THE CONGRESSIONAL COMMITTEES WHICH DRAFTED THIS ANTIBRIBERY LEGISLATION CONSIDERED TWO POSSIBLE APPROACHES: DISCLOSURE AND CRIMINALIZATION. THE SECURITIES AND EXCHANGE COMMISSION (SEC) PROPOSED A THIRD APPROACH: IMPROVING CORPORATE ACCOUNTING AND AUDIT PROCEDURES. THE LAW COMBINED THESE APPROACHES, REQUIRING COMPANIES SUBJECT TO SEC'S JURISDICTION TO MAINTAIN STRICT ACCOUNTING STANDARDS AND MANAGEMENT CONTROL OVER THEIR ASSETS. IN ADDITION, IT IS UNLAWFUL FOR REPORTING COMPANIES AND DOMESTIC CONCERNS TO BRIBE A FOREIGN GOVERNMENT OFFICIAL, POLITICAL PARTY, OR CANDIDATE FOR CERTAIN SPECIFIED CORRUPT PURPOSES. THE ACCOUNTING PROVISIONS THEREFORE SEEK DETERRENCE THROUGH DISCLOSURE; THE ANTIBRIBERY PROVISIONS, THROUGH CRIMINALIZATION. EFFECTIVE ENFORCEMENT MUST DRAW ON BOTH SETS OF PROVISIONS BUT WILL BE LIMITED BY THE DIFFICULTY OF GATHERING SUFFICIENT CREDIBLE EVIDENCE. SEVERAL ENFORCEMENT ACTIONS ALREADY UNDERTAKEN ILLUSTRATE THE PROBLEMS INVOLVED IN ENFORCEMENT AND RESULTS ACHIEVED. IN CASES OF UNREGULATED COMPANIES, ENFORCEMENT MAY BE ESPECIALLY DIFFICULT, BECAUSE THE LAW'S ACCOUNTING PROVISIONS DO NOT APPLY. THE RESULTING PROBABILITY OF DISPARATE ENFORCEMENT MAY THEREFORE CREATE PROBLEMS. EXAMINATION OF SPECIFIC PROVISIONS OF THE LAW, DESCRIPTION OF EFFORTS TO DEVELOP MULTILATERAL AGREEMENTS, CASE STUDIES, BUSINESS COMMUNITY REACTION TO THE LAW AND FOOTNOTES ARE INCLUDED. (CFW)