The difficulties associated with managing and surviving a hostile operating environment has weakened commitment to ethical operating standards. In a major survey Ernst & Young notes that the marked increase in corporate tolerance for unethical practice coincides with what its terms an extremely aggressive enforcement environment. That environment is far from uniform, notwithstanding global commitment to the OECD Convention on Anti-Bribery and Corruption. The United States remains, by far, the most influential jurisdiction in prosecuting economic crime, notably through the application of deferred prosecution agreements. Now the United Kingdom intends to transplant the approach, with refinements, to address the lack of judicial oversight. It remains, however, unclear whether the refinement will necessarily either address the accountability deficit or prove more efficacious in ensuring more substantive compliance. The paper evaluates the strengths and pitfalls of negotiated prosecution and assesses the dangers of using creative enforcement to combat economic crime.