Document Type



In the corporate compliance and anti-corruption domains, international standard-setting is in vogue. Recent years have witnessed a flurry of new compliance standards authored by the International Organization for Standardization (ISO), the world’s leading private standard-setter. ISO claims to offer a more effective way to address transnational corruption risks and related compliance challenges, one that boasts the approval of a global committee of technical experts and enticingly purports to accord with international “best practices.” A number of companies and governments around the world have taken the bait, with many adopting or giving legal effect to ISO’s anti-bribery standard (ISO 37001) in particular.

This Article argues that, despite the theoretical allure of this nascent wave of standard-setting, ISO’s compliance standards are fraught with pitfalls that call into question their practical utility. In effect, companies and governments that adopt them are investing in clickbait compliance, a superficially attractive set of compliance recommendations that overpromise and are likely to underdeliver in many respects. First, a conceptual analysis of ISO 37001 illustrates that such standards are unlikely to function as desired (“clickbait functions”). Second, an examination of ISO’s growing presence in the burgeoning field of compliance reveals that supposed connections or synergies between the organization’s new standards and compliance-related laws, practices, and trends do not meaningfully exist and may not fully materialize (“clickbait connections”). The Article concludes by discussing how ISO’s disjointed, siloed organizational system exacerbates these issues before proposing systemic reforms that would promote a more evidence-based approach to ISO compliance, an approach that may curtail—but will certainly not eliminate — “clickbait” concerns.


William R. Heaston is a Law Clerk, Duane Morris LLP. J.D., University of Pennsylvania Carey Law School (2021); M.S., Department of Legal Studies and Business Ethics, The Wharton School of the University of Pennsylvania (2021); M.A., Centre for the Study of Corruption, University of Sussex (2016); B.A., Drake University (2015).

Publication Date


Included in

Law Commons



To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.