahead
While TI takes a pessimistic view towards APAC governments’ failure to address corruption, it is crucial to appreciate that CPI scores reflect perceptions of public sector corruption and do not provide a complete picture of bribery and corruption risks (nor legislative or enforcement measures to address these risks) in individual jurisdictions.
We expect the coming year will see increased local legislative and enforcement measures by APAC jurisdictions to combat corruption and related risks including money laundering and terrorism financing. Top CPI-performing countries (e.g., Australia and Japan) have already strengthened legislative frameworks to tackle foreign bribery (while previously focusing more on domestic bribery), and enforcement is likely to follow soon. Similarly, countries with stagnating or relatively lower CPI scores (e.g., India, Vietnam, and Indonesia) are likely to refine their enforcement efforts and dispel any perceptions that their government officials are susceptible to bribery in a bid to attract foreign investors. Ultimately, the proof will be in the pudding for these countries.
Although the United States may appear to be “pausing” efforts to enforce its foreign anti-bribery laws like the U.S. Foreign Corrupt Practices Act, companies operating in APAC should be staying the course on anti-corruption compliance, for various reasons, including the need to comply with local laws and regulators’ expectations. As alluded to above, regulatory scrutiny and enforcement actions in certain APAC jurisdictions remain active yet unpredictable, often affected by geopolitics and shifting domestic priorities. Companies should be prepared to strategically respond to these developments and demonstrate the strength of their overall compliance framework.
To further address evolving compliance risks, corporates operating in APAC should also consider compliance strategies such as risk mapping or assessments, and benchmarking (both internal and external). These measures will allow corporates to (1) ensure that their global compliance programs are being implemented effectively on a local or regional basis, (2) timely identify relevant compliance risks (e.g., bribery and corruption, trade compliance, ESG), how those risks may intersect, and necessary remediation, and (3) promote compliance with applicable local laws and regulations that may vary across jurisdictions.
For more information about assessing and addressing compliance-related risks in APAC and around the globe, please contact us.
London trainee Michal Pati assisted with the research for this client alert.
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