Bribery and corruption involving public officials have been on the international policy agenda for decades. Corrupt practices within and between enterprises (“private-to-private corruption”), on the other hand, have only recently emerged as an area of concern. Private-to-private corruption’s harmful effect on the business and investment climate, and on the public interest more generally, is increasingly acknowledged—especially as private enterprises provide more public services. The inclusion of a non-mandatory offense of private-to-private corruption in the UN Convention against Corruption testifies to the global recognition of the increasing importance of tackling private-to-private corruption.