The TRACE Compendium is a user-friendly and fully searchable database of comprehensive, yet succinct, summaries of international anti-bribery enforcement actions. Most actions included in the TRACE Compendium are Foreign Corrupt Practices Act (“FCPA”) enforcement actions brought by the U.S. Department of Justice (“DOJ”) and/or the U.S. Securities and Exchange Commission (“SEC”). However, the TRACE Compendium also includes the growing number of international anti-bribery enforcement actions brought by enforcement authorities outside of the United States, particularly amongst signatories to the OECD Anti-Bribery Convention.

Enforcement activity included in the TRACE Compendium share two characteristics: first, the conduct at issue – the bribery – must cross an international border; second, the bribery must be of a government official.  Domestic anti-bribery investigations and enforcement matters involving commercial bribery purely between private parties are not included in the TRACE Compendium.

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    TRACE Compendium Alert

    MTS Reaches US$850 Million FCPA Resolution with DOJ and SEC

    Russian telecommunications company Mobile Telesystems PJSC (“MTS”) resolved SEC and DOJ FCPA enforcement actions stemming from violations of the anti-bribery, books and records, and internal accounting controls provisions of the FCPA. 

    The complete Compendium summary for this case may be accessed here.  


    Telefônica Brasil Resolves FCPA Violations with SEC, Agrees to Pay US$4.125 Million

    Telefônica Brasil reached a settlement with the SEC with respect to allegations that the company had provided numerous Brazilian government officials, both federal and local, with free tickets to the 2014 World Cup and the 2013 Confederations Cup.

    The complete Compendium summary for this case may be accessed here.