To date, “transnational criminal law” has been the dominant paradigm for explaining and mapping rules on corruption in the international legal literature. This Chapter details the limits of transnational criminal conceptions of “anticorruption” through a study of nascent changes to Australian corporate foreign bribery law. Drawing on primary and secondary documentary sources, it shows that the proposed (but for now lapsed) reforms are only partially transnational, as that term is understood in “TCL” theory. Likewise, multilateral suppression conventions and related soft laws were but one impetus for the suggested amendments. Rather, as the transnational legal ordering literature suggests, a recursive process appears to have been at work between international organizations and local legislators, as well as transnational non-state actors. This process was marked, it seems, by moments of borrowing from the US and UK. However, it was also punctuated by themes of modernization, efficiency, and reputation. In addition, if settled, the amendments would result, not just in changes to national criminal law, but also the extension of “new” – and controversial – techniques of governance.