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September 2012



We hope you enjoy the September newsletter of TRACE. Features this month include a review of new investigations and settlements, TRACE Anti-Bribery and Anti-Corruption Employee Headcount 2012 survey results, upcoming events and webinars, insightful articles, and more.

Compendium Roundup

In early September, a Paris court sentenced Safran to a Euro 500,000 fine for corruption in Nigeria between 2000 and 2003, in connection with a USD 214 million contract to manufacture national identity cards. Bribes were paid to Nigerian officials, including the former Minister of the Interior. The case is summarized briefly here; for the complete Compendium entry, see here.


On 24 September, Tyco International agreed to pay USD 26 million to settle FCPA charges. Six years earlier, the company paid USD 50 million in civil penalties for similar charges. The new allegations involve corrupt payments in 16 countries by Tyco and various local subsidiaries and third-party intermediaries. See here for a brief description of the case, or here for the full Compendium summary.


Following an exposť on Swedish television on 19 September 2012, telecommunications firm TeliaSonera acknowledged that it is under investigation by the National Anti-Corruption Unit of the Swedish Prosecutor General's office. The Company disclosed that the police were investigating the 2007 transaction whereby it acquired 3G licenses worth USD 333 million in Uzbekistan. The complete Compendium summary for this case is available here.


There have also been updates on the investigations of Tenix, Man SE, ZTE, Layne Christensen, Harris, Eni, Finmeccanica and Hewlett Packard, among others.


September was a busy month for the TRACEblog. In addition to celebrating the launch of TRAC, our online global due diligence platform, TRACEblog examined the factors contributing to bribery in Italy,  and the success of anti-corruption efforts currently underway in Latvia and South Africa (and some failures to curb corruption there as well). The Blog explored how motorcycles and bribery are connected, and speculated on the repatriation of a fugitive from prosecution in one of the Siemens cases. It also took a close look at the efficacy of the UK Bribery Act, and examined the impact of deferred prosecution agreements and the effects of India's relaxation of its foreign direct investment rules. The latest and thus-far greatest whistleblower was introduced, and the virtues of the TRACE Compendium, an invaluable resource for anyone interested in international corruption, were revealed. Finally, the TRACEblog applauds President Obama's new initiatives in the campaign against human trafficking.

TRACE Anti-Bribery Employee Headcount

2012 Survey Results

As a result of the recent Pfizer H.C.P. Corporation's Deferred Prosecution Agreement (DPA) with the US Department of Justice (DOJ), TRACE created a survey regarding the number of employees TRACE member companies have dedicated to various anti-bribery and anti-corruption functions. The objective of this survey was to identify and better understand how companies are resourcing their anti-bribery compliance duties and program management.

Resource Center Alerts

Georgia - Arbitration Clauses


According to recent judicial practices in Georgia, in order for an arbitration clause of a Georgian law government instrument to be upheld by the courts of Georgia it must envisage arbitration as the sole dispute resolution mechanism and must expressly specify the particular arbitral forum to consider disputes arising between the parties. The judiciary's position on foreign law government instruments is not fully clear, although the same requirements may be imposed.


Uzbekistan - Limitation on Gifts


In May 2012, the threshold for criminal liability to be imposed for giving a material reward or benefit to a lower level government employee increased to 30 or more minimum wages (or approximately $1100 US dollars from a previous $870 US dollars).


United States - Government Officials and Ownership Interest


The Stop Trading on Congressional Knowledge Act of 2012 (the "STOCK Act") affirmed that Members of Congress, congressional staff, and federal officials are subject to the provisions of U.S. securities laws that address insider trading. The Act states that all federal officials have an express duty of trust and confidentiality with respect to material, nonpublic information that they may receive in the course of their official duties, and a duty not to use such information to make a private profit. In addition, the STOCK Act prohibits certain officers and employees of the federal government from purchasing securities that are the subject of an initial public offering "in any matter other than is available to members of the public generally." Beginning on July 3, 2012, U.S. Government officials and employees are required to publicly report a covered transaction an income-producing assets no later than 45 days after the transaction.


For more information, visit the Resource Center.

Articles and Books

In this eminently readable collection, anti-corruption experts guide the reader through the dark world of international bribery schemes, from Washington, D.C. to Europe and Africa and across Asia. Following the authors' accounts of imaginative and varied schemes in which charitable contributions are tainted and fine art is used as a vehicle for passing bribes to greedy officials, this volume offers recommendations for the best practices companies can incorporate to avoid corruption as they interact with governments, intermediaries and each other in international markets. Available for purchase here.
 ByAlexandraWrage,Corporate Counsel, September 20, 2012

 By Alexandra Wrage, September 07, 2012

TRACE Events

TRACE Forum 2012, October 29-30, St. Regis, Washington, DC


Live audience polling with real-time results, an interactive and private setting, and the opportunity to share best practices with your fellow TRACE members are what make the TRACE annual Forum a true benchmarking event. Don't miss the opportunity to engage directly with panelists and attendees and discuss new strategies for more effective and cost-conscious compliance. Registration closes October 12. To confirm attendance, please send your name, company affiliation and contact details to View agenda here.


As in previous years, in order to maintain an interactive setting, each member company is limited to one representative. Additional employees will be placed on a waiting list and may attend if space permits.


TRACE Workshops - Registration Now Open for Mexico City, London and Istanbul


TRACE organizes one-day anti-bribery training sessions throughout the world for employees of member companies and member intermediaries. These seminars feature local and foreign lawyers and business people familiar with the practical problems inherent in international business. Workshops are open to the public but priority is given to the employees of member companies and member intermediaries. There is no charge for employees and intermediaries of TRACE member companies. The following workshops have been scheduled for January 2013 through June 2013:


Mexico City, February 07, 2013

London, March 12, 2013

Istanbul, May 7 ,2013


To register for or inquire about specific workshops, please write to

Upcoming Webinars
 03 October 2012, 12:00 pm ET


TRACE makes compliance with due diligence obligations easier and less expensive for organizations by providing flexible and cost-effective due diligence options for all intermediary risk levels. Our due diligence services and solutions range from baseline reviews to on-the-ground, intensive reviews of high risk third parties or acquisition or joint venture targets. For a fraction of the cost of other providers, TRACE offers due diligence solutions that are customizable, practical and comprehensive. Our team of multilingual due diligence analysts and attorneys carefully vets every report for accuracy, alerting you of red flags and higher risk relationships that may require more attention. To learn more about TRACE due diligence services, sign up for tomorrow's complimentary webinar today. Register here.

Featured Tool

Not all third parties require the same level of due diligence. That's why TRACEselect allows companies to order separately priced components of a due diligence report, tailoring their experience based upon what is important to them. TRACEselect is designed to help companies better manage their commercial intermediaries at all levels of risk and fulfill their unique compliance needs with one simple and cost-effective due diligence solution. To learn more, listen to our recent webinar by clicking here or contact

03 October 2012

Internal Investigations in Russia and the CIS

Robert Wieck, Forensic Audit Senior Manager, EMEA of Oracle Corporation in Romania

10 October 2012

The Shot Show Case: FCPA Lessons Learned from the Frontlines

Michael J. Madigan, Senior Counsel, White Collar & Corporate Investigations of Orrick, Herrington & Sutcliffe LLP

29-30 October 2012

2012 TRACE Annual Forum


TASA Candidates may earn five credits for attending the TRACE Forum. There is no charge for TRACE members to attend, but pre-registration is required by October 12. Available spaces are open to non-members for a fee. For more information, or to register, please send your name, company affiliation and contact details to


Fall/Winter courses under development include:


Navigating the Evolving Regulatory Landscape in Myanmar to Address Anti-Bribery Challenges


Third Party Due Diligence and Supply and Marketing Chain Compliance - Beyond Anti-Bribery


Anti-Bribery Compliance Challenges in Kazakhstan


Contract Negotiation and Execution: Detecting and Responding to Bribery


Anti-Bribery Compliance Challenges in Venezuela


Global Anti-Corruption Enforcement and Regulatory Update


The FCPA Year in Review and Looking Ahead to 2013


Courses are being added frequently. Visit for course updates and to apply for accreditation.

News & Press

September marked the official release of TRAC, the free global online due diligence platform for supply and marketing chain compliance. In a press conference on September 11, TRACE announced the members of the TRAC Leadership Group: ABB, Adobe, American Airlines, Barrick Gold, Home Depot, and International Relief and Development. We thank our Leadership Group companies for their endorsement of TRAC and encourage other companies to join us in tackling bribery, money laundering, sanctions violations, trafficked labor, and the use of conflict minerals in the global marketing and supply chain.


To learn more about TRAC, view a 90 second clip here, or visit


"TRACE Inc. Launches New Compliance Platform"

Main Justice, September 11, 2012


"TRACE Releases New Marketing and Supply Chain Compliance Tool"

Compliance Week, September 11, 2012


"Due Diligence Platform Aims to Cut Out Compliance Questionaires"

WSJ Corruption Currents, September 11, 2012

 October Partner Events

2012 NACD Board Leadership Conference
Gaylor National Resort, National Harbor, MD, October 14-16, 2012
*Alexandra Wrage, TRACE President, speaking


 7th Annual Sustainable Supply Chain Summit
Regents Park Marriott Hotel, London UK, October 22-23, 2012
*Alexandra Wrage, TRACE President, speaking


Managing Third Party Relationship Risks
Hotel Lutetia, Paris, October 23-24, 2012
TRACE Members receive a $200 discount.

*Eileen Radford, Director, Advisory Services, TRACE, speaking


World Bribery & Corruption Compliance Conference 2012

Crowne Plaza St James, London, UK, October 23-25, 2012
TRACE Members receive a 20 percent discount.

*Eileen Radford, Director, Advisory Services, TRACE, speaking


10th Annual General Counsel West Coast Conference
Grand Hyatt, San Francisco, October 30-31, 2012 
*Alexandra Wrage, TRACE President, speaking


Please contact for more information about TRACE partner events and discounts.





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To learn more about TRACE anti-bribery resources and due diligence services, view a short video clip here.