The FCPA Blog is a valuable resource for anyone who tracks FCPA and anti-corruption issues. It recently posted an entry about the UK's Serious Fraud Office's welcome but late efforts on the anti-corruption front. You can find the entry at
http://fcpablog.blogspot.com/2009/08/here-comes-sfo-part-two.html.
Take a look at what they are looking for in a compliance program. It's remarkable how much of it is what would be expected in a US-style program.
I'm not pointing this out to crow about a US victory but to celebrate the birth of common thinking.