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Compendium Roundup
Books, White Papers and Articles
Featured Resource
Partner Events
International Regulatory Updates
News & Press
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May 2014
Compendium Roundup

This month, Chinese prosecutors filed criminal charges against a former executive at GlaxoSmithKline plc ("GSK").  According to police in Changsha, Hunan province, the former chief executive officer of GSK China ordered his sales teams to bribe doctors and hospitals to achieve the company's sales targets.  Two other GSK executives allegedly helped execute the bribery scheme, which may have netted the company revenue worth billions of yuan.  Criminal charges of bribery carry a maximum sentence of life in prison in China.


A former co-CEO of PetroTiger Ltd. was indicted by a federal grand jury this month and charged with violating the FCPA.  He will go to trial in connection with allegedly bribing a Colombian official and orchestrating a kickback scheme.


There have also been developments for Johnson Controls Inc., Teva Pharmaceutical Industries Ltd.Key Energy

Services Inc., and Fresenius Medical Care AG.

  1. Conflict Mineral Disclosure Deadline Approaches. The Appellate Court for the District of Columbia denied the National Association of Manufacturer's emergency stay motion to block the SEC's conflict minerals rule.  Meanwhile, lntel Corporation filed its conflict minerals report with the SEC in advance of the June 2 deadline, noting that some of their suppliers were in fact "DRC conflict undeterminable."
  1. 11th Circuit Court Rules on Definition of "Instrumentality" under the FCPA In a landmark ruling affirming the sentences of Joel Esquenazi and Carlos Rodriguez, the court upheld a multi-factor test used to determine that Telecommunications D'Haiti, S.A.M. (Teleco) was an "instrumentality" of the government and its employees were therefore "foreign officials" as defined by the FCPA.
  1. PetroTiger CEO Indicted for FCPA Violations. Joseph Sigelman, chief executive officer of the oil and gas services company PetroTiger, Ltd., was indicted by Grand Jury in New Jersey on May 9, 2014. The indictment charges that Sigelman negotiated the terms of a kick-back scheme and paid $333,500 in bribes to obtain approval from Colombia's national oil company, Ecopetrol S.A., for a $39.6 Million contract. The payments were masked as "consulting services" conducted by an official's wife on behalf of PetroTiger.
  1. Guatemala's Former President Faces U.S. Jail Time for Bribery. In March, Alfonso Portillo, President of the Republic of Guatemala from 2000 to 2004, admitted to accepting $2.5 Million in bribes from Taiwan and laundering the money through U.S. banks. In a May 12 court filing, U.S. Prosecutors sought a minimum jail sentence of 5 years 11 months in addition to time served since his arrest in 2010.
  1. EU Data Privacy Ruling Establishes "Right to be Forgotten" Online. The European Court of Justice determined that, in the absence of a justified public interest, an individual has the right to have information about them removed from online search results at the expense of the search engine operator. 
Vote now on the TRACEblog
Books, White Papers and Articles

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


From the cover: Revisit the furtive corporate backroom dealings of  bribery and corruption in this second collection of works by authors, journalists, prosecutors and bribery experts from around the world. Behind the newspaper headlines and government investigations, these are the true to life stories of what leads people down bribery's crooked path. Explore the unscrupulous lengths to which some will go in order to win business, from using shady offshore front companies in the British Virgin Islands to setting up bogus charities in Eastern Europe. Whether you are a seasoned compliance expert or new to the field, each chapter in this collection offers practical advice while remaining an immensely engaging read.

The Global Enforcement Report (GER), now in its fourth year of publication,
provides graphic and textual analyses of all known enforcement actions-including investigations, prosecutions, settlements and cases settled with no finding of bribery-since the first bribery cases were prosecuted in the United States following the enactment of the FCPA.


View the full press release here. Download the complete GER with charts and further analysis here.
Featured Resource: Toxic Transactions

The highly acclaimed anti-bribery training video,

"Toxic Transactions: Bribery, Extortion and the High Price of Bad Business," hosted by TRACE President Alexandra Wrage, is now available to TRACE Members as part of their membership package at no additional cost.


Lively and informative, and featuring internationally renowned anti-bribery experts, "Toxic Transactions" offers practical insights into global anti-bribery laws and enforcement trends, making it the perfect addition to your training program. As an added benefit, users of our online anti-bribery training module may add the video as a course and share it with an unlimited number of employees and third parties.


Watch a seven-minute clip of the video here.


Please write to for more information about the benefits of TRACE Corporate Membership.  

TRACE Anti-Bribery Specialist Accreditation (TASA) 

TASA is the only accreditation program available that is dedicated to anti-bribery compliance and offers over 100 courses taught by a 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. To learn more about TASA, view the catalog. To enroll in the TASA program, please write to
June 24-25, 2014 * Chicago, IL
July 15-16, 2014 * Washington, DC


Upcoming live TASA accredited TRACE events:

June 18, 2014, Washington, DC

July 29, 2014, Vancouver

To inquire about discounts and credits, write to  
This month, TRACE co-hosted an executive roundtable in Brazil with Chediak Advogados. Senior compliance professionals and leaders from a wide variety of industries gathered to discuss anti-bribery challenges in Brazil as well as the new Clean Companies Act. Several issues were raised including compliance versus bureaucracy, training and communications and the characteristics of an effective compliance officer. The roundtable discussion was led by Virna Di Palma of TRACE and Rafael Mendes Gomes of Chediak Advogados. If you wish to receive a copy of the roundtable presentation, please write to Virna Di Palma at

TRACE Roundtables offer senior-level compliance professionals an opportunity to participate in an advanced discussion on the latest anti-bribery enforcement trends and compliance best practices. Roundtables are limited to 20 participants and are led by a TRACE representative and special guest speaker. Upcoming roundtables are listed below.  
Washington, DC, June 18, 2014
View agenda details hereThis roundtable is being held exclusively for senior-level leaders in the field of anti-bribery compliance and is an invitation-only event.


Vancouver, July 29, 2014
View agenda details here
To request an invitation or suggest locations for  upcoming events, please write to





June 3-4, 2014
Hosted by: International Bar Association
*Severin Wirz, Manager, Advisory Services, speaking
London, UK
June 5-6, 2014
Hosted by: Momentum
TRACE Members receive a 15% discount. 
*Severin Wirz, Manager, Advisory Services, speaking

Shanghai, China
June 17-18, 2014
Hosted by: American Conference Institute
TRACE Members receive a $200 discount. 

Chicago, IL
June 24-25, 2014
Hosted by: American Conference Institute
TRACE Members receive a $200 discount. 

London, UK
June 24-25, 2014
Hosted By: C5
TRACE Members receive a 10% discount.
*Eileen Radford,  Director, Advisory Services, speaking 

Grange Tower Bridge Hotel, London, UK
June 24-26, 2014
Hosted by: IBC Legal
TRACE Members receive a 10% discount.
*Eileen Radford, Director, Advisory Services, speaking 

Basel, Switzerland
June 26-27, 2014
Hosted by: B20 Collective Action Hub
*Virna Di Palma, Senior Director, Global Strategy & Communications, speaking


Financial Crimes Detection Workshop
Washington, DC
July 14-18, 2014
Hosted by: International Monetary Fund/World Bank/Federal Reserve System
*Alexandra Wrage, TRACE President, speaking


5th Global Forum on Anti-Corruption Compliance in High Risk Markets
Washington, DC
July 15-16, 2014
Hosted by: American Conference Institute   



For a complete list of upcoming events, visit the Anti-Corruption Event Calendar on our website. 
International Regulatory Updates



In Italy, the Presidential Decree n. 62 of 16 April 2013, entered into force on 19 June 2013, has abrogated the Code of Conduct for Public Employees and introduced a new and far more reaching Code of Conduct applicable to public employees, including military officials. Among the new restrictions, public employees are now prohibited from accepting collaboration agreements with private persons or entities which have or had, in the two previous years, a significant economic interest in decisions or activities related to the public employee's office.





New Ecuadorian Criminal Code (COIP) was signed into law in February 2014, and will take effect on August 11, 2014. Under the new Code, there is no specific prohibition against the bribing of owners, employees or directors of private, non-government customers. "Bad" actions that are not specifically and clearly typified in the law, are not punishable under the law. However, banks and most other financial institutions in Ecuador may be punished for violations of the Public Trust that cause economic harm. Therefore, it is likely that the bribing of owners, employees or directors of private, non-government customers by the owners, employees or directors of banks or other financial institutions, and that causes economic harm, is prohibited.


New Partner Firm Announcement:


South Africa

ENS Forensics (Proprietary) Limited 

Mr. David Loxton, Co-Head of Forensics

150 West Street

Sandown, Sandton, Johannesburg, 2196

South Africa

Tel: 011 269 7600

Fax: 011 269 7899

News & Press
Supply Chain: No Easy Fix
7 May 2014
IndustryWeek, Jill Jusko



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