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

    Transport Logistics International Enters into Three Year DPA with DOJ; Must Pay $2MM Criminal Fine

    On 12 March 2018, Transport Logistics International Inc. (TLI) entered into a three year DPA with the DOJ, requiring TLI to pay a criminal fine of USD 2,000,000. The co-Presidents of TLI – Daren Condrey and Mark Lambert – are alleged to have conspired to violate the FCPA by paying USD 2,000,000 in bribes to Vadim Mikerin, a Russian official who worked for a subsidiary of Russia’s State Atomic Energy Corporation, in exchange for the award of uranium transportation contracts to TLI.

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

    SEC Issues Cease-and-Desist and USD 500,000 Civil Penalty Order to Elbit Imaging Ltd.

    On 09 March, 2018, the SEC issued an administrative order with the consent of Elbit Imaging Ltd., an Israel-based holding company—to conclude its investigation into the company’s alleged FCPA violations, without admitting or denying findings. The SEC ordered Elbit to cease and desist from committing any future violations of Sections 13(b)(2)(A) & (B) of the Exchange Act and to pay a USD 500,000 civil penalty. The SEC stated that it was willing to accept Elbit's settlement offer due to Elbit’s self-reporting, prompt remedial efforts, cooperation with the SEC's investigation, and the fact that Elbit is in the process of winding down and not currently developing new business.

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