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C O N F I D E N T I A L PARIS 003181 
 
SIPDIS 
 
STATE FOR EB/IFD/OMA, EUR/ERA, INL/C, L/LEI AND L/EB 
DOC FOR ITA/MAC/MTA/KOZLOWICKI, OGC/NICKERSON/MANSEAU 
DOJ FOR CRIMINAL DIVISION/FRAUD SECTION/MMENDELSOHN/JACOBSON 
USEU FOR MRICHARDS 
PASS TO US SECURITIES AND EXCHANGE COMMISION/ENFORCEMENT/RGRIME, 
INTL.AFFAIRS/TBEATTY 
 
FROM USOECD 
 
SIPDIS 
 
E.O. 12958: DECL: 07/25/2012 
TAGS: KCOR ECON EINV ETRD PREL OECD
SUBJECT: OECD: REPORT OF MARCH 12-14, 2007 MEETING OF THE 
WORKING GROUP ON BRIBERY 
 
Classified By: A/DCM CURTIS STONE FOR REASONS 1.5 (B AND D) 
 
¶1. (SBU) SUMMARY:  At its March 12-14 meeting, the OECD Working 
Group on Bribery (WGB) conducted Phase 2 peer-review evaluations 
of Portugal and Ireland's implementation of the OECD 
Anti-Bribery Convention ("Convention").  The WGB called on 
Portugal to raise awareness of foreign bribery in both the 
public and private sector, to be more proactive in detecting, 
investigating and prosecuting foreign bribery offenses, and to 
take measures to disallow undocumented, confidential expenses. 
Lead examiners advised that the GOI's poor participation in the 
original on-site visit left them with little basis to assess 
Ireland's implementation and enforcement efforts.  Ireland 
acknowledged this problem and agreed to an additional on-site 
visit within one year.  The WGB assessed UK efforts to implement 
the Convention in context of a Phase 2 written follow-up review, 
continued discussions on the UK's discontinuation of the 
BAE/Saudi Arabia investigation, and released a public statement 
expressing serious concerns.  The WGB also announced its 
decision to conduct a supplemental, Phase 2 bis examination of 
the UK.  Japan reported on results of its self-assessment of 
obstacles to effective enforcement.  The WGB completed Phase 2 
follow-up reviews of Japan and Switzerland and established 
mandates for two sub-groups to review anti-bribery instruments 
as part of the possible revision of the 1997 Revised 
Recommendation, which outlined best practices in areas such as 
accounting, auditing and public procurement, non-tax 
deductibility of bribes and other measures to combat foreign 
bribery.  END SUMMARY. 
 
TABLE OF CONTENTS 
 
Portugal Phase 2 Evaluation - paras 2-3 
Ireland Phase 2 Evaluation - paras 4-6 
Japan Self-Assessment - paras 7-10 
Phase 2 Follow-up Reports - para 11 
-- Japan Written Follow-up - paras 12-13 
-- UK Written Follow-up - paras 14-19 
-- UK:  BAE/Saudi Arabia - paras 20-24 
-- Switzerland Written Follow-up - paras 25-26 
-- Revision of Anti-Bribery Instruments- para 27 
-- Deferral of Tour de Table - para 28 
-- Outreach Activities - para 29 
-- 2006 Annual Report- para 30 
-- Other Items - paras 31-34 
 
PORTUGAL PHASE 2 EXAMINATION 
 
¶2. (U) Lead examiners Brazil and the Netherlands briefed on 
results of the Phase 2 on-site visit to Portugal, identifying 
key deficiencies in Portuguese enforcement efforts.  Although 
Portugal had made significant legislative efforts to implement 
the Convention, it has had no foreign bribery prosecutions or 
serious investigations.  While many government actors are 
involved in anti-corruption efforts, they are not active.  More 
vigorous action by the private sector is also required.  The 
Portugal delegation reported that the on-visit had made a very 
positive contribution to Portugal's revision of its criminal 
code.  Since the visit, the Foreign Ministry, Ministry of 
Economy and the Export Promotion Agency had carried out a major 
dissemination campaign to inform all Portuguese missions abroad, 
major business associations and the largest Portuguese companies 
about foreign bribery obligations. 
 
¶3. (U) WGB members called on Portugal to take measures to 
disallow undocumented, confidential expenses; establish an 
autonomous definition of foreign public officials; clarify 
reporting obligations and procedures within the public service 
and accounting and auditing professions; provide additional 
resources and training to law enforcement authorities to 
proactively detect, investigate and prosecute foreign bribery; 
E 
 
raise awareness among public officials on preventing, detecting, 
reporting and investigating foreign bribery, including raising 
awareness among law enforcement authorities about special rules 
to establish nationality and extra-territorial jurisdiction in 
foreign bribery cases, specifically the absence of a dual 
criminality requirement; and to work more closely with the 
private sector and civil society to raise awareness and to 
develop effective prevention strategies. 
 
IRELAND PHASE 2 EXAMINATION 
 
¶4. (SBU) Lead examiners New Zealand and Estonia reported on a 
wholly unsatisfactory on-site visit to Ireland in October. 
Inadequate preparation and participation by the GOI left them 
with little basis to assess Ireland's implementation and 
enforcement efforts.  They advised that the total absence of 
awareness raising activities on foreign bribery in Ireland had 
demonstrated the low priority given to Ireland's application of 
the Convention.  There have been no prosecutions of foreign 
bribery in Ireland.  No law required public officials to report 
foreign bribery allegations, no whistle-blowing legislation was 
in place for the private sector, and overlapping statutes 
prohibiting foreign bribery contained differing elements which 
could impede enforcement efforts. 
 
¶5. (U) Lead examiners reported that since the visit, Ireland had 
recognized the serious problems with the evaluation and 
demonstrated that it intended to give higher priority to 
implementing the Convention.  Senior Irish officials announced 
that a Prevention of Corruption (Amendment) bill had been 
approved by the government, which intended to move quickly to 
introduce it to Parliament.  The Irish delegation advised that 
the bill will broaden the definitions for bribery and foreign 
public officials and introduce extraterritorial jurisdiction. 
They also reported that Ireland would consider including 
whistle-blower protection in the new bill.  The Irish del said 
the peer-review examination had been valuable and Ireland wanted 
to adopt best anti-bribery practices.  A group of senior Irish 
officials would be convened to review and implement WGB 
recommendations. 
 
¶6. (U) The WGB concluded that Ireland had not fully met its 
Phase 2 monitoring obligations, but accepted Ireland's 
invitation to carry out a Phase 2 bis examination with another 
on-site visit within one year.  The WGB recommended that Ireland 
strengthen its foreign bribery legislation; consolidate or 
harmonize the foreign bribery offense under the two overlapping 
statutes to remove inconsistencies; expand corporate liability 
for foreign bribery; clarify the scope of the relevant 
legislation for companies; amend its laws to confirm that bribe 
payments are not tax deductible; and ensure that Irish citizens 
and corporations can always be effectively prosecuted for 
foreign bribery offenses committed outside Ireland by promptly 
establishing nationality jurisdiction under the Prevention of 
Corruption (Amendment) Act 2001. 
 
JAPAN SELF-ASSESSMENT 
 
¶7. (SBU) The Chairman noted that the main difficulty with 
Japan's Phase 2 examination was whether the system was geared to 
generate cases and whether one could effectively initiate an 
investigation.  Japan conducted a self-assessment to determine 
legal and procedural impediments to the effective investigation 
and prosecution of foreign bribery.  Japan had established an 
inter-agency task force, which met 12 times, and held 
consultations with experts, prosecutors and police.  The GOJ 
concluded the greatest obstacles were inadequate investigative 
leads, the lack of reliable whistle-blowing information, 
insufficient responses from Mutual Legal Assistance (MLA) 
requests, limited information on investigative methods used by 
other countries and insufficient foreign language abilities. 
 
 
The Japanese del noted authorities needed to disseminate 
information about the foreign bribery offense more widely, more 
fully grasp the state of internal auditing and internal control 
systems, and raise awareness regarding the Japanese 
whistle-blower law that went into effect in June 2005. 
 
¶8. (SBU) The Japanese delegation committed to raise awareness of 
whistle-blower protection, utilize MLA requests early and 
actively, conclude bilateral MLA agreements, actively use 
voluntary investigative measures at the earliest possible stage 
and exchange information among police, prosecutors, experts and 
civil society.  The Japanese del suggested greater focus on the 
prevention of foreign bribery is appropriate, commenting that 
cases and convictions were not the only criteria of success. 
The Japanese del noted that a potential foreign bribery case 
involving Japanese firm Kyudenko's activities in the Philippines 
was under investigation. 
 
¶9. (SBU) Lead examiners United States and Italy applauded Japan 
for completing the self-assessment.  The US noted that Japan's 
passive approach to investigation and emphasis on maintaining 
secrecy at the sacrifice of advancing cases needed to be 
addressed.  Not only did the placement of the foreign bribery 
offense in the Unfair Competition Prevention Law (UCPL) rather 
than in the Criminal Code appear to reduce awareness, but the 
entities responsible for pursuing investigations (Ministry of 
Economy, Trade and Industry (METI) and Ministry of Justice 
(MOJ)) provided conflicting guidance.  The U.S. also highlighted 
that the whistle-blower law did not apply to employees of 
Japanese companies based overseas.  The principal recommendation 
of lead examiners was on-going consultation and monitoring of 
Japan's enforcement efforts.  The Italian lead examiner echoed 
US comments, and urged Japan to bring a case and build 
experience in how to start prosecutions.  He also noted that the 
GOJ had shared no information about the Kyudenko case until 
reports had appeared in the press. 
 
¶10. (SBU) The Japanese del responded that the GOJ has been 
proactive in ordering Japanese representations abroad to report 
foreign bribery allegations, that prosecutors are trying to 
identify evidence and have added enhanced MLA efforts, and 
defended the Japanese emphasis on secrecy to avoid destruction 
of evidence by suspects.  In the 6 months since the 
whistle-blowing law had been enacted, 2,000 reports had been 
made, but the Japanese del conceded it needed to raise awareness 
about the protection offered.  The Chairman commented that the 
key issue appeared to be how Japan can develop an allegation 
into a filed case. 
 
PHASE 2 FOLLOW-UP REPORTS 
 
¶11. (U) Within one year of the WGB's approval of the Report of 
Phase 2 Examination, countries must, at a minimum, provide an 
oral report on steps they have taken or plan to take to 
implement the WGB's priority recommendations.  A detailed 
written follow-up report must be provided within two years. 
 
JAPAN WRITTEN FOLLOW-UP 
 
¶12. (SBU) Lead examiners U.S. and Italy reported that Japan had 
complied with many Phase 2 recommendations.  Japan reported it 
had reformed the UCPL to extend statutes of limitation, 
requested MLA on two occasions, raised awareness of foreign 
bribery, including of amendments to the corporate tax law and 
income tax law expressly denying tax deductibility of bribes to 
foreign public officials, and distributed amended 2007 
Guidelines to prevent foreign bribery.  The WGB found that Japan 
had not implemented: 
 
- Rec. 1(iv) to raise awareness of foreign bribery among the 
legal profession; and 
 
 
- Rec. 5(c) to clarify that UCPL prohibits all cases where a 
foreign public official directs transmission of benefit to a 
third party. 
 
The WGB found that Japan had partially implemented a number of 
recommendations, including: 
 
- recommendation in preamble to Phase 2 recommendations re: 
assessing impediments to effective investigation and 
prosecution, make use of MLA at non-"filed" investigative stage, 
increase law enforcement coordination and address difficulties 
encountered in establishing and enforcing territorial 
jurisdiction; 
 
- Rec. 2(b) for METI to establish a formal system to effectively 
process allegations of foreign bribery 
 
- Rec. 2(d) on improving whistle-blower protection for those 
reporting directly to law enforcement authorities; 
 
- Rec. 3(a) to ensure all activities under article 8.1 of the 
Convention are prohibited, including off-the-books accounts. 
 
 - Rec. 5(b) to ensure METI guidelines on facilitation payments 
conform to the Convention and Commentaries. 
 
The WGB found that Japan had satisfactorily implemented other 
specific recommendations, but some follow-up recommendations had 
not been the subject of sufficient practice and required 
continued follow-up. 
 
¶13. (SBU) The WGB agreed that, in order to continue moving this 
positive process forward, Japan should provide a Phase 2 bis 
follow-up report in one year.  This will allow Japan and lead 
examiners to consult and exchange views on progress being made 
and for a brief report to the WGB.  The WGB agreed that both the 
written follow-up and the self-assessment would be published, 
along with a summary of the discussion. 
 
U.K. WRITTEN FOLLOW-UP 
 
¶14. (SBU) The WGB found that the UK had implemented a number of 
the WGB Phase 2 recommendations, but failed to enact 
comprehensive foreign bribery legislation.  The U.K. had no 
foreign bribery prosecutions and its decision to drop the BAE 
Systems plc investigation relating to Saudi Arabia highlighted 
WGB concerns.  The WGB found that the UK had made progress since 
its March 2005 Phase 2 examination in raising awareness (e.g. 
appointment of a UK anti-corruption coordinator); in continuing 
to encourage Overseas Territories to adopt anti-bribery 
legislation (UK verified compliance of Guernsey's legislation 
with the Convention and Jersey's enactment of a foreign bribery 
statute, but not yet extended the Convention to either island); 
in providing additional resources to facilitate MLA and in 
increasing capacity to investigate allegations of foreign 
bribery (e.g. new Metropolitan Police/City of London Police unit 
investigating foreign corruption allegations).  Since March 
2005, the Serious Fraud Office (SFO) had launched 6 new 
investigations and had worked on 23 vetting files in an attempt 
to develop enough information to open a case file.  The UK del 
expressed its optimism that its first foreign bribery 
prosecution could be launched in 2007. 
 
¶15. (C) The UK del claimed its existing law implemented the 
obligations of the Convention, but noted the UK remains 
committed to fundamental reform of its bribery laws.  A Home 
Office consultation report had concluded that no consensus 
existed for moving forward a draft 2003 bill to enact 
comprehensive corruption legislation.  The issue has been 
referred to the Law Commission, which was expected to prepare a 
 
new draft bill within 18 months.  WGB lead examiners France and 
Canada underscored that 6 years had passed since the Phase 1 
examination recommended the UK enact comprehensive foreign 
bribery legislation.  France noted this delay sent a negative 
message regarding the UK's commitment to implement the 
Convention as a whole. 
 
¶16. (C) US del said the UK position that current legislation is 
adequate to effectively implement the Convention was rebutted by 
concrete evidence that it was not.  US del also noted that the 
WGB should ask the UK to do what it had asked Japan to do: 
identify the structural problems that have prevented cases from 
moving to indictment.  The Chairman commented that the WGB had 
long been doubtful regarding the UK's reliance on its 
principal-agent element of bribery.  The UK del noted that 
evidentiary problems raised by some UK officials regarding the 
BAE/Saudi investigation gave a distorted view of the 
deficiencies of UK law, calling the Saudi case "wholly unusual, 
if not exceptional" given the involvement of an absolute 
monarchy. 
 
¶17. (U) The WGB found that the UK had failed to implement: 
 
- the recommendation in the preamble to the Phase 2 to enact at 
the earliest possible date comprehensive foreign bribery 
legislation; 
 
- Rec. 3(a) to proceed with adoption of reforms clarifying and 
unifying UK accounting legislation with IAS to ensure fraudulent 
accounting offense is in full conformity with Article 8 of the 
Convention; 
 
- Rec. 5(a) to amend where appropriate the Code for Crown 
Prosecutors, the Crown Prosecution Manual and other documents to 
ensure investigation and prosecution of foreign bribery is not 
influenced by considerations of national economic interest, the 
potential effect upon relations with another state or the 
identity of the natural or legal persons involved (Article 5 of 
Convention); and 
 
- Rec. 5(c) to broaden the level of persons engaging the 
criminal liability of legal persons for foreign bribery. 
 
The WGB also concluded that the UK had partially implemented 9 
recommendations and satisfactorily implemented 8 
recommendations. 
 
¶18. (U) Following a further discussion of the BAE/Saudi 
investigation (see below), the WGB agreed that it would conduct 
a Phase 2 bis review of the UK focused on progress in enacting a 
new foreign bribery law and in broadening liability of legal 
persons for foreign bribery, examining whether systemic problems 
explain the lack of foreign bribery cases brought to prosecution 
and addressing other issues raised by the discontinuance of the 
BAE/Saudi Arabia investigation.  The review will include an 
on-site visit to be conducted by March 2008. 
 
¶19. (C) An extensive discussion of how the WGB would make public 
this decision followed.  The UK stridently objected to any 
engagement with the media by the Chair regarding the review and 
asked that only a WGB press release be issued.  The Secretariat 
argued that OECD practice is to be as open as possible with the 
media, while respecting the confidential nature of the 
discussions.  After many delegations expressed confidence in the 
Chair, the WGB agreed to allow the Chair to brief the press, 
accompanied by OECD Legal staff and the director of the 
Financial and Enterprise Affairs Directorate.  Bilateral 
interview requests made in the following several days would be 
referred to the Secretariat. 
 
TERMINATION OF BAE/SAUDI ARABIA INVESTIGATION 
 
 
¶20. (C) Lead examiner France noted a number of issues were still 
outstanding regarding the BAE/Saudi Arabia investigation, 
including the materiality of the UK's national security 
rationale.  Lead examiner Canada said it accepted the 
explanations given by the UK for reasons for discontinuing the 
investigation, but had serious concerns about the UK's legal 
framework and adequacy of its corporate criminal liability 
legislation.  US del asked whether the UK could provide any 
assurances that BAE was not continuing to make corrupt payments 
to Saudi officials and that MOD officials were not continuing to 
participate in the alleged corrupt payments.  The U.S. also 
asked about evidence preservation and whether UK national 
security concerns would pose an impediment to providing MLA to 
other states. 
 
¶21. (C) The UK del, which included Foreign and Commonwealth 
Office, SFO, Ministry of Defense Police, Department for 
International Development, Metropolitan Police and office of the 
Attorney General (AG) officials, reported that the SFO was 
reviewing the aftermath of the decision to discontinue in light 
of its duty to ensure that the MOD Police, Export Credit 
Guarantee Department (ECGD) and other bodies received all 
relevant information to help them carry out their public duties. 
 The UK del advised that since no one has been charged and found 
guilty, there are limitations on actions the UK government can 
take and other fora must accept their responsibilities in 
considering the case.  The UK del advised that no evidentiary 
material would be returned until the judicial review has run its 
course.  The SFO did not see a reason why national or 
international security would prevent the UK from responding to a 
request for MLA. 
 
¶22. (C) The Chairman inquired further into the reasons for 
discontinuance and asked whether the WGB should not deplore a 
threat by a sovereign state to stop fundamental cooperation, if 
Saudi threats to stop counter-terrorism cooperation were the 
basis of the national security interests involved.  He inquired 
about how precise Parties must be in identifying risks and the 
immediacy of danger posed before invoking national security. 
The UK del advised that the SFO Director had considered only 
national and international security grounds in reaching his 
decision to discontinue the investigation.  The judicial review 
would address whether the decision-making process was valid and 
whether the decision was in conformity with Article 5 of the 
Convention.  The Swiss del noted that it continued to be very 
concerned about the effect of the UK decision, that it implied 
that the UK would not prosecute allegations of foreign bribery 
by its firms in Saudi Arabia, depriving other parties of a level 
playing field there and possibly in other countries. 
 
¶23. (C) In response to an OECD legal advisor's inquiries whether 
the UK recognized international public policy and public 
interest factors in favor of prosecution, the UK del (AG rep) 
confirmed that the UK recognized that bribery was contrary to 
international public policy and that the nature of bribery as an 
offense was a powerful factor for prosecuting the act.  In the 
BAE/Saudi matter, however, he advised that the SFO Director had 
considered protecting national security an even more important 
factor.  The UK AG shared this view, and also considered that 
the case was unlikely to lead to successful prosecution. 
Regarding the basis for identifying the national security risk, 
the UK del said the UK ambassador to Saudi Arabia had considered 
the risk that Saudi Arabia would withdraw counter-terrorism 
cooperation to be real and that all who expressed views had 
shared that assessment, including the UK's security services. 
In response to an OECD legal advisor's query about whether the 
ECGD had the right to refuse to provide official support to BAE 
Systems in the future in light of the allegations in this case, 
the UK del said it could not speak for the ECGD, which had its 
own duties to implement anti-corruption policies and the right 
 
to insist that BAE Systems provide due diligence information. 
 
¶24. (C) US del stressed the difficulty in assessing from the 
outside the factors taken into account in the UK's decision. 
While concerns remained about the particular case, more critical 
was what the case had revealed regarding the UK's legal 
framework for preventing foreign bribery.  As the Convention 
approaches its tenth anniversary, the WGB must demand that all 
parties meet their obligations and maintain high standards.  The 
French del spoke of the need to convey a clear message to the 
business community and civil society that payment of bribes to 
foreign public officials was no longer an acceptable competitive 
advantage.  The Canadian del agreed that abandonment of the 
investigation created a problem for the Convention.  Following a 
discussion which frequently underscored the need to defend the 
Convention, and which weighed the merits of various next steps, 
France, Italy, New Zealand Greece, Chile, Germany, Ireland, the 
Netherlands, Sweden, Spain, Turkey, Switzerland, and the US del 
all expressed continuing serious concerns about the UK's 
decision and spoke in favor of the WGB (1) issuing a strong 
statement to the public relaying those concerns and (2) 
conducting a Phase 2 bis review of the UK focused on Convention 
implementation.  Although Germany and Canada expressed a 
preference for waiting until the results of the UK domestic 
judicial review, a position strongly favored by the UK, WGB 
consensus ultimately opposed such a delay. 
 
SWITZERLAND WRITTEN FOLLOW-UP 
 
¶25. (SBU) Switzerland reported that its Phase 2 examination had 
contributed to greater awareness of its obligations under the 
Convention and had spurred long-term cooperation among federal 
and cantonal-level authorities, the Swiss business community and 
civil society.  Switzerland reported that 23 foreign bribery 
cases were initiated in 2005 and 2006, of which 17 were in 
connection with the UN Oil for Food program.  A total of 19 
cases were still in the investigative stage and four were 
closed.  No charges were pressed nor rulings handed down during 
the period.  Informed by comments from lead examiners Hungary 
and Belgium, the WGB found that Switzerland had taken efforts to 
raise awareness, but further measures targeted at small and 
medium-sized enterprises and cantonal-level authorities were 
required to fully implement WGB recommendations.  Switzerland 
had fully implemented: 
 
- Rec. 3(a) to consider establishing a formal obligation for any 
federal authority, civil servant or public official to report 
indications of possible bribery to authorities and 
 
- Rec. 3(d) to consider extending mandatory reporting 
obligations for auditors to report to prosecutorial authorities 
evidence of possible corrupt practices by those whose accounts 
they audit if executive bodies refrain from taking action. 
 
¶26. (U) Discussion of Switzerland's follow-up report revealed 
certain difficulties encountered by the WGB in distinguishing 
between full and partial implementation of recommendations and 
highlighted the need for precision in recommendation text.  In 
several instances Switzerland had taken action in response to 
recommendations, but measures had not yet been finalized. 
Switzerland contended it had nonetheless fully implemented the 
recommendations.  The WGB ultimately found that Switzerland had 
only partially implemented the remaining 8 recommendations. 
 
REVISION OF ANTI-BRIBERY INSTRUMENTS: DRAFT MANDATE FOR 
SUB-GROUPS 
 
¶27. (U) The WGB agreed that Chairman Pieth and Vice-Chair 
Gavouneli would serve as chairs of two ad hoc sub-groups on (1) 
criminalization and (2) prevention issues, involving areas such 
as export credit, official development assistance, public 
 
procurement, auditing and non-tax deductibility.  The sub-groups 
are to be open and informal and their task will be to assist the 
WGB in completing proposed revisions to anti-bribery instruments 
by December 2007.  This would include likely revision of the 
1997 Revised Recommendation (requiring approval by the OECD 
Council) and possible clarification in Commentaries regarding 
interpretations of the Convention. 
 
TOUR DE TABLE DEFERRED 
 
¶28.  (U) The WGB deferred reviewing country enforcement actions 
on foreign bribery and UN Oil-for-Food cases to June, given the 
press of other agenda items. 
 
OUTREACH ACTIVITIES 
 
¶29. (U) The Secretariat briefed on outreach activities, 
including the anticipated signature in April of a Memorandum of 
Understanding with the Organization of American States to 
strengthen the fight against corruption in the Americas.  The 
Secretariat also agreed to provide suggestions on next steps for 
 
SIPDIS 
WGB outreach to China. 
 
ANNUAL REPORT 
 
¶30. (U) The WGB approved the 2006 draft annual report, after 
agreeing to a UK request to delete a reference to the BAE/Saudi 
investigation.  US del noted that there was nothing 
inappropriate with the proposed reference, but did not object to 
its deletion.  The French del noted that reference should be 
included in the 2007 Annual Report. 
 
OTHER ITEMS 
 
¶31. (U) The Italian delegation briefed on the invitation by the 
Government of Italy to hold a Prosecutors' Meeting in Rome in 
November as part of an event marking the 10th anniversary of the 
Convention in November or December 2007, which may involve 
ministerial participation. 
 
¶32. (U) The Netherlands del noted that differences in WGB 
Parties' positions regarding UNCAC issues have complicated UNCAC 
implementation.  They proposed including an agenda item for the 
October WGB plenary meeting to exchange ideas about how to 
organize in preparation for the second UNCAC Conference of State 
Parties. 
 
¶33. (U) The US del suggested, with support of Dutch and Swiss 
colleagues, that prosecutors plan to meet on the margins of the 
June plenary for a brainstorming session to discuss the 
usefulness of a prosecutors' forum.  The UK requested that this 
be scheduled for the same day as the Tour de Table to facilitate 
attendance.  The Chair suggested that the prosecutors also 
provide guidance to the Italian delegation regarding the agenda 
for the 10th anniversary event. 
 
¶34. (U) The June WGB plenary meeting will take place June 19-21, 
¶2007.  (Ad hoc sub-groups were subsequently scheduled to meet on 
June 18.) 
MORELLA