TRACE Releases 12th Annual Global Enforcement Report

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16 March 2022 – Annapolis, Md. – TRACE, a globally recognized business association dedicated to anti-bribery, good governance and compliance, today announced the findings of the 2021 Global Enforcement Report, noting that the pace of transnational anti-bribery enforcement actions and investigations lagged worldwide. The report, TRACE's 12th annual compilation, provides anti-bribery enforcement data from 2021 and summarizes 45 years of anti-bribery enforcement activity.

There was a notable slowdown in the number of foreign bribery enforcement actions brought by the United States in 2021, the report found. Enforcement actions by other countries held closer to the average of recent years but did not reverse a longer-term slowdown. Both in the United States and elsewhere, according to available information, there was a drop in the number of open foreign bribery investigations.

“The slowdown in enforcement actions coincides with a continued upward trend in transnational cooperation among enforcement authorities, which has led to coordinated resolutions with substantial penalties in recent years,” TRACE President Alexandra Wrage said. “With a recently renewed focus among G7 countries on prosecuting financial crime, especially corruption and kleptocracy, we expect enforcement authorities to maintain very high expectations for companies’ compliance programs.”

The Global Enforcement Report also examines industry and regional trends. U.S. enforcement agencies in 2021 continued to focus largely on the extractives, financial services, engineering/construction, and manufacturing/services industries in open investigations and enforcement actions. Notably, Brazil surpassed China as the most active non-U.S. jurisdiction in bringing enforcement actions for domestic bribery from foreign companies.

Read the report at

About the Global Enforcement Report

TRACE's Global Enforcement Report provides graphic and textual analyses of all known investigations and enforcement actions involving transnational commercial bribery since the passage of the U.S. Foreign Corrupt Practices Act. The Global Enforcement Report derives its data primarily from the TRACE Compendium, TRACE's database of transnational corruption cases. The analysis covers enforcement events for which information is publicly available, and does not address matters involving only domestic bribery.


TRACE is a non-profit business association dedicated to anti-bribery, compliance and good governance. Founded in 2001 to make it easier and less expensive to reduce the risk of bribery, TRACE is widely recognized for establishing compliance standards and advancing commercial transparency worldwide. Members include hundreds of multinational companies across all industry sectors. TRACE is headquartered in the United States and registered in Canada, with a presence on five continents. For more information, visit