The Serious Fraud Office says it is steadfast in its commitment to tackle foreign bribery, but it has not resulted in a single prosecution.
The OECD Working Group on Bribery said New Zealand must strengthen foreign bribery detection as well as its corporate liability framework for foreign bribery.
Its report says there had been progress in law reform, but there had not been a single prosecution of a foreign bribery case, and detection levels are low.
Transparency International chief executive Julie Haggie said there was a problem with the implementation of New Zealand's law.
"Considering the amount of business that our businesses are doing overseas and number of countries we interact with, it's just unbelievable that we're not encountering foreign bribery in some way," Haggie said.
"The last time the (OECD) gave us a kick at the bum in 2013 we did respond in terms of law, but not necessarily in terms of how we implemented that law. So this is our challenge now to do both."
SFO and Ministry of Justice officials said they would carefully consider the recommendations made in the report, before deciding how to best implement them.
Ministry general manager of criminal justice policy Alida Mercuri said the OECD's evaluation confirmed New Zealand's commitment to address the bribery issue.
"We recognise that the convention is a key tool in fighting the insidious criminal activity of bribery," Mercuri said.
"Like many countries, we still face challenges when it comes to detecting foreign bribery carried out by New Zealand-based companies.
"The Working Group has made a range of recommendations, which the government will carefully consider before deciding how best to implement them."
SFO director Karen Chang said the report highlighted the office's investigative and prosecutorial model as being a notable example of good practice.
"Other examples cited as good practice in New Zealand were the extension of whistleblower protections to a range of third parties, and accessible court judgement databases," Chang said.
The SFO and NZ Police also worked with global networks such as the International Anti-Corruption Coordinations centre and International Foreign Bribery Taskforce, alongside domestic partnerships with information-sharing agreements with the IRD.
"Awareness is key to combating foreign bribery," Chang said.
"In the public sector, our prevention efforts focus on enhancing systems and controls to reduce vulnerabilities, equipping agencies with tools to identify risks, and promoting ethical leadership."
She said the safeguards reinforced trust in "government institutions as pillars of integrity."