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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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

    Analogic Corporation and its Danish Subsidiary Enter Settlements with SEC and DOJ, Agree to Pay Nearly $15M in Disgorgement, Interest, and Penalties

    On June 21, 2016, the Department of Justice announced a settlement and non-prosecution agreement with BK Medical ApS, a Danish manufacturer of medical ultrasound equipment, in which the company acknowledged participation in a decade-long illicit-payment scheme in Russia and elsewhere. The Securities and Exchange Commission also announced a civil settlement with BK Medical’s parent company, Massachusetts-based Analogic Corporation, and with BK’s former Chief Financial Officer.

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


    Two SEC Non-Prosecution Agreements Announced Following Self-Reporting of Subsidiaries' Bribery.

    On June 7, 2016, two companies entered into non-prosecution agreements (“NPAs”) with the Securities and Exchange Commission in connection with bribery schemes carried out by subsidiaries in China. Each company had identified and self-reported the schemes to the SEC and the Department of Justice.

    The complete Compendium summaries for these cases may be accessed here and here.

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    ‘On balance, the public interest in transparency far outweighs the rights of those hiding, for whatever reasons, behind secret or shell companies.’ TRACE President Alexandra Wrage discusses a reasoned response to the Panama Papers on the SCCE Compliance and...
    Recent News Feed 4/27/2016 12:00:00 AM Read More
    ‘The lifting of sanctions creates opportunities for the maritime industry, but compliance and due diligence challenges linger for vessel owners and operators seeking to trade their vessels to and from Iran.’ TRACE President Alexandra Wrage discusses the...
    Recent News Feed 4/26/2016 12:00:00 AM Read More
    TRACE International, the leading global anti-bribery standard setting organization, recently published the third in its biennial How to Pay a Bribe: Thinking Like a Criminal to Thwart Bribery Schemes series. The collection offers an insider’s view on how bribery and...
    Recent News Feed 4/20/2016 12:00:00 AM Read More
    “Due diligence is an ongoing process and requires constant, ongoing communication; it’s a tool, not an end in itself." TRACE President Alexandra Wrage comments on lessons that can be learned from the Unaoil bribery scandal with respect to due diligence. To read...
    Recent News Feed 4/19/2016 12:00:00 AM Read More
    Follow the 19-part TRACE Advantage series on EDC ExportWise to learn about business bribery risk in different regions. New content will be posted every Friday. To view the series, click here.
    Recent News Feed 4/15/2016 12:00:00 AM Read More
    The Unaoil story first published by The Age and Huffington Post on March 30, and supplemented yesterday with another chapter, has it all. There are code names, huge dollar amounts and intrigue.
    There have since been raids on the company’s offices by the Monaco...
    Recent News Feed 4/12/2016 12:00:00 AM Read More
    The international business community wins when companies across supply and marketing chains work to the same high standards. There is less risk and more predictability, which promotes confidence among business partners. Benchmarking among peers and establishing and sharing...
    Recent News Feed 3/28/2016 12:00:00 AM Read More
    Corporate Compliance is a hot topic nowadays in Romania since private companies have an increasing interest in developing policies and procedures which are meant to protect them from potential situations of waste, fraud, and abuse, either intentional or unintentional. The...
    Recent News Feed 3/25/2016 12:00:00 AM Read More
    Discussions in the compliance community can get pretty technical. Conferences focus on jurisdictional issues, appropriate levels of third party due diligence, sufficiency of internal controls and the best types of risk management tools. But a bribe is ultimately just a...
    Recent News Feed 3/24/2016 12:00:00 AM Read More
    Today,TRACE International, the leading global anti-bribery standard setting organization,published the third in its biennial How to Pay a Bribe series. The collection offers an insider's view on how bribery and corruption impact international business, making it an...
    Recent News Feed 3/15/2016 12:00:00 AM Read More
    Severin Wirz, Director of Member and Advisory Services, comments on trends in global anti-bribery enforcement in this guest post for Compliance Week.
    "To be sure, enforcement data is an important tool for companies to understand their anti-bribery regulatory risks. But...
    Recent News Feed 3/10/2016 12:00:00 AM Read More
    "TRACE International today announced the findings of its sixth annualGlobal Enforcement Report (GER), noting that the number of U.S. enforcement actions concerning bribery of foreign officials has increased slightly from the previous year, though there was a slowdown in the...
    Recent News Feed 3/9/2016 12:00:00 AM Read More
    "International anti-bribery cases dropped by 73% last year, according to a report out Wednesday, putting the U.S. back in the driver’s seat of international enforcement." To continue reading this post on the Wall Street Journal Risk & Compliance Journal, click...
    Recent News Feed 3/9/2016 12:00:00 AM Read More
    "The extraction industries saw the brunt of bribery enforcement actions in 2015, but the manufacturing/service providing industry faces more U.S.investigations, according to a new report fromTRACE International, a provider of anti-bribery compliance services."Continue...
    Recent News Feed 3/9/2016 12:00:00 AM Read More
    Today, TRACE International, the leading global anti-bribery standard setting organization, named Intel the winner of the 2016 TRACE Innovation in Anti-Bribery Compliance Award (IACA) for the development of path-breaking educational methods.Read the complete press release...
    Recent News Feed 3/3/2016 12:00:00 AM Read More
    Click here to read comments from Patrick Stokes, head of the Justice Department’s FCPA unit, at the Annual TRACE Forum in D.C. on the Wall Street Journal Risk & Compliance Journal blog.
    Recent News Feed 3/3/2016 12:00:00 AM Read More
    ‘Amidst the amusing anecdotes, there’s a very real collapse of leadership, especially with respect to creating a culture of compliance.’ TRACE President Alexandra Wrage discusses 5 leadership lessons from the FIFA scandal. Read the full article here.
    Recent News Feed 2/29/2016 12:00:00 AM Read More
    ‘FIFA will continue to be FIFA and the game, it’s fans, players and clubs will continue to be exploited.’ TRACE President Alexandra Wrage discusses the election of Gianni Infantino as the new FIFA president. Read the full article on Forbes here.
    Recent News Feed 2/27/2016 12:00:00 AM Read More
    As a three-time winner of the Top 100 Women award, Alexandra Wrage joins the Daily Record'sCircle of Excellence. To view the complete list of winner, click here.
    Recent News Feed 2/26/2016 12:00:00 AM Read More
    "The U.S. Department of Justice and the Securities and Exchange Commission (SEC) are no longer the only two cops on the global anti-corruption beat," writes Alexandra Wrage, TRACE President, in this article published on Corporate Knights. To continue reading, click here.
    Recent News Feed 1/8/2016 12:00:00 AM Read More
    "Shipping is a huge and crucial industry. As Rose George, author of Deep Sea and Foreign Going says 'Without ships, half of the world would freeze and the other half would starve.'
    It is also a largely opaque one.  As pirates have known for millennia, the high seas are...
    Recent News Feed 12/2/2015 12:00:00 AM Read More