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May 2013


Since late April, reports surfaced regarding FCPA investigations of multiple companies by enforcement authorities in the United States. In a submission to the U.S. Securities & Exchange Commission ("SEC"), International Business Machines Corporation disclosed that the SEC and U.S. Department of Justice ("DOJ") are investigating allegations of potential FCPA violations regarding the company's transactions in Poland, Argentina, Ukraine, and Bangladesh. Harris Corporation also announced that the SEC has issued a formal order of investigation regarding allegations involving a recent acquisition in China.


In May 2013, the DOJ charged multiple individuals with violating the FCPA. Two employees of a New York broker-dealer were charged with FCPA violations regarding alleged payments made in Venezuela. A former executive of Alstom USA was also charged with FCPA violations relating to allegations of bribery in Indonesia. Also, a former Willbros International Inc. consultant who pleaded guilty to FCPA violations in 2009 was sentenced to 15 months in prison and must pay a $1 million fine.


During late April and May 2013, there were also updates to the following investigations in various countries: MTS Systems Corporation, Archer Daniels Midland Company, Eurasian Natural Resources Corporation, News Corporation, and others.


The month of May brought more in-depth reporting from TRACE Blog.  In response to the growing concern that we're hearing from compliance officers about reaching their employees, we explored 3 steps that companies can take in order to build a better compliance culture: changing the compensation structure, personalizing the compliance message and making an example out of both good and bad behavior. 


We also tried to answer a question that we're increasingly getting from companies: who are the third parties that pose risks to my company?  The answer is that any outside representative used by a company to conduct business abroad poses an FCPA risk.  We also gave you a look inside TRACE in our TRACE Profile: Stories from the Front Lines of Due Diligence  series, where we interviewed TRACE due diligence associate Patty Orndorff.


Looking at the U.S. Securities & Exchange Commission ("SEC"), we explored rising tensions over a proposal that would require all public companies to disclose their spending for political purposes.  The proposed rule, which is still being assessed by the SEC, has been a lightning rod for both proponents on the left and opponents on the right.


Outside the United States, we looked at Corruption in China, providing some historical context of how overall economic development may have an effect on the country's corruption levels.  We also looked at how bribery and cheating in schools is still a global epidemic, and ways in which groups in Moldova, Uganda and Kenya are coming together to combat the problem.  Stay tuned for more articles in June and let us know what stories you'd like to hear!

  • Yet another big American multinational technology corporation has disclosed that it is under investigation for FCPA violations. This time, International Business Machines Corporation (IBM) disclosed that the SEC and DOJ are investigating allegations regarding the company's transactions in Poland, Argentina, Ukraine, and Bangladesh.
  • The FCPA hit Wall Street this month. During a periodic examination of a broker-dealer, the SEC uncovered evidence that bond traders Tomas Clarke and Alejandro Hurtado paid at least $5 million in bribes to an official of Venezuela's state economic development bank in exchange for business opportunities. Formal charges have been brought against both employees under the FCPA.
  • Several Canadian businessmen are on trial in Cuba on charges that they bribed Cuban officials. The trials are part of a country-wide push by Raul Castro's government to crack down on corruption.
  • Switzerland proposed several new anti-corruption laws recently. In late May, the government introduced an asset recovery law that would allow the Swiss government to freeze the assets of corrupt politically exposed persons and return those assets to the countries that were the victim of the theft. Earlier in the month, the Swiss government proposed broadening its anti-corruption laws to bribes paid during the selection of hosts for major sporting events like the FIFA World Cup or the Olympics.
  • Several executives were either charged or sentenced in the U.S. for paying bribes this month, including a former executive of Alstom USA, a former Willbros International Inc. consultant and a husband-and-wife couple who were both executives of Rino International Corporation, a China-based company.

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Books, Articles & Reports

 How to Pay a Bribe: Thinking Like a Criminal to Thwart Bribery Schemes

Last year, TRACE published a fascinating and instructive book about how bribery schemes are devised, carried out and covered up. TRACE is now in the process of compiling the 2013 edition. We invite in-house counsel and anti-bribery practitioners to "join the conversation" by sharing their corruption (and compliance!) stories by writing to

 In Waging War on Corruption: Inside the Movement Fighting the Abuse of Power  

Frank Vogl, one of the leaders of the worldwide anticorruption movement, shares a history filled with stories of heroes and victims of corruption. He chronicles the successful campaigns by enormously courageous civil society activists, journalists, and public prosecutors and explains the crucial challenges that now must be confronted. At stake is nothing less than our global security, the reduction of poverty, the stability of our economic and financial systems, and the cause of freedom and democracy. Waging War on Corruption

will be of interest to readers of politics and government, business, human rights, and law.



Citizens Against Corruption: Report From The Frontline tells the story of how groups of courageous and dedicated citizens across the globe are taking direct action to root out corruption. It shows how people are no longer prepared to accept the predatory activities of dishonest officials and are challenging their scams. It draws on over 200 unique case studies that describe initiatives undertaken by 130 civil society organisations (CSOs) which engage directly with public agencies to stop the bribery and extortion that damages peoples' lives and obstructs social and economic progress. This book challenges the notion that, at best, civil society can only have a marginal impact on reducing corruption and argues that aid donors need to radically rethink their assistance for governance reform.  



Why CEOs Resign

Alexandra Wrage, 9 May 2013


Latin America's Business Attractions Belie Its Risks

Julie Coleman, 13 May 2013


An Introduction To Tax And The Foreign Corrupt Practices Act

Clinton Long, 9 May 2013  


FCPA Lessons for the Financial Services Industry from Morgan Stanley

Clinton Long, Eileen Radford, May 2013  


The FraudNet Report

FraudNet, May 2013


The CEELI Institute 2012 Annual Report


Pulling Together: Leveraging The Whole Company To Ensure Compliance

Alexandra Wrage, 28 May 2013


Global Enforcement Report

The GER 2012 is the third in an annual series from TRACE that provides a summary of international anti-bribery enforcement trends based on the cases and investigations tracked in the 

TRACE Compendium. Several new developments and ongoing trends are highlighted in the report, including a decline in foreign/outbound bribery enforcement actions brought by the United States and by other countries and an uptick in the enforcement of inbound/domestic bribery legislation worldwide. The report also includes for the first time information about how many times countries declined to take formal enforcement actions or closed official inquiries related to outbound or inbound bribery from 1977 through 2012. 


Click here to download. 


Interviews: U.S. Dept of Commerce Conversation


In celebration of World Trade Week, TRACE caught up with representatives from the U.S. Department of Commerce to discuss the many ways in which the Department is helping companies face the challenges posed by bribery in international trade. We learned, for example, that the Department's Trade Compliance Center offers counsel to those facing bribery concerns overseas and also assists with related problems such as suspected bribery by a competitor. The conversation also covered what the U.S. Government is doing more broadly to advance anti-corruption and good governance initiatives globally. 


Click here to download the full interview.

Featured Resource: TRAC
Your Answer to Supply Chain Compliance

One year ago, TRACE launched TRAC, the first global platform that captures, assesses and shares baseline due diligence on organizations and individuals across the supply and marketing chain and assigns a universal ID number (TRAC number) to all approved applicants. A year later, we're celebrating this new approach to due diligence, which has been adopted by thousands of companies and their suppliers and business partners operating worldwide.


Unlike other due diligence platforms, TRAC is not just a database. Multilingual analysts review each due diligence file before making it available to companies to incorporate into their compliance programs with confidence. TRAC uses social media principles to gather due diligence on large numbers of third parties and provides detailed due diligence at no cost to companies. TRAC holders pay just $80 a year.


To learn more, watch our 90-second TRAC video here or download our TRAC brochure


Still not sure how TRAC or our other portable due diligence solutions can help you? Download our recent supply chain compliance and portable due diligence presentation here. Contact Virna Di Palma at to receive the recording of this webinar.

TASA graduates demonstrate sufficient knowledge of anti-bribery regulations, beyond the FCPA, and global compliance best practices and are recognized by employers as anti-bribery specialists. By enrolling in TASA and passing the accreditation exam, you will both join an exclusive community of anti-bribery compliance professionals and help further your career. To being the application process, visit


Upcoming ACI TASA accredited conferences:


China Summit on Anti-Corruption 

Jun 18 - 19, 2013, Shanghai


 FCPA Boot Camp 

Jun 19 - 20, 2013, Chicago


3rd Latin America Summit on Anti-Corruption 

Jun 24 - 25, 2013, São Paulo


Anti-Corruption Compliance in High Risk Markets 

Jul 22 - 24, 2013, Washington


3rd India Summit on Anti-Corruption 

Sep 23 - 24, 2013, New Delhi


*TASA candidates may earn 12 credits for attending a full two-day FCPA Boot camp; 3 credits per day for attending any other FCPA/anti-corruption event; and 2 credits for workshops. A $200 registration discount is offered to TASA candidates.

TRACE is pleased to present the 2nd Global Anti-Bribery In-House Network (GAIN) Conference. This is an excellent opportunity for attorneys from TRACE partner law firms and TRACE member and non-member companies to meet while learning first-hand about compliance challenges and enforcement trends around the world. 


Click here to view the Agenda-at-a-Glance. If you are interested in speaking, please contact Virna Di Palma at


Visit our GAIN webpage for program updates and registration details.


TRACE presents its first anti-bribery training workshop in Israel. Employees and intermediaries of TRACE member companies are invited to attend at no charge.


The Agenda at-a-Glance is available here. Please visit TRACE workshops for program updates and registration details.

Save the Date! 10th Annual TRACE Forum

March 26-27, 2014, St. Regis, Washington, DC

TRACE members should plan now to attend what has become the premier anti-bribery benchmarking conference. The 10th Annual TRACE Forum will be held March 26-27, 2014 at the St. Regis in Washington, DC. Companies using TRAC should also plan to attend the TRAC working group the afternoon of March 25, 2014. The program is currently under development. Please visit our Forum webpage for program updates and registration details.


2nd Annual Fraud & Corruption Asia Pacific Summit
Hong Kong
June 3-5, 2013
Hosted by: MIS Training
TRACE Members receive a 15% discount. 


11th Annual IBA Anti-Corruption Conference
June 12-13, 2013
Hosted by: International Bar Association
* Eileen Radford, Director, Advisory Services, TRACE, speaking


The Global Anti-Corruption Congress
Washington, DC
June 18-19, 2013
Hosted by: Momentum
TRACE members receive a 15% discount. 
* Alexandra Wrage, TRACE President, speaking


China Summit on Anti-Corruption
Shanghai, China
June 18-19, 2013
Hosted by: American Conference Institute
TRACE Members receive a $200 discount. 


FCPA Boot Camp
Chicago, IL
June 19-20, 2013
Hosted by: American Conference Institute
TRACE Members receive a $200 discount. 


The European & UK Anti-Corruption & Compliance Congress
London, UK
June 24, 2013
Hosted by: Momentum
TRACE members receive a 15% discount. 
* Eileen Radford, Director, Advisory Services, TRACE, speaking


Corruption & Compliance - Asia Congress 2013
Hong Kong
June 24-26,2013
Hosted by: Beacon
TRACE Members receive a 15% discount. 
* Alexandra Wrage, TRACE President, speaking


 3rd Latin America Summit on Anti-Corruption 
Sao Paulo, Brazil
June 24-25, 2013
Hosted by: American Conference Institute
TRACE Members receive a $200 discount. 


Anti-Corruption London
London, UK
June 25-26, 2013
Hosted by: C5
TRACE Members receive a 10% discount. 


Anti-Corruption Compliance in High Risk Markets
Washington, DC
July 22-24, 2013
Hosted by: American Conference Institute
TRACE Members receive a $200 discount


InsideNGO Annual Member Conference
Washington, DC
July 30-August 1, 2013
Hosted By: InsideNGO 
* Alexandra Wrage, TRACE President, speaking


Corruption & Compliance South & South East Asia Summit
September 17-19, 2013
Hosted By: Beacon
* Alexandra Wrage, TRACE President, speaking 


12th Annual Compliance & Ethics Institute
Washington, DC
October 6-9th, 2013
Hosted By: Society of Corporate Compliance and Ethics
* Alexandra Wrage, TRACE President, speaking



TRACE Partner Firm Updates

This month, TRACE gladly welcomed the addition of two new partner firms: Bun & Associates in Cambodia and Baker & McKenzie in Morocco. Mr. Youdy Bun, Partner at Bun & Associates is available by e-mail at or by telephone at +855 (0) 23 999 567. Mr. Kamal Nasrollah, Managing Partner at Baker & McKenzie is available at Baker & McKenzie's website is also accessible here


TRACE partner firms around the world prepare TRACE's local law resources (including Country Bulletins and Gifts & Hospitality Guidelines). Biographies and contact information for each partner law firm - one firm per country - are listed on the Resource Center, providing a valuable reference for TRACE members. 



News & Press

Wall Street Journal, 20 May 2013


Report: Bribery Prosecutions Revive Following 2012 Lag

National Law Journal, 20 May 2013  


Learn more about TRACE membership benefits. Download our membership brochure here.




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