In This Issue
Books, White Papers and Articles
Featured Resource
TRACE Workshops
TRACE Roundtables
TRACE Webinars
Partner Events
International Regulatory Updates
News & Press
New TRACE Scholar Program
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February 2014
  1. Thailand's Prime Minister Charged with Corruption.   Thailand's prime minister, Yingluck Shinawatra, was charged by Thai authorities for irregularities in the government's rice buying scheme, under which the government was paying prices 50% higher than world prices. Following the high profile investigation, China canceled a deal to buy 1.2 million tons of rice in early February.
  2. Double Declination for Baxter.  Pharmaceutical company Baxter International announced that both the DOJ and SEC have completed their investigations and will not take further action.  Following a whistleblower complaint, the company investigated allegations and found improper expense payments by a Chinese joint venture in August 2013.
  3. Alstom Faces UK Bribery Charges After 5-year Probe.  Alstom, the French maker of trains and power equipment, will be charged in the U.K. over bribery allegations after a five-year investigation.  The U.K. is the latest country to charge Alstom following fines in France, Switzerland, Brazil and the U.S.
  4. Congress to Investigate Navy Bribery Scandal.  The House Oversight and Government Reform Committee opened an investigation into the unfolding Navy sex-and-bribery scandal following Rep. Darrell Issa's concerns that the Navy's investigations and reviews "will not go far enough."  In return for paid travel and prostitutes, a naval commander allegedly sent classified information to a government contractor.
  5. Siemens Executives Ordered to Pay Largest Penalties Ever Levied Against Individuals. Two former Siemens executives were ordered to pay a combined $1.46 million for their roles in the Argentine government bribery scheme, the largest FCPA penalties ever levied against individuals.  U.S. District Judge Shira Scheindlin entered a default judgment, ordering each to pay a $524,000 civil penalty, and one to pay disgorgement of $413,957.
Vote now on the TRACEblog
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 publishing the 2013 edition. This edition is scheduled to be released in early 2014. 

For questions, please write to


December 2013 | Elizabeth Judd, Foundation for Public Affairs


The 2013 Global Enforcement Report (GER) is coming soon. Stay tuned for its release.  

Featured Resource: New Anti-Bribery Training Vignettes 

We are pleased to provide you with 9 new Anti-Bribery Training Vignettes to supplement your anti-bribery training program. These timely and insightful videos are now available in the TRACE Resource Center, accessible on our website through your "My TRACE" login. Anti-Bribery Training Vignettes are short, 3-10 minute videos offered by TRACE to enhance your training curriculum. Topics cover a broad range of bribery issues including country-specific compliance challenges and enforcement trends, anti-corruption audits, government investigations and third party screening.

 The New Videos Include: 

  • 2013's Top 5 Compliance Takeaways
    Martin Weinstein, Partner, Willkie Farr & Gallagher LLP
  • Anti-Bribery Enforcement in China-How to Minimize Your Exposure
    Kelly Austin, Partner, Gibson, Dunn & Crutcher LLP
  • Anti-Corruption Audits and How to Leverage the Results
    William B Jacobson, Senior Vice President, Co-General Counsel, Chief Compliance Officer, Weatherford International
  • Compliance Program Enhancements During and Post-Investigation
    Timothy L Dickinson, Partner, Litigation Department Paul Hastings LLP
  • Top Three Bribery Risks to Watch Out for in Latin America*
    Matteson Ellis, Special Counsel/Abogado, Miller & Chevalier Chartered
  • Top Three Takeaways from the FCPA Guidance
    Jamie Parkinson, Partner, BuckleySandler, LLP
  • Top Three Tips for Building a Culture of FCPA Compliance
    Rebecca Goldman, Vice President, Commercial Law, Rockwell Automation
  • Why M&A Due Diligence Wont Prevent an FCPA Violation
    Sharie A Brown, Partner, Troutman Sanders LLP

For more information on accessing the TRACE Resource Center or setting up a login, please write to


If you have an idea or request for the next installment of our Anti-Bribery Training Vignette Series or if you would like to participate, please write to Virna Di Palma at

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:
March 11 | Reagan R. Demas, Partner,  Baker & McKenzie LLP


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:
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 Calgary on March 18, 2014


For more information or to request an invitation to this event, please write to
10th Annual TRACE Forum 
March 26-27, 2014, St. Regis

TRACE is delighted to announce  that
Patrick Stokes, the new Deputy Chief of the DOJ's FCPA Unit, will be speaking at  the 10th Annual TRACE Forum in Washington, DC.  Patrick Stokes will be joined by Tracy Price, Assistant Director of the SEC's FCPA Unit, on the opening panel entitled, "The US DOJ and SEC Discuss FCPA Enforcement Priorities and Compliance Takeaways from Recent Cases." The panel will be moderated by Charles Duross, Partner with Morrison & Foerster LLP, who formerly served as Deputy Chief of the DOJ's FCPA Unit.
We look forward to welcoming over 100 TRACE member companies to the Forum. The registration list for this popular event has now reached capacity and we regret that we are unable to take any additional registration requests. 


We have also reached the nomination deadline for the TRACE Innovation in Anti-Bribery Compliance Award. Thank you for your nominations and enthusiastic response to the award. We look forward to announcing the winner at the Forum reception on March 26, 2014. 


Please remember to to submit your benchmarking questions in advance of the Forum by writing to  


TRACE Webinars


TRACEcertification: Transparency as a Competitive Advantage for SMEs


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. 



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. 
*Julie Coleman, Director, Advisory Services, speaking


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.


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


Anti-Corruption France
Paris, France
May 13, 2014
Hosted by: C5
TRACE Members receive a 10% discount. 


Anti-Corruption North Africa
Paris, France
May 14-15, 2014
Hosted By: C5

TRACE Members receive a 10% discount. 
*Severin Wirz, Manager, Advisory Services, speaking 


European Compliance & Ethics Institute

London, UK 

May 18-21, 2014 

Hosted by: Society of Corporate Compliance and Ethics 

*Alexandra Wrage, TRACE President, speaking


Global Anti-Corruption & Compliance in Mining
London, UK
May 27-30, 2014
Hosted by: Resourceful Events
TRACE Members receive a 25% discount.
*Alexandra Wrage, TRACE President, speaking

International Regulatory Updates


ACI Partners


In Moldova, a new government decision regulating the limit of symbolic gift value went into effect on 01 March 2013.  The decision regulates the procedure for gift assessment, recording, storage, use and re-purchase, sets the limit of diplomatic or courtesy gift's value at MDL 1,000 (about EUR 60) and provides for a Committee responsible for assessing and recording gifts. 


Bosnia & Herzegovina

Karanovic & Nikolic


In Bosnia & Herzegovina, a new law on the Protection of Persons Reporting Corruption in the Institutions of Bosnia and Herzegovina was recently enacted.  The new law explicitly stipulates that any whistleblower employed within state-level institutions of Bosnia and Herzegovina  will be protected by the Agency.



AB & David


The Code of Ethics for Ministers and Political Appointees in Ghana, released in September 2013, states that a Minister may retain gifts received in Ghana or overseas, provided the estimated value of the gift is not more than GHȻ200.00 (about a $100). If the estimated value of the gift is GHȻ200.00 or more, the gift may be retained while in office but must be declared in the interest of the individual.


Additionally, the Bank of Ghana has recently reiterated its position that all transactions in Ghana are required to be conducted in Ghana cedis. Furthermore, effective 05 February 2014, the Bank of Ghana has revised the mode of operation for the Foreign Exchange Accounts and Foreign Currency Accounts.



Magnusson Law Firm


In 2012, the European Union adopted rules making it obligatory for member states to establish an anonymous whistleblower arrangement at a government agency for employees in the financial sector.  The Danish rules implementing such was scheduled to enter into force on 01 January 2014, however, it has been postponed and is expected to enter into force later in 2014.  Under this rule, the whistleblower arrangement must be registered with and approved by the Danish Data Protection Agency.  The rule will be particularly relevant within the financial sectors, where bank employees will be able to anonymously contact a government agency, specifically the Danish Financial Supervisory Authority, to report any suspected irregularities in the management of the bank.


New Partner Firm Announcement:


United Arab Emirates

Reed Smith LLP

Peter Michelmore, Senior Partner - Middle East (

Level 14, Al Sila Tower

Sowwah Square

Al Maryah Island

P.O.Box 46904

Tel: +971 2 491 2770

Fax: +971 2 622 2625

News & Press

Anti-bribery U.S. nonprofit opens branch in Philippines

10 February 2014 | Maricar CP Hampton, FilAm Star
10 February 2014 |  C5
6 February 2014 | Jennifer Koons, Main Justice

New TRACE Scholar Program

TRACE International is delighted to announce its new Scholar Program aimed at developing exceptional young leaders in the field of anti-corruption who are committed to advancing commercial transparency. The TRACE Scholar Program will fully fund, with tuition, lodging and travel, three international LLM students to pursue studies related to strategies and tools for increasing transparency and reducing corruption.  TRACE Scholars will spend an academic year at one of three universities, followed by a paid summer internship at TRACE headquarters in Annapolis, Maryland. Additional details coming soon.



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