Compendium

Compendium

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.  

    Cognizant reaches US$25 million settlement with SEC to resolve FCPA Offenses

    Cognizant Technology Solutions Corporation (“Cognizant”) reached a US$25 million settlement with the SEC via a consensual cease-and-desist order to resolve violations of the anti-bribery, books and records, and internal accounting controls provisions of the FCPA. The violations stem from a 2014–2016 bribery scheme in which Cognizant executives in the United States and India authorized third parties to pay approximately US$3.6 million in bribes on Cognizant’s behalf to Indian government officials.

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