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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Download the TRACE Global Enforcement Report 2015 to view charts and analysis of information found in the Compendium.


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    TRACE Compendium Alert

    JPMorgan Chase to pay US $264 million to Resolve U.S. Bribery Charges 

    On 17 November 2016, JPMorgan Chase & Co. (“JPMorgan”) agreed to pay more than US $264 million in penalties, disgorgement and interest to the Federal Reserve Board of Governors, U.S. Department of Justice and U.S. Securities and Exchange Commission (“SEC”) to resolve allegations regarding its subsidiary JPMorgan Securities (Asia Pacific) Limited (“JPMorgan APAC”). The allegations focused on the company’s misuse of an employment referral program to obtain business by making employment and internship decisions based on referrals by officials at state-owned enterprises (“SOEs”) in China. The allegations included that JPMorgan APAC hired the son of an official at a manufacturing SOE from which it was able to earn net profits of US $32 million; that it hired two employees at the request of officials at a transportation SOE, which awarded the company work worth profits of more than US $10 million; and that it helped the son of a sympathetic Chinese deputy minister get a job at its parent company’s office in New York, despite the son’s unimpressive interview and subsequent poor performance. Altogether, JPMorgan allegedly used this program to refer almost 100 candidates connected to officials of Chinese SOEs for employment or internships with the company.

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

    Embraer S.A. to Pay US $205 Million to Resolve U.S. and Brazil Bribery Charges 

    On 24 October 2016, Embraer S.A. agreed to pay more than US $205 million in penalties, disgorgement and prejudgment interest to the U.S. Department of Justice (“DOJ”), the U.S. Securities and Exchange Commission (“SEC”) and Brazilian authorities to resolve allegations that the company made improper payments to government officials in the Dominican Republic, India, Saudi Arabia and Mozambique related to the purchase of Embraer aircraft. In 2008 Embraer allegedly agreed to pay US $3.52 million to an official of the Dominican Republic to promote the sale of eight Super Tucano airplanes for US $96.4 million. The payment allegedly was made through an agent purportedly retained to assist with sales of aircraft to the Jordanian Air Force, when no such sales or attempted sales were made. When Embraer sold three business jets to a Saudi Arabian state-owned entity for US $93 million in 2010, the company allegedly paid a high-level official at the entity over US $1.5 million, again through an agent. In connection with the 2008 sale of two commercial airplanes to a Mozambique-owned airline, Embraer allegedly paid a high-level Mozambican government official US $800,000 through a designated agent with whom Embraer had never previously worked. And in India, Embraer allegedly misaccounted for payments of US $5.76 million to an agent in connection with the sale of military aircraft to the Indian Air Force for US $208 million.

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

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