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The Global Business Bribery Risk Index for the Compliance Community

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New content is regularly added to the TRACE Resource Center. 
Anti-Bribery Compliance Challenges in the Middle East (Webinar)
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June 2015
Compendium Roundup


A variety of anti-bribery enforcement activity occurred this month. Gold Fields Ltd. announced that the U.S. Securities and Exchange Commission ("SEC") had closed its investigation into the company and would not recommend an enforcement action for possible violations of U.S. Foreign Corrupt Practices Act ("FCPA"). The SEC had been investigating allegations that the company had provided a share allocation to an official in South Africa to ensure a Black Economic Empowerment transaction concerning the company's South Deep mine went forward. Net 1 UEPS Technologies announced that the SEC had closed its investigation into the company and would not recommend an enforcement action against the company for possible violations of the FCPA. The investigations into Net 1 by the SEC and the U.S. Department of Justice ("DOJ") were focused on payments the company allegedly made to South African officials to obtain a contract with the South African Social Security Agency. The DOJ investigation is still ongoing. 


Read more on the TRACEblog>>>

Featured Resource: TRACEsort 
TRACEsort offers companies an efficient, cost-effective way to collect and assess third party risk information, manage due diligence reviews, upload supporting documentation and record a definitive on-boarding decision for any number of third parties. As a member benefit, TRACE Corporate Members pay a discounted hosting fee of just $3000 to implement and deploy this third party risk management tool. Recent updates to the TRACEsort platform include: 
  • The ability to have "split" questionnaires, allowing TRACEsort users to combine responses from their third parties with internal information to generate the overall risk score.
  • A messaging system that allows TRACEsort users to send links to questionnaires to their third parties, their colleagues, or both when they are inputting third party information into the system. 
For more information on TRACEsort or to schedule a demo, please click here
Benchmarking Survey: Third Party Commission Rates (Asia)

The Asia segment of the TRACE Commission Benchmarking Project survey includes China, India, Indonesia, South Korea and Kazakhstan. This project will provide 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. Business-to-government deals are defined as contracts between companies and regional, municipal or federal governing bodies. Anti-trust counsel has reviewed the survey questions, and we ask that you use only commission rates paid in Q4 2014 or prior when answering the questions. 

Unlike other benchmarking project, the results of the Commission Benchmarking are not available EXCEPT to those companies that participate. To receive a copy of the survey results, please submit one response per company by July 24, 2015. Click here to participate.

*If you participated in any of the previous segments and have not yet received a copy of the final results, please write to
Online Training: New Modules

As we look to expand our online training options, we would like to provide you with the opportunity to select future training module topics. We invite you to participate in a one question survey available here



Current Modules Include:

Anti-Bribery Training

Conflicts of Interest

Avoiding Trafficked Labor

Coming Soon:

NEW Anti-Bribery Training

Conflict Minerals

To learn more about online training options, please write to

TASA: TRACE Anti-Bribery Specialist AccreditationŽ webinars are now available to TRACE members at no additional charge.

Register for a live webinar or view any recorded webinar in the TRACE Resource CenterFor more information, contact



Recently Recorded Webinars:

  • Anti-Bribery Compliance Challenges in the Middle East 
  • Offsets, Charitable Donations, and Other Foreign Government Requests: What Are the Risks? 
  • Conducting an Effective Anti-Bribery Risk Assessment

Interested in taking the TASA accreditation exam? Enroll in TASA today and become TASA accredited by the end of 2015. To inquire about discounts and credits, write to


These invitation-only, advanced sessions provide senior-level compliance professionals with the opportunity to share best practices and discuss emerging trends. Fall 2015 roundtable locations are listed below. To request an invitation, please write to Space is limited and is first come, first served. 

London (as part of London Int'l Shipping Week)
Click here to view the agenda.
8 September
Copenhagen (as part of Danish Maritime Days)
Click here to view the agenda. 
8 October
Click here to view the agenda. 
16 October
Agenda under development. 
3 November


TRACE workshops provide practical, in-depth anti-bribery training for your global employees and intermediaries. These events feature TRACE representatives, compliance and business executives and TRACE Partner Firms. Register today for our fall 2015 locations. 
Click here to view agenda-at-a-glance. 
9 September
Mexico City
10 November
This high-level event provides TRACE Member Companies with the opportunity to share best practices and learn first-hand from TRACE Partner Law Firms and one another about corruption risks and enforcement trends around the world.  Register now for this highly anticipated event.
Venue: Mandarin Oriental, Hyde Park
View the agenda-at-a-glance 
13-14 October


Global Anti-corruption Regulatory & Enforcement Update

Hosted by: ACI

July 20

Washington, DC

6th Global Forum on Anti-Corruption and Compliance in High Risk Markets

Hosted by: ACI

July 21

Washington, DC


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

International Regulatory Updates



Miller Thomson LLP

Canada recently enacted new procurement rules which provide for ten year debarment following a conviction or guilty plea with a conditional or absolute discharge for any number of primarily corruption-based Canadian or similar foreign offences.  Following a public outcry, the Government indicated, that it would introduce a new integrity regime for procurement that is "consistent with best practices in Canada and abroad."



BGI Advisory Services Georgia

Recent amendments to the Law on Conflict of Interest and Corruption in Public Sector in Georgia define whistleblowing as reporting by public servants or former public servants to relevant public institution, investigator, prosecutor and/or public defender of Georgia regarding violations of the laws of Georgia or norms of Code of Ethics by a public servant when such violations have resulted in or may result in damages to public interests or reputation of respective public institution.  The statutory authority provides protections of the whistleblowers, which, inter alia, include prohibition of disclosure of the whistleblower's name unless such disclosure is expressly consented by the whistleblower in writing.


New Partner Firm - South Sudan


Juba Associated Advocates 

Issa Muzamil Sebit (

Konyo-Konyo Market

Juba, Central Equatoria State

South Sudan

TEL: +211 955.217.563

News & Press

BBC Newsnight

Channel 4

Bloomberg TV

Monsters & Critics

Bureau Van Dijk

Gulf Business

David Hechler, Corporate Counsel



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