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November 2013
Compendium Roundup


In the last week of November, Weatherford International, an oilfield services company based in Switzerland, and three of its subsidiaries agreed to pay $152.6 million to settle FCPA violations with the SEC and DOJ and $100 million to settle related export control violations with the U.S. government.  Weatherford was charged with falsifying its books and records to conceal the authorization of improper travel and entertainment to officials in Africa and the Middle East as well as failing to conduct proper due diligence on distributors and agents who paid bribes. Notably, Weatherford was fined $1.875 million in penalties for lack of cooperation early in the investigation.


There have also been developments for Brookfield Asset Management, Leighton, Hyperdynamics Corporation, Glen Defense Marine Asia Ltd., National Geographic Society, and Archer Daniels Midland.


2013 Gifts & Hospitality Benchmarking Survey: Holiday Gift Giving


The results of our 2013 Gifts & Hospitality Benchmarking Survey on Holiday Gift Giving are available here. In total, 24 survey responses were received from TRACE member companies. As demonstrated in the charts, for holiday gifts to government officials, third parties and customers, the majority of respondents have a maximum limit between $50 and $250, with disclosure or pre-approval required on gifts exceeding $150. Moreover, most respondents that permit gifts to government officials do not impose different dollar thresholds between government officials as opposed to customers or third parties.

  1. French corruption reforms enacted:  The French National Assembly voted on November 5 to pass a new law against fiscal fraud and corporate tax evasion.  Among other things, the new law imposes heavier penalties in cases of corruption and misuse of company assets.  Late last month, France created the new Central Office for fighting against Corruption and Financial Offences, which will target white collar crime, tax fraud and bribery and money laundering offenses.
  2. DOJ and SEC predict more FCPA settlements by year's end:  At last week's American Conference Institute's International FCPA Conference, Charles Duross, deputy chief of the FCPA unit of the DOJ Criminal Division's Fraud Section, said that the government had a large number of open FCPA investigations.  He predicted some potentially major criminal actions involving significant penalties that might be announced before year's end.
  3. SEC enters into its first DPA with an individual: Last Spring, the SEC announced its first non-prosecution agreement (NPA) with Ralph Lauren for FCPA misconduct. This month, the SEC announced its first deferred prosecution agreement (DPA) with an individual, Scott Herckis, a former hedge fund manager, who alerted the SEC to significant investor fraud at Connecticut-based Heppelwhite Fund LP
  4. Supreme Court hears oral argument on whistleblower case - Earlier this month, the US Supreme Court heard oral arguments in the case of Lawson v. FMR LLC.  The justices will have to answer the question of whether the whistleblower provisions of the Sarbanes-Oxley Act protect employees of a privately held contractor or subcontractor of a public company.   Read more about what was said at oral arguments here.
  5. Corruption trials against several high-profile individuals continue - Several big name corruption cases were splashed across headlines worldwide this month.  Among them is the UK trial of Victor Dahdaleh, the Canadian-British businessman who is accused of paying bribes of 38 million to a senior member of the Bahraini Royal Family. The trial of Germany's former president, Christian Wulff, also began this month.  Mr. Wulff is accused of receiving certain loans and benefits from wealthy friends, such as travel invitations.  Also on trial is Bernie Ecclestone, the former owner of Formula One racing, who was cross-examined this month for his involvement in making an improper payment of $44 million to a German banker in 2006 in order to facilitate the sale of a 47% stake in the sport.  Israel's top rabbi Yona Metzger was arrested for his involvement in an alleged money laundering scheme, and a senior official at a state-run Omani oil company, Juma Al Hinai, went on trial for allegedly accepting bribes from a local oil company.
Vote here on the TRACE Blog. 
Books, White Papers and 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


Did You Pay Taxes On That Bribe? The Tax Consequences Of FCPA Violations

14 November 2013

Eileen Radford and Alice Hsieh

Featured Resource: 10 Days of Giving
10 Days of Giving is Back!
Last year, TRACE debuted its 10 Days of Giving campaign to celebrate the holidays. We gave away TRACE Anti-Bribery Specialist Training (TASA) courses, TRAC portable due diligence reviews, online training courses, TRACEcertification reports, free consultations with our compliance advisors, tickets to our Mexico City workshop and more!

This year, we have 10 days of new and exciting giveaways planned and we're giving TRACE Members exclusive access. Check your email starting December 9 for a first look at the day's giveaway before we post it anywhere else! These offers will also be posted to the TRACE Blog and shared on our Twitter, Facebook and LinkedIn accounts. 

TASA (TRACE Anti-Bribery Specialist Accreditation) 
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. To learn more about TASA, view the catalog here. To enroll in the TASA program, please write to


Upcoming live TASA courses:
December 18, 2013
12:00 - 1:15 PM EDT
Martin Weinstein, Partner, Willkie Farr & Gallagher


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

December 3-4, 2013, Singapore

January 22-23, 2014, Houston, TX


Middle-East Summit on Anti-Corruption

February 24-25, 2014, Dubai, UAE


Mexico Summit on Anti-Corruption

March 24-25, 2014, Mexico City, Mexico


6th Russia & CIS Summit on Anti-Corruption 

March 25-27, 2014, Moscow, Russia



Upcoming live TASA accredited TRACE events:
January 23, 2014, Toronto
February 10, 2014, Tripoli

March 18, 2014, Zambia

March 26-27, 2014, Washington, DC

To inquire about discounts and credits, write to  
TRACE Libya Workshop
10 February 2014
TRACE Zambia Workshop
18 March 2014

Please visit TRACE Workshops for program and registration details. 


If you are interested in speaking at TRACE workshops or events, please contact Virna Di Palma at

Join TRACE in Toronto on January 23, 2014 at the Park Hyatt for an advanced roundtable discussion on anti-bribery enforcement and compliance. The roundtable will be led by TRACE President, Alexandra Wrage, and Jonathan Drimmer, Vice President and Deputy General Counsel of Barrick Gold Corporation. 

For more information or to request an invitation to this event, please write to
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: Singapore Summit on Anti-Corruption, Compliance and Risk Management

December 3-4, 2013 
*Alexandra Wrage, TRACE President, speaking 
TRACE Members receive a $200 discount.  


Anti-Corruption Compliance for High Risk Markets 

London, UK 

December 4-5, 2013 

Hosted by: Momentum

*Julie Coleman, TRACE Senior Director of Advisory Services, speaking

TRACE Members receive a 15% discount.   


Global Investigations Summit 

London, UK 

December 4-5, 2013 

Hosted by: IQPC 

*Julie Coleman, TRACE Senior Director of Advisory Services, speaking


FCPA Boot Camp  

Houston, TX 
January 22-23, 2014 
TRACE Members receive a $200 discount. 


The Canadian Institute's 3rd Annual Anti-Corruption Compliance

Toronto, Canada 

February 5-6, 2014 

Hosted by: C5

TRACE Members receive a $200 discount.  


Utilities & Energy Compliance & Ethics Conference

Houston, TX 

February 23-26, 2014 

Hosted by: Society of Corporate Compliance and Ethics

*Alexandra Wrage, TRACE President, speaking


Oil & Gas Supply Chain Management  

Houston, TX 
February 24-27, 2014 
Hosted by: Hanson Wade 
*Alexandra Wrage, TRACE President, speaking


Middle-East Summit on Anti-Corruption  

Dubai, UAE 
February 24-25, 2014 
TRACE Members receive a $200 discount. 


18th Annual Corporate Counsel Institute

Washington, DC 

March 13-14, 2014 

Hosted by: Georgetown Law CLE

*Alexandra Wrage, TRACE President, speaking


Women in Compliance Awards

London, UK

March 20, 2014

Hosted by: C5


Mexico Summit on Anti-Corruption  

Mexico City, Mexico  
March 24-25, 2014  
TRACE Members receive a $200 discount.    


6th Russia & CIS Summit on Anti-Corruption  

Moscow, Russia  

March 25-27, 2014  

Hosted by: American Conference Institute 

TRACE Members receive a $200 discount.


European Compliance & Ethics Institute

London, UK 

May 18-21, 2014 

Hosted by: Society of Corporate Compliance and Ethics 

*Alexandra Wrage, TRACE President, speaking

News & Press

NGO Hits Israel on Foreign Bribery Prosecution Record

2 November 2013

Niv Elis, The Jerusalem Post


TRACE International is "Making Anticorruption a Goal at the Brazil World Cup"

11 November 2013

Sue Reisinger, Corporate Counsel 



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