As Western corporations continue to expand internationally in search of natural resources and greater economies of scale, they increasingly find themselves operating amidst the political unrest and social conflict that afflicts many developing nations. In such contexts, multinational enterprises often turn a blind eye to human rights abuses, and in the worst cases, become active participants. As a result, many have called for a global system of corporate governance. This Note focuses on the OECD’s framework for influencing corporate behavior internationally: the “OECD Guidelines for Multinational Enterprises.” After explaining the mechanics of the Guidelines, this Note provides a critical analysis of the United States’ implementation by comparing U.S. methods with those of two other adherent states—the Netherlands and France. Ultimately, the Note concludes that U.S. practices leave much room for improvement and offers suggestions for a more robust imple-mentation of the Guidelines.