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Country Risk Profile (Greece)
Recently Added: 
Animated Anti-Bribery Training Vignettes, Country Risk Profiles (Greece, Kazakhstan, Pakistan), 
Russia/Ukraine Conflict Sanctions Guide, Magnitsky Sanctions Guide

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January 2015
Compendium Roundup

The US Securities & Exchange Commission ("SEC") kicked off the year by levying $3.4 million in US Foreign Corrupt Practices Act ("FCPA") fines against Florida-based engineering and construction firm The PBSJ Corporation ("PBSJ") and fining one of PBSJ's former officers $500,000.  According to the SEC, the former PBSJ officer, Walid Hatoum, offered to bribe a foreign official to access confidential sealed-bid and pricing information to enable PBSJ to win bids for a hotel resort development project in Morocco and a light rail transit project in Qatar.  The SEC did not go to court for the case, entering into a two-year Deferred Prosecution Agreement ("DPA") with PBSJ and an administrative order against Hatoum.  WS Atkins plc acquired PBSJ in 2010, and the company is now known as The Atkins North America Holdings Corporation.


In other FCPA news, a federal grand jury in Philadelphia indicted Dmitrij Harder, the former owner and president of Chestnut Consulting, Inc. ("Chestnut Consulting"), for bribing an official of the European Bank for Reconstruction and Development ("EBRD").  According to the criminal indictment, Mr. Harder allegedly paid more than USD $3.5 million to an EBRD official in exchange for the approval of financing for two of Chestnut Consulting's corporate clients by the EBRD.  Chestnut Consulting allegedly earned about USD $8 million in "success fees" as a result of the EBRD's approval of the two applications, according to the U.S. Department of Justice ("DOJ"). 


In the U.K, Graham Hill, a former director of Alstom S.A. ("Alstom"), was charged by a British court with corruption and conspiring to dishonestly obtain services in relation to transportation contracts in India and Poland.  Two of the charges relate to Mr. Hill corruptly giving or agreeing to give payments totaling INR 23,020,000 to an officials of the Delhi Metro Rail Corporation Limited.  According to the allegations, the improper payments were given as inducements or rewards for favoring Alstom in relation to the award or performance of a contract with the Delhi Metro Rail Corporation.  Meanwhile, two individuals were acquitted of charges in relation to the U.K.'s Serious Fraud Office ("SFO") investigation of News Corporation ("News Corp.").  Former employees John Edwards and John Troup were acquitted of all charges related to making improper payments to London police in exchange for classified information that was allegedly used in tabloid stories.  


Visit the TRACE Compendium to view the complete entries. 
January 2015 Poll

Vote for which story you think deserves the top spot in our monthly poll:

  1. Spain Enacts Tough New Corporate Compliance Law - Spain approved measures this month to reform its penal code (link in Spanish) which will increase penalties for crimes related to corruption, raises the statute of limitations, and limit political donations. Companies are also now required to adopt a compliance program and those that meet the requirements will be able to insulate themselves from certain criminal liability.
  2. EU Agrees to New Anti-Money Laundering Directive -  The European Parliament and the Council of the European Union agreed to a new anti-money laundering directive which requires EU member states to keep central registers of information on the ultimate beneficial owners of corporate and other legal entities, as well as trusts.  The full text of the directive can be accessed here.
  3.  PBSJ Corp. Fined $3.4 million for Violating FCPA to Win Qatari Gov. Contracts - The former Florida-based engineering and construction firm entered into a deferred prosecution agreement with the SEC this month, agreeing to pay $3.4 million in penalties and fines.  The President of PBSJ paid bribes to an official of the Qatari Diar Real Estate Investment Company in exchange for access to confidential sealed-bid information and pricing information on the two government contracts.  Read the full story on the TRACE Compendium
  4. Bank of New York Mellon Announces Expected FCPA SEC Action on Internships - In its January 23 filing, the Bank announced that it expected the SEC to bring charges against it for improperly hiring relatives of sovereign wealth fund officials.  The SEC began investigating financial institutions' relationships with sovereign wealth funds back in January 2011.
  5. OFAC Amends Regulations to Allow More U.S. Trade With Cuba - The Department of the Treasury's Office of Foreign Assets Control (OFAC) amended its Cuban Assets Control Regulations to implement policy changes announced by President Obama last month.  The amendments will allow for more activities related to telecommunications, financial services, trade, and shipping with Cuba.

Vote now on the TRACEblog 

Featured Resource: How to Say No Training Vignettes 
This month, TRACE added two new animated anti-bribery training vignettes to the TRACE Resource Center. The new "How to Say No" videos provide employees with practical tips and strategies to deflect requests for bribes or potentially inappropriate hospitality. The five minute videos are available in English, Spanish, Russian, Portuguese and Chinese. 
The animated training vignettes are available to TRACE Members in the TRACE Resource Center
Innovation in Anti-Bribery Compliance Award

TRACE is currently accepting nominations for the Innovation in Anti-Bribery Compliance Award 2015! The deadline for submissions is February 20th.

The Innovation in Anti-Bribery Compliance Award (IACA) honors a company that has developed an innovative compliance program or system and, in keeping with TRACE's philosophy, is willing to share its experience with the larger compliance community.

Eligible themes for nomination include Training Employees and/or Intermediaries, Third Party Due Diligence and Management, Gifts and Hospitality Management, Creating a Compliance Culture, and Recruiting and Hiring.

To find out more or to submit a nomination, please click here
TRACE Scholar Program

Each year, the TRACE Scholar Program, fully funds two scholarships for LLM (Master of Laws) students or professionals committed to enhancing transparency in business and government. The scholarships are awarded to applicants from developing countries who have demonstrated a commitment to reducing corruption.

The program provides emerging leaders and professionals with an interest in anti-corruption and bribery prevention with an intensive course of study followed by a practical and "hands-on" internship at TRACE headquarters in Annapolis, MD. TRACE Scholars study with students from a diverse range of countries to further enrich their understanding of regional challenges in reducing corruption.

Applications are now being accepted. Please click here to learn more. 
TRACE Anti-Bribery Specialist Accreditation (TASA)

Start the New Year off right by enrolling in TASA (TRACE Anti-Bribery Specialist Accreditation) before the year ends. TASA offers the most comprehensive, high-quality and easily accessible anti-bribery education on the market. Candidates have access to an extensive library of recorded webinars, as well as live webinars scheduled regularly throughout the year. Apply now to participate in live December courses.

TRACE members now have complimentary access to live TASA webinars. However, access to the online library of recorded courses and the TASA accreditation exam is limited to TASA candidates.

18 February 2015
Sgt. Pat Poitevin, Senior Investigator - Outreach Coordinator, Royal Canadian Mounted Police, Sensitive and International Investigations, National Division

3 March 2015
Michelle de Kluyver, Counsel, Allen & Overy LLP

18 March 2015
Thiago Jabor Pinheiro, Attorney, Mattos Muriel Kestener Advogados

To inquire about discounts and credits, write to 
TRACE Roundtables & Workshops
Upcoming 2015 roundtables and workshops will be announced soon. Please check the TRACE Member Activities page for updates. 

11th Annual TRACE Forum
The 11th Annual TRACE Forum will be held March 25-26, 2015 at the St. Regis Hotel in Washington, DC. Early registration ends on February 6, 2015. Click here to view the agenda. 
TRACE Corporate Members are invited to register now by writing to
Recent Events: Australia   
TRACE hosted two senior-level roundtable discussions in
Melbourne and Sydney during the month of January. We thank all attendees and speakers for their participation. 

Hosted by: AmCham India
February 13, 2014
New Delhi, India
*Alexandra Wrage, TRACE President, speaking

Hosted by: AmCham Turkey
February 20, 2015
*Alexandra Wrage, TRACE President, speaking

Hosted by: Advamed
February 23-25, 2015
Mexico City, Mexico
*A TRACE representative will be attending

Hosted by: American Conference Institute 
February 24 - February 26
Dubai, UAE
*A TRACE representative will be attending


Hosted by: Inside Intelligence
March 23-24
Houston, TX
*Severin Wirz, Director, Advisory Services, speaking

Hosted by: American Conference Institute 
March 24 - March 25
Moscow, Russia

Hosted by: American Conference Institute 
March 24 - March 26
Mexico City, Mexico 

Hosted by: SCCE
March 29 - April 1
London, UK
*Alexandra Wrage, TRACE President, speaking


For a complete list of upcoming events, visit the Upcoming Events Calendar on our website. 
International Regulatory Updates

The Act on Civil Service became fully effective on 01 January 2015.  Under the Act, the government may specify certain top officials to wait maximum 1 year and certain positions connected to public procurement and subsidy politics to wait maximum 6 months before engaging in business field in which they performed civil service.  In addition, it also includes a provision prohibiting government officials from accepting gifts or other advantages of the value exceeding CZK 300 (approximately USD 15).


Angolan Law on the Criminalization of the Infractions relating to Money Laundering (Law No. 3/14), entered into force on 11 May 2014.  This new law notably provides for new corruption-related criminal offences, e.g., the crime of receiving undue benefits, trading in influence and economic participation in business with impact in matters such as the offering of gifts and business courtesies to public officials.

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News & Press

Jaclyn Jaeger | Compliance Week
December 2, 2014

Tom Fox | FCPA Compliance and Ethics Report
December 3, 2014

December 15, 2014

The Northern Miner
January 14, 2015



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