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

    Halliburton settles with SEC over FCPA allegations

    Nearly six years after formally disclosing its internal investigation into potential FCPA violations in connection with its operations in Angola, the Halliburton Company and a former officer have entered into settlement agreements with the Securities and Exchange Commission, consenting to the agency’s entry of a cease-and-desist order on 27 July 2017

    Access the complete Compendium summary for this case.

    CDM Smith Inc. to disgorge more than US$4 million to U.S. Department of Justice

    On 29 June 2017, CDM Smith Inc., headquartered in Boston, Massachusetts, agreed to disgorge US$4,037,138 to the U.S. Department of Justice (“DOJ”), representing the net profits from an bribery scheme allegedly carried out in connection with its India subsidiary, CDM Smith Global Services Pvt. Ltd. Between 2011 and 2015, employees of CDM Smith and its subsidiary allegedly obtained contracts by paying bribes (generally 2-4% of the contract price) to officials at India’s state-owned highway management agency. The bribes were paid through fraudulent subcontractors who provided no actual services. An additional USD 25,000 was allegedly paid to local officials in Goa in connection with a water project contract.

    Access the complete Compendium summary for this case.