Corruption in the private sector: the convergence of legal systems

Corruption in the private sector is an interdisciplinary issue covering international law, criminal law, civil law and disciplinary law. One of the key difficulties is the broadness of the concept of corruption in the private sector. The broad definition actually fits all branches of the aforesaid laws. Therefore, one must draw some guiding (yet, simplified and relative) criteria according to which the convergence of legal systems could be possible. One of the criteria is harm, damage or dangerousness. Another criteria come from ECHR case-law: the nature of offence and the nature of sanction entrenched in a certain legal system. Considering such criteria, it can be decided what legal system(s) should be applied to tackle corruption in the private sector. Key words: Corruption, private sector, damage, ultima rati