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August 2013
In The News


It was a busy month in China as several reports emerged about a widening bribery sweep of the pharmaceutical industry.  Visit the TRACE Compendium  to learn more and read the latest entries on  AstraZeneca, Sanofi,Novartis and Baxter.  Outside of China, the DOJ joined the SEC this month in investigations into AB InBev's Indian affiliates, while Juniper Networks confirmed in its second quarter filings that both the SEC and the DOJ are investigating possible FCPA violations by the company.  There have also been developments in settlements for ADM, Avon and Diebold, and updates to the TRACE Compendium have also been made to the entries for Owens-Illinois, Allied Defense Group, SciClone, BHP Billiton and Walmart.


News outlets have also reported that the SEC is investigating JPMorgan's hiring activities in China, following allegations that the company may have  violated the FCPA by hiring children of Chinese government officials to win business.  Alexandra Wrage, TRACE's President, comments on the JP Morgan investigation in an article published on Forbes' website entitled Cautionary Tale: U.S. Bribery Probe Into JP Morgan's Hiring Practices In China.  In the article, Wrage explains how the JP Morgan investigation is a reminder of the broad definition of "bribery" and "government official" under the FCPA.


Wrage also tackled recent multi-stakeholder meetings being held at the World Bank and proposed changes to the World Bank Sanctions System.  The Sanctions System is part of the World Bank's overall governance and anti-corruption strategy.  Read Wrage's article on Corporate Counsel to understand the changes she proposes to help the World Bank continue to address corruption through its administrative sanctions process.  

With August almost over, we've rounded up all of the top anti-bribery stories this month and listed them below. Vote for which one you think deserves the top spot:


  • Tens of thousands protest corruption in streets of  Manila - Tens of thousands of Filipinos protested in Manila earlier this week amid several recent high-profile corruption scandals and accusations that an estimated $141 million in public money had been embezzled by politicians.  
  • Brazil enacts tough new anti-bribery law - On August 1, Brazilian President Dilma Vana Rousseff signed into law a robust new law that, like the FCPA and the UK Bribery Act, establishes direct civil liability for companies for the bribery of both domestic and foreign public officials.  
  • Chinese investigations of foreign bribery in the pharmaceutical industry widen - Since last month's investigation into British drugmaker GlaxoSmithKline, several more companies, including AstraZeneca, Sanofi, Baxter and Novartis, are now under scrutiny for bribery in China.  
  • Canada convicts first individual under the Corruption of Foreign Public Officials Act (CFPOA) - Nazir Karigar, an Indian-Canadian businessman, was found guilty this month under the CFPOA for conspiring to bribe Air India officials and an Indian cabinet minister on behalf of Ottawa-based, high-tech company, CryptoMetrics.  
  • Corruption investigation into JP Morgan's hiring practices in China - The New York Times revealed this month that leading financial firm JP Morgan was under investigation by the Securities and Exchange Commission regarding hiring of children of public officials in China.  
  • Indonesia's Corruption Eradication Commission (KPK) arrests oil and gas regulator on corruption charges - The KPK, Indonesia's top anti-bribery government agency, arrested several top officials at the national oil and gas regulator SKKMigas on allegations of taking bribes.  The arrests are part of a wider inquiry into corruption in the oil and gas industry in Indonesia.  
  • Serious Fraud Office (SFO) prosecutes first defendant under the 2010 U.K. Bribery Act - The SFO charged three British nationals on 14 August with offenses under the U.K. Bribery Act in connection with a 23 million fraud at Sustainable AgroEnergy.  
Books & Articles

 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 reader 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.  


4 Ideas for Reforming the World Bank Sanctions System 

19 August 2013

Alexandra Wrage


Cautionary Tale: U.S. Bribery Probe Into JP Morgan's Hiring Practices In China

20 August 2013

Alexandra Wrage 


Who Watches the Watchmen? A Look at Anti-Bribery Risks in the Legal Profession 

9 August 2013

Severin Wirz

 Featured Resource

TRACEcertification is a detailed due diligence review, analysis and approval process that eliminates screening costs. TRACEcertification portable due diligence reports contain a wealth of anti-bribery information establishing that the commercial intermediary has been thoroughly vetted, trained and certified by TRACE. The report is packaged for the purpose of sharing verified due diligence information with an unlimited number of global business partners. TRACEcertification solves five major problems for most companies:

  1. TRACEcertification offers ongoing monitoring of third party relationships with constant screening of names against international sanctions and enforcement lists.
  2. TRACEcertification provides evidence of a compliance program, policies and procedures and a Code of Conduct.
  3. TRACEcertification requires certified intermediaries to update their verified compliance information annually.
  4. TRACEcertification satisfies anti-bribery training requirements for third parties.
  5. TRACEcertification shifts due diligence costs away from multinationals and enables third parties to own and share their verified due diligence reports with all of their global business partners. 

Join the growing community of companies and intermediaries adopting this new approach. To learn more, please email us at


Save 20% when you enroll in TASA by September 6. Offer extended one week. Apply Now!


Apply today and SAVE 20 percent. To take advantage of this discount, visit and use voucher code AugTASA2013.


TASA is the only certification program available that is dedicated to anti-bribery compliance and offers over 100 courses taught by world-renowned faculty. TASA integrates rigorous standards with a flexible learning environment. The certification process requires that candidates complete thirty hours of coursework before taking the accreditation exam which ensures students acquire the requisite knowledge. Earn an internationally recognized compliance credential. Begin the application process today at


Upcoming live TASA accredited ACI conferences:


3rd India Summit on Anti-Corruption 

September 23 - 24, 2013, New Delhi


6th FCPA Boot Camp

October 1-2, 2013, San Francisco, CA


2nd Annual: Singapore Summit on Anti-Corruption, Compliance and Risk Management  

December 3-4, 2013, Singapore



Upcoming live TASA accredited TRACE events:

October 28-29, 2013, Dubai, UAE

TRACE Israel Workshop
October 31, 2013, Tel Aviv, Israel

TRACE Libya Workshop
November 12, 2013, Libya 


To inquire about discounts and credits, write to  

Join Cisco, Mubadala, ABB, 3M Company, FH Bertling Holdings, and other industry leaders for our 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 agenda and speakers.


If you are interested in speaking, please contact Virna Di Palma at 


Visit our GAIN webpage for program updates and registration details. Register early to guarantee your place.


TRACE presents its first anti-bribery training workshop in Israel on October 31, 2013. Employees and intermediaries of TRACE member companies are invited to attend at no charge. The Agenda is available here. 


TRACE, in collaboration with the American Chamber of Commerce in Libya, is hosting a full-day anti-bribery and trade compliance workshop on November 12, 2013 in Libya.  Employees and intermediaries of TRACE member companies and AmCham Libya  members are invited to attend at no charge. To learn more about this partnership, click here. To view the Agenda At-a-glance, click 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.

Corruption & Compliance South & South East Asia Summit  

September 17-19, 2013 
Hosted By: Beacon  
*Alexandra Wrage, TRACE President, speaking 
Tysons Corner, VA
September 19, 2013
Hosted By: Grant Thornton
*Eileen Radford, TRACE Director of Advisory Services, speaking
Houston, TX 
September 23, 2013
Hosted By: Momentum
*Julie Coleman, TRACE Senior Director of Advisory Services, speaking
TRACE Members receive a 15% discount. 
New Delhi, India 
September 23-24, 2013
Hosted By: American Conference Institute
TRACE Members receive a $200 discount. 
Moscow, Russia 
September 26-27, 2013
Hosted by: C5
TRACE Members receive a 10% discount. 
San Francisco, CA 
October 1-2, 2013
Hosted By: American Conference Institute
TRACE Members receive a $200 discount. 

12th Annual Compliance & Ethics Institute  

Washington, DC 
October 6-9th, 2013 
*Alexandra Wrage, TRACE President, speaking


Phoenix, AZ 
October 8-9, 2013
Hosted By: IACCM
*Alexandra Wrage, TRACE President, speaking 
London, UK 
October 9-10, 2013
Hosted by: 
TRACE Members receive a 10% discount.  
October 9-10, 2013
Hosted by: C5
*TRACE Representative attending
TRACE Members receive a 10% discount.  
London, UK 
October 15-17, 2013
Hosted by: IBC Legal Conferences
TRACE Members receive a 20% discount. Please quote VIP code: FKW82396TRCL when registering. 


New York, NY
Oct 28-29, 2013
Hosted By: Momentum
*Eileen Radford, TRACE Director of Advisory Services, speaking  
TRACE members receive a 15% discount.

London, UK
November 4-7, 2013
Hosted By: 
*Alexandra Wrage, TRACE President, speaking 
Conflict Minerals & The Ethical Supply Chain
Chicago, IL
November 18, 2013
Hosted By: Momentum
*Alexandra Wrage, TRACE President, speaking
TRACE Members receive a 15% discount.  
Washington, DC 
November 18-21, 2013
Hosted By: American Conference Institute
*Alexandra Wrage, TRACE President, speaking
TRACE Members receive a $200 discount.
2nd Annual: Singapore Summit on Anti-Corruption, Compliance and Risk Management
December 3-4, 2013
Hosted By: American Conference Institute
*Alexandra Wrage, TRACE President, speaking
TRACE Members receive a $200 discount. 
International Regulatory Updates



TRACE Partner Firm: Vitor Costa Advogados

In Brazil, the new Anti-bribery Law was approved on August 1, 2013 and will come into force on January 29, 2014. The new Law applies to all legal entities, regardless of the form of organization or corporate model adopted, as well as any foundations, associations, legal entities or persons, or foreign companies which have their registered office, branch or representation in Brazil, consisting of fact or law, even temporarily. The responsibility of the legal entity does not exclude individual liability of its directors or officers or any natural person in the illicit act.   


The new Law subjects companies who commit bribery crime to administrative and judicial sanctions, which includes loss of the assets/advantages or benefits gained from the infringement, partial suspension or interdiction of its activities, and compulsory dissolution of the legal entity.  In addition, sanctions can include one to five years of prohibition from receiving incentives, subsidies, grants, donations or loans from public agencies or entities and from public financial institutions or institutions controlled by the Government.


International regulatory updates are provided by TRACE Partner Law Firms. For more information on TRACE Partner Firms, please visit the TRACE Resource Center


News & Press



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