most recent Commission Rule of Law Report has underscored 1this would not answer the sudden increase of EU anti-corruption law in the last decade. II. Situating the EU anti-corruption law in the international sphereSince the 1990s, anti-corruption regulations have been the norm in the international sphere.The OECD Anti-Bribery Convention, 2 the United Nations Convention Against Corruption, 3 regional agreements such as the Council of Europe Conventions against Corruption, 4 the wide scope of implementation of the US Foreign Corrupt Practices Act 5 and countless democracy promotion programs, 6 have made anti-corruption one of the primary elements of good governance programs around the world.This regulatory flow has been accompanied by a reconceptualisation of corruptionnot merely as a crime, but as a threat to the integrity of legal and institutional orders.7 Corruption replaces lawful interactions between citizens and public officials with illicit ones, undermining the functioning of the legal order itself.While academic debate continues over which public law value corruption harms, it is widely accepted that it disrupts legal systems.8 In response to this threat, thanks to the proliferation of these international and regional tools, anti-corruption has evolved into a kind of "transnational legal order."9 This perspective treats corruption as a structural threat to the rule of law, regardless of scale or whether criminal elements are involved.It aligned with a global shift toward administrative responses to corruption, supplementing traditional criminal enforcement with tools like independent oversight bodies and integrity rules for public officials.10 The tide has, however, recently turned.Decreasing budgets of the international development agencies or, in the case of US Agency for International Development, their dismantling has sent a rippling effect whose impact has not yet been quantified.11 Looking 1 Commission, Rule of Law Report 2025, General Report, 1. 2 Organization for Economic Co-operation and Development,
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