The U.K.'s Serious Fraud Office ("SFO") was particularly active in July.  The SFO started criminal proceedings against Alstom S.A.'s U.K. subsidiary, Alstom Network U.K. Ltd., charging it with three corruption offenses, and three counts of conspiracy to corrupt based on allegations that the company paid millions of dollars in bribes to win contracts concerning large transport projects in India, Poland and Tunisia. The SFO also began a formal investigation into U.K.-based construction services company, Sweett Group.  The investigation is based on allegations that a former Sweett Group employee, based out of Dubai, offered to award design work on a USD $100 million hospital construction contract in Morocco to a New York-based architecture firm, if it agreed to pay a bribe to a United Arab Emirates official.  In another case, four employees of Airbus S.A.S. were arrested as part of the SFO's criminal investigation into allegations that the company gave Saudi Arabian officials cars, jewelry, and cash to win a USD $3.38 billion communications contract.  In addition, a former CEO of Aluminium Bahrain BSC ("Alba") began a sixteen-month prison term in the U.K. after being charged by the SFO for paying bribes to former Bahraini officials between 1998 and 2006 in return for raw material supply contracts for Alcoa worth over USD $3 billion.

On the U.S. anti-corruption front, Smith & Wesson Holding Corporation agreed to pay USD $2 million to the U.S. Securities and Exchange Commission ("SEC") to settle charges that it violated the U.S. Foreign Corrupt Practices Act ("FCPA"), after last month receiving a declination from the U.S. Department of Justice ("DOJ") for its role in the Africa Sting Operation.  The SEC alleged that Smith & Wesson's international sales staff attracted new business by providing illegal payments and gifts to government officials in Pakistan, Indonesia, Turkey, Nepal, and Bangladesh in violation of the FCPA.

There have also been developments for GlaxoSmithKline plc, Japan Transportation Consultants Inc., Glenn Defense Marine Asia, Deutsche Bank AG, Finmeccanica S.p.A., and Bizjet International Sales and Support, Inc.

The 2014 TRACE Commission Benchmarking Project provides data on the average commission rates paid to third parties on a country-specific basis for business-to-government deals based on four deal sizes. Each segment covers four or five countries within a region. The results for the South America segment are now available. Companies that participated should have received a copy of the results. If you participated but did not receive a copy, please email hsieh@TRACEinternational.org. 

You may now access the survey for the Middle East segment, which includes Saudi Arabia, Israel, United Arab Emirates, Oman and Egypt, here. Survey responses are submitted anonymously, so please register your company's participation via email to hsieh@traceinternational.org to receive a copy of the results. 

Please submit only one response per company by Friday, August 15th. 

Poll - July's Biggest Bribery Development

Take a moment to take our poll and vote for which headline you think was most newsworthy this month:

1. UK's Serious Fraud Office Charges Alstom Network UK with Corruption: The investigation, which commenced as a result of information provided to the SFO by the Office of the Attorney General in Switzerland, concerns large transport projects in India, Poland and Tunisia in the early 2000s. None of the charges fall, however, under the UK's 2010 Bribery Act.
2. China Launches Formal Investigation of Zhou Yongkang for Graft: China put an end to years of speculation when it brought charges this month against Mr. Zhao, who was formerly in charge of the country's entire state security, courts, police and paramilitary forces until retiring two years ago.
3. U.S.-based Firearms Manufacturer to Pay $2 million to Settle SEC Corruption Charges:  Smith & Wesson Holding Corporationagreed to pay $2 million to the U.S. Securities and Exchange Commission to settle charges that it violated the U.S. Foreign Corrupt Practices Act, after last month receiving a declination from the U.S. Department of Justice for its role in the  Africa Sting Operation.
4. U.S. Corruption Trial of Former Virginia Governor Bob McDonnell Begins:  McDonnell and his wife were indicted in January on federal corruption charges following a months-long federal investigation into gifts McDonnell received from a political donor.  The former Governor has adopted a unique defense strategy, claiming that his marriage was too unhappy and disjointed for either partner to have conspired with the other to accept bribes.
5. More Whistleblowers Come Forth in GSK Bribery Investigation: Starting in China, bribery claims against British drug maker GlaxoSmithKline have surfaced in other countries as well over the past year, including Poland, Iraq, Jordan and Lebanon.  This month, allegations emerged that the company paid bribes to Syrian doctors, dentists, pharmacists and government officials to win tenders and to obtain improper business advantages.

TRACE is pleased to announce the release of its Conflicts of Interest online training module, the most recent addition to our customizable online training platform. There are many circumstances which constitute or may give rise to a conflict of interest in the normal course of business, and often, they are misunderstood or overlooked by employees and third parties. Using hypothetical examples, this interactive course aims to help employees and intermediaries recognize different types of conflicts of interest in the workplace. The course also provides guidance on the appropriate action to take when faced with an apparent or potential conflict of interest.

• 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.

How McDonald's, KFC, Others Can Recover From Chinese Food Scandal: Experts 

22 July 2014

Connor Adams Sheets, International Business Times

HBO Real Sports: The Price of Glory in Qatar Web Extra #2 (July 2014) (HBO Sports)

23 July 2014

HBO Sports