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

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.

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

Las Vegas Sands Corp. to Pay US $6.9 Million Penalty to Resolve U.S. Bribery Charges

On 19 January 2017, Las Vegas Sands Corp. (“LVSC”) agreed to pay US $6.9 million to the U.S. Department of Justice to resolve allegations that the company violated the U.S. Foreign Corrupt Practices Act by providing US $60 million to a Chinese consultant despite a lack of due diligence and documentation and repeated warnings about the risk of working with the consultant. Attempts to conduct due diligence or audits allegedly were thwarted by the consultant, aided by executives at LVSC and one of its subsidiaries. This settlement follows one the company made with the SEC in April 2016.

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

Corruption and Commerce: The Costs and Benefits of Policing International Markets

Good morning, ladies and gentlemen. I am delighted to start the second panel this morning of the Council on Foreign Relations workshop on the intersection of corruption and U.S. national interests. Today I will be leading the second panel, which is going to deal...