In This Issue
Compendium Roundup
Books, White Papers and Articles
Featured Resource
TRACE Workshops
TRACE Roundtables
TRACE Videos & Webinars
Innovation in Anti-Bribery Compliance Award
Partner Events
International Regulatory Updates
News & Press
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January 2014
Compendium Roundup


This month, aluminum producer Alcoa Inc. ("Alcoa") agreed to pay $384 million to the U.S. Securities and Exchange Commission ("SEC") and U.S. Department of Justice ("DOJ") to settle charges of violating the U.S. Foreign Corrupt Practices Act ("FCPA"). Alcoa's subsidiaries allegedly used a London-based consultant, with connections to Bahrain's royal family, as an intermediary to funnel illicit payments to Bahraini officials and their beneficiaries in order to retain Alcoa's position as a supplier to a government-operated aluminum plant in Bahrain.  The SEC and DOJ alleged that Alcoa and its subsidiaries falsified its books and records to conceal the illicit payments as legitimate commissions, and lacked sufficient internal controls to detect the bribes.


There have also been developments for Yara International and AgustaWestland SpA.

We're back!  After a short hiatus in December, the monthly TRACE poll is back. And so far 2014 has started out with a bang. Vote for which story you think deserves the top spot:

  1. Brazil's New Anti-Bribery Law Comes into Effect The law, passed last August, establishes direct civil liability for companies for the bribery of both domestic and foreign public officials.
  2. Alcoa Settles Bahraini Bribe Scheme for $384 Million.  Alcoa's subsidiaries allegedly used a London-based consultant, with connections to Bahrain's royal family, as an intermediary to funnel illicit payments to Bahraini officials and their beneficiaries in order to retain Alcoa's position as a supplier to a government-operated aluminum plant in Bahrain.
  3. Charles Duross Leaves US DOJ, Replaced by Patrick Stokes.  During his tenure as head of the Department of Justice's FCPA Unit, the DOJ is said to have resolved more than 40 corporate bribery cases, which resulted in approximately $1.9 billion in monetary penalties and the conviction of more than two dozen business executives and money launderers.
  4. Turkish graft probe intensifies.  Several prominent businessmen close to the government and the sons of three ex-ministers have already been detained as part of the inquiry, and the government has purged scores more of government employees within the Police Department and the judiciary.  Still, the inquiry has been marred by political infighting, and two prosecutors originally in charge of the investigation have already been removed from the case.
  5. Judge approves Weathorford Company's $252 million FCPA settlement. - The Swiss-based oil services company allegedly falsified its books and records to conceal illicit payments, including exorbitant trips for government officials and their family members.  Weatherford's Middle East subsidiary also allegedly made more than $1.4 million in improper payments to obtain contracts in the Iraqi Oil-for-Food program in 2002.
  6. New report highlights offshore tax havens of Chinese elite. A report by a team of media outlets led by the International Consortium of Investigative Journalists (ICIJ), revealed this month more than 37,000 tax haven clients from Greater China, including close relatives of some of China's top Communist Party members.  While offshore accounts are not illegal per se, the report shows how far China's anti-graft campaign has yet to go in curbing government corruption.
Click here to vote! 
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. This edition is scheduled to be released in early 2014. For questions, please write to

Featured Resource: Avoiding Trafficked Labor Online Training Module

TRACE announced the launch of its newest online training module on "Avoiding Trafficked Labor" earlier this month. This training course is the first-ever designed for the business community and offers companies a cost-effective and practical way to train a large number of employees or intermediaries on how to recognize human trafficking in the supply chain and address trafficking-related risks.


TRACE Online Avoiding Trafficked Labor Training at a Glance:

  • Unlimited access to this module is included in TRACE annual membership.
  • Available in English, with 13 additional languages coming soon.
  • Administrative dashboard for easily managing and recording training results.
  • Real-life scenarios teach appropriate conduct in a variety of situations.
  • Ability to customize platform by uploading your company's logo, messaging and policies.

To learn more, please contact

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:
5 February 2014
12:00 PM - 1:15 PM EST
19 February 2014
8:00 AM - 9:15 AM EST



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:
February 14, 2014, London
March 18, 2014, Calgary

March 26-27, 2014, Washington, DC

April 28, 2014, Singapore

April 30, 2014, Manila

To inquire about discounts and credits, write to  
TRACE hosts practical, informative anti-bribery training workshops at locations throughout the world. Workshops provide the local employees and third party intermediaries of TRACE member companies with a full day of training on anti-bribery legislation and enforcement and guidance on international compliance best practices. This spring, TRACE will hold workshops in Singapore on April 28 and Manila on April 30


Agendas for both workshops are currently under development. Please visit TRACE Workshops for program updates and registration details. 


If you are interested in speaking at TRACE workshops or events, please contact Virna Di Palma at
Throughout the year, TRACE hosts complimentary senior-level roundtable discussions on compliance with anti-bribery regulations in multiple locations in the US and worldwide. These small-group discussions facilitate peer-to-peer interactions that focus on the priorities of each participant. Join us in London on February 14, 2014 or in Calgary on March 18, 2014


For more information or to request an invitation to these events, please write to
Register Now! 10th Annual TRACE Forum March 26-27, 2014, St. Regis, Washington, DC
Don't wait! Over 70 TRACE member companies are now registered to attend the 10th Annual TRACE Forum. The deadline for registration is February 21, 2014
Companies using TRAC should also plan to attend the TRAC working group the afternoon of March 25, 2014. Full agenda details are available here.  Please visit our Forum webpage for program updates and registration details. 
TRACE Videos & Webinars

Be sure to tell your intermediaries and business partners about TRACE's 
complimentary webinar
on anti-bribery compliance for SMEs on March 6, 2014 at 12:00pm ESTThis webinar will provide an overview of TRACEcertification, an internationally recognized compliance credential that showcases a company's strong and pragmatic commitment to transparency and integrity. It will also briefly address the expanding international legal landscape and the need for companies to comply with anti-bribery laws, including the U.S. Foreign Corrupt Practices Act, UK Bribery Act, and regulations addressing conflict minerals and trafficked labor in supply chains. 

Our video, TRACE Portable Due Diligence Solutions: Own and Share Your Verified Compliance Information, is now available in 6 different languages on our YouTube channel at the videos now and share them with your international business partners to spread the word about TRACE Portable Due Diligence Solutions, a new way of approaching due diligence that benefits both multinational corporations and their third party intermediaries.
Innovation in Anti-Bribery in Compliance Award

Over the course of the last decade, many companies have developed and implemented exemplary compliance programs and procedures that have helped to raise anti-bribery compliance standards worldwide. TRACE created the Innovation in Anti-Bribery Compliance Award to recognize one of these companies for their innovative approach and their contribution to the field of anti-bribery. Recognition will focus on programs or initiatives that apply a new approach to addressing anti-bribery compliance challenges, such as third party due diligence, training, gifts and hospitality management and compliance program design.


The deadline for nomination submissions is February 21, 2014The winner will be recognized on March 26, 2014 at the

10th Annual TRACE Forum in Washington, DC. We look forward to receiving your entries and celebrating with you in March.


Click here for more information. 

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

Toronto, Canada 

February 5-6, 2014 

Hosted by: C5

TRACE Members receive a $200 discount.  


Anti-Corruption Pharmaceutical and Medical Devices Industry

Zurich, Switzerland 
February 11-12, 2014 
Hosted by: C5
*Eileen Radford, Director, Advisory Services, speaking 
TRACE Members receive a 10% 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. 

Managing Third Party and Counterparty Relationship Risks
London, UK
February 26-27, 2014
Hosted by: C5
*TRACE Representative attending
TRACE Members receive a 10% discount. 

2014 International Trade Update
Washington, DC
February 27-28, 2014
Hosted by: Georgetown Law
*Alexandra Wrage, TRACE President, speaking


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


The 2nd Global Anti-Corruption Congress
Washington, DC
March 20-21, 2014
Hosted by: Momentum
TRACE Members receive a 15% discount. 


Mexico Summit on Anti-Corruption  

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

Sydney, Australia
March 25-26, 2014
Hosted by: C5
TRACE Members receive a 10% 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.


Anti-Corruption Spain
Madrid, Spain
March 26, 2014
Hosted by: C5
TRACE Members receive a 10% discount. 


4th Annual Oil & Gas Supply Chain Compliance Week
Houston, TX
April 14-17, 2014
Hosted by: Hanson Wade
*Alexandra Wrage, TRACE President, speaking  


Ethics and Anti-Corruption / Bribery Programs - Internal Audit's Role
May 13, 2014
Hosted by: The Institute of Internal Auditors Canada
*Alexandra Wrage, TRACE President, speaking  


European Compliance & Ethics Institute

London, UK 

May 18-21, 2014 

Hosted by: Society of Corporate Compliance and Ethics 

*Alexandra Wrage, TRACE President, speaking

International Regulatory Updates


Pinsent Masons LLP


The Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Bill 2013 is currently before the UK Parliament. When enacted, it will impose statutory registration for consultant lobbyists (commercial consultants but not in-house lobbyists) and establish a Registrar to enforce the registration requirements


Additional legislation is proposed specifically for Scotland in the form of the Lobbying Transparency (Scotland) Bill. If enacted, that Bill, as currently drafted, will require commercial lobbyists and those working in-house to register and to comply with the conditions of registration.


Czech Republic

Squire Sanders, v.o.s., Advokátní Kancelář


In Czech Republic, significant changes to the legislations were made as of January 01, 2014, including but not limited to the following:

  • Non-exclusive relationship with a commercial intermediary is now a default relationship for both sales representative and indirect agents, unless agreed otherwise by the contracting parties.  
  • Although contractual agreements could only be terminated for cause before, now agreements may be terminated by a decision of court based on the circumstances.
  • Currently, a government official is not obligated to wait a specific period of time before working as a business intermediary promotion sales to the government.  However, starting on January 01, 2015, top officials will have to wait 2 years before engaging in business in the field in which they performed civil service.


Tilleke & Gibbins International Ltd.


In Thailand, there has been continued efforts to comply with the United Nations Convention Against Corruption, since the Thai government ratified it on March 31, 2011.  Such efforts include, but are not limited to, the following:

  • In 2012, the National Anti-corruption Commission set up conditions under which contractors of large public projects must provide detailed income and expenditure accounts, and submit such information to the Department of Revenue for review in order to raise the transparency level of what had previously opaque procurement contracts. 
  • In 2013, there has been significant developments in the implementation of regulation to establish Provincial Anti-Corruption Committee for each province, which shall have the power to investigate corruption complaints initiated by the locals.

Kyrgyz Republic

Kalikova & Associates


In the Kyrgyz Republic, in addition to the general prohibition of gift giving to government officials or public servants, actions or inactions of state officials and local municipal authorities in relation to gift giving, providing material and other benefits are now considered offences pursuant to the Law of the Kyrgyz Republic "On Anti-Corruption, dated August 8, 2012.

News & Press 

27 January 2014

Compliance Week 

27 January 2014

The FilAm Metro DC

14 January 2014

All About Shipping

2 January 2014 

Corporate Counsel, Sue Reisinger



151 West Street
Annapolis, Maryland 21401
410-990-0076 | 410-990-0707 (fax)