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Compendium Roundup
Books, White Papers and Articles
Featured Resource
TRACE Scholar Program
Partner Events
International Regulatory Updates
News & Press
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June 2014
Compendium Roundup

This month, FedEx Corp. voluntarily disclosed to the U.S. Department of Justice ("DOJ") and the U.S. Securities and Exchange Commission ("SEC") possible bribes to government officials in Kenya.  According to a report by the Wall Street Journal, FedEx received an anonymous tip by email in December 2013 with allegations of bribery in Kenya starting in 2010.  The alleged bribes went to customs officials to clear shipments without inspection, as well as to government vehicle inspectors and others.


Smith & Wesson announced that the DOJ ended its four-year FCPA investigation of the company and declined to bring criminal charges.  Smith & Wesson first came under scrutiny in connection with the 2010 Africa Sting operation, in which FBI agents posed as African government officials seeking to purchase equipment.  Smith & Wesson's former Vice President-Sales, International & U.S. Law Enforcement, was indicted in connection with the Africa Sting operation.


Dodd-Frank Conflict Mineral Disclosure Deadline Reached - June 2, 2014 was the first filing deadline for SEC issuers to comply with the SEC's conflict minerals rule under Dodd Frank.  Listed companies must report to the SEC under the statute as to what due diligence measures they undertook regarding any conflict minerals in their chain of custody.


China Continues Arrests of Top-Level Officials as Part of Official Anti-Graft Campaign - In recent weeks, Wan Qingliang party chief of Guangzhou, Xu Caihou, a former vice-chairman of the powerful Central Military Commission, and Su Rong, vice-chairman of China's parliamentary advisory body have all been fired or are under investigation for corruption.  Thousands of Communist party officials have been investigated for corruption since President Xi Jinping took power two years ago.

SEC Brings First Anti-Retaliation Case Under Dodd-Frank Act Whistleblower Provisions - In an administrative proceeding against Paradigm Capital Management, an investment adviser to private funds, the SEC alleged that the company had demoted a head trader and removed him from his trading and supervisory responsibilities after he'd disclosed infractions by the company to the SEC.  The company was penalized $2.1 million and ordered to hire an independent compliance consultant.

Qatar FIFA Bribery Scandal Heats Up - Earlier this month, the

Sunday Times of London reported that it was in possession of millions of secret emails, bank statements, and letters that allegedly prove that a Qatari official made USD $5 million worth of bribes in order to influence Qatar's bid to host the 2022 World Cup.  Since the news broke, numerous FIFA sponsors have threatened to back out of the games and there's been mounting pressure that Qatar be stripped of its right to host the tournament.

Second Circuit Affords Significant Deference to SEC Consent Settlements - The Second Circuit held that a court cannot require an admission of liability as a condition for approving a negotiated settlement. On appeal from a district court order refusing to enter a consent decree between the SEC and Citigroup, the Second Circuit accorded the SEC "significant deference" in deciding whether a consent decree serves the public interest.  The ruling preserves the SEC's discretionary use of Deferred Prosecution Agreements, a modern bedrock of the corporate federal regulatory enforcement regime.


Vote now on the TRACEblog

Test your knowledge of the murky world of bribery and the flourishing field of compliance with our new weekly quiz. Authored by TRACE President, 
Alexandra Wrage, the Wednesday InterWRAGEtory will feature a new multiple choice question related to anti-bribery and corruption each week. In addition to providing an entertaining way to test your knowledge of anti-bribery facts, the quiz can be used to enhance any training program. 
Sign up for our mailing list to receive weekly reminders when the next question is posted. You can also use our Contact Us page to suggest new topics and questions for inclusion in the quiz. 
June Quiz Questions:
June 18, 2014
Sani Abacha, dictator of Nigeria from 1993-1998, is estimated to have stolen how much from the people of Nigeria?
Click here to answer. 
June 25, 2014
How many companies have been prosecuted under the 2010 UK Bribery Act?
Click here to answer. 
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.
18 June 2014, Thomson Reuters Checkpoint
By: Martha Mallory and Lianne L. Worden
Featured Resource: Complimentary TASA Course

As a sample of our TASA (TRACE Anti-Bribery Specialist Accreditation) program and course catalog material, we are pleased to offer you complimentary access to our upcoming webinar on anti-bribery compliance audits. This course will be taught by Eileen Radford, Director of Advisory Services at TRACE, and will address how and when companies are expected to perform anti-bribery audits, what should be tested and how to follow up and preserve information on an audit's findings.  
Complimentary Course Details:


Anti-Bribery Compliance Audits - A Checklist of Essentials

Date: 23 July 2014

Time: 12:00 - 1:15 pm EST

Faculty: Eileen Radford, Director of Advisory Services, TRACE 


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
Upcoming live TASA courses:
9 July 2014
Faculty: Severin Wirz, Manager of Advisory Services, TRACE
23 July 2014
Faculty: Eileen Radford, Director of Advisory Services, TRACE
*Complimentary TASA course
July 15-16, 2014 * Washington, DC
India Summit on Anti-Corruption 
September 22-23, 2014 * New Delhi, India
FCPA Boot Camp West
September 29-30, 2014 * San Francisco, CA


Upcoming live TASA accredited TRACE events:

July 29, 2014, Vancouver

To inquire about discounts and credits, write to  
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.  


Vancouver, July 29, 2014
View agenda details here
To request an invitation or suggest locations for  upcoming events, please write to
Save the Date: 11th Annual TRACE Forum
 The 11th Annual TRACE Forum will be held March 25-26, 2014 at the St. Regis in Washington, DC. TRACE members should plan now to attend what has become the premier anti-bribery benchmarking conference. 
The Forum program is currently under development. Please visit our Forum webpage for program updates and registration details. For questions, please write to
On June 26, 2014, TRACE International announced the inaugural recipients of the TRACE Scholar Program, fully-funded scholarships for two international LLM students from developing countries who will be pursuing studies aimed at increasing transparency and reducing corruption.

The two TRACE Scholars are:
  • Ernesto Alejandro Valasco Granda of Ecuador, who will attend the Maryland Carey School of Law;
  • Chitra Nair of India, who will conduct her studies at University of Washington School of Law.
Each scholar will receive full tuition, lodging and travel from their home country to the U.S. where they will each spend a full academic year studying anti-corruption, business ethics, governance and related issues.

"Response to the call for applications was overwhelming," said Alexandra Wrage, President of TRACE. "Hundreds of professionals submitted their credentials. It's a clear indication that individuals and organizations increasingly recognize the inherent value in ethical, compliant business practices and want to implement those values in their business dealings and home countries."
Read the full press release here

TRACE International announced three new partnerships
in Ghana, Hungary and Turkey on June 19, 2014. These strategic alliances are part of TRACE's continued effort to advance commercial transparency and to promote a global standard for third party due diligence. 

These recent partnerships include:
  • EuCham CEE, a private, non-governmental institution working to enhance the business environment for companies operating in Europe; and
  • Ethics and Reputation Society, or TEID, a nonprofit organization dedicated to building a robust and ethical business culture in Turkey.
    Over the last year, TRACE has responded to the growing demand for anti-bribery and third party compliance solutions by establishing an on-the-ground presence in Dubai, Manila and New Delhi and developing partnerships with the American Chambers of Commerce in Zambia and Libya and the Makati Business Club in the Philippines.  
Click here to view the press release.


Buenos Aires, Argentina
July 10-11, 2014
Hosted by: Compliance LATAM
*Martha Mallory, Latin America Regional Manager, 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   




Pro-Active Defenses Against White Collar Crime in China 

Seattle, WA
August 14-15, 2014

*Alexandra Wrage, TRACE President, speaking


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


Miller Thomson LLP (

The Federal Accountability Act established a regime for allegations of wrongdoing by government agencies to be investigated and for whistleblowers to seek protection from reprisals. The Act created the Public Sector Integrity Commissioner who receives complaints and conducts investigations. The wrongdoings complained of may come from public servants or members of the public. Along with this Act and the Public Servants Disclosure Protection Act, individuals and companies may make anonymous complaints or ask the Commission to keep their identity confidential.


K & L Gates LLP 


Recently, in China, as part of the nationwide crackdown on official bribery and as part of the campaign for constructing clean government, a series of regulations have been further promulgated in 2013, including the Rules on Strictly Enforcing the Combat against Waste within the Party, and the Regulations on Domestic Official Receptions for Party and Government Organizations. These regulations prohibit acceptance by party and government officials of any cash, marketable securities, vouchers, souvenirs and local specialties, etc. and impose restrictions on meals provided to officials. Also, leisure trips in disguise as business travel and any other trips irrelevant to official activities or beyond prescribed standards are expressly prohibited. 


Additionally, the Ministry of Supervision under the Central Discipline Inspection Commission launched a new tool to facilitate reporting of bribery and other corruption behaviors by government officials and Communist Party of China members in September 2013. The website is available at: with a hotline 12388. Both the website and the hotline accept anonymous/confidential reports or reports made on a real-name basis.



New Partner Firms:




Mayer Brown JSM



David Harrison, Consultant

Suite 1705-1709, 17th Floor, Saigon Tower 

29 Le Duan, District 1

Ho Chi Minh City


Tel: +848 3513 0300

Fax: +848 3822 8864


Nguyen Hoang Anh, Partner

12th Floor, Pacific Place
83B Ly Thuong Kiet Street, Hoan Kiem District

Tel: +844 3825 9775

Fax: +844 3825 9776





Mourant Ozannes (Guernsey)


Mr. Jeremy Wessels, Partner

Mr. Alex Horsbrugh-Porter, Senior Associate

PO Box 186

1 le Marchant Street

St Peter Port



Tel: +44 1481 731 439;  +44 1481 731 450

Fax: +44 1481 727 935




Cayman Islands

Mourant Ozannes (Cayman Islands)


Mr. Simon Dickson, Partner

94 Solaris Avenue

Camana Bay

P.O. Box 1348

Grand Cayman


Cayman Islands

Tel: +1 345 949 4123

Fax: +1 345 949 4647





DFDL (Lao) Sole Co., Ltd


Mr. Rupert Haw, Senior Regional Counsel & Managing Director, Lao PDR

Phai Nam Road, House 004 Xieng Yeun Village (PO Box 2920)

Vientiane, Lao PDR

Tel: +856 21 242 068

Fax: +856 22 218 422

News & Press



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