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July 2015
Compendium Roundup


This month, Louis Berger International Inc. agreed to pay $17.1 million to the U.S. Department of Justice ("DOJ") to resolve allegations that the Company violated the U.S. Foreign Corrupt Practices Act ("FCPA") by making $3.9 million in improper payments to government officials in Indonesia, Vietnam, India and Kuwait. Louis Berger allegedly provided the improper payments to secure contracts for projects. In addition to paying the $17.1 million penalty, Louis Berger agreed to retain a compliance monitor for three years.


Mead Johnson Nutrition Co. agreed to pay over $12 million to the U.S. Securities and Exchange Commission ("SEC") to resolve allegations that the Company violated the books and records and internal controls provisions of the FCPA by making more than $2 million in improper payments to health care professionals at state-owned hospitals in China.


Read more on the TRACE Blog.

July 2015 Poll: What was this month's biggest storyline?


We had many new developments this month in the world of anti-bribery compliance.  Read the summaries below and then vote for which one you think is most deserving of the top spot:


  1. DOJ settles with Louis Berger for $17.1 million over bribes to win government construction management contracts - according to the DOJ's press release, Louis Berger International Inc., a New Jersey construction management company, made $3.9 million in illicit payments to foreign government officials in India, Indonesia, Vietnam, and Kuwait from 1998 to 2010 to win construction management contracts.  The DOJ noted Louis Bergers self-reporting, cooperation with the investigation, remediation efforts (including the firing of involved employees), and commitment to improving its compliance program as mitigating factors.  As part of the settlement, Louis Berger has agreed to implement new internal controls and to a three-year compliance monitor.  The SEC [has declined to bring/has brought] a parallel action against the company.
  2. Brazil convicts high-level construction executives and will investigate former president Luiz Inacio Lula da Silva in relation to Petrobras scandal - the convictions and expanded investigation stem from the Petrobras scandal, in which former executives of the Brazilian state oil company admitted to receiving bribes.  A Brazilian federal court convicted three executives of the construction group Camargo Correa this month on money-laundering charges related to the scandal.  Brazilian federal prosecutors have also initiated an investigation into former president da Silva's involvement in the fraud scheme following allegations of influence peddling on behalf of the construction company Odebrecht, whose chief executive has also been accused of involvement. 
  3. Whistleblower awarded over $3 million by SEC - the SEC announced in a press release this month that it has awarded a whistleblower over $3 million - the 3rd highest SEC whistleblower award to date - in relation to a fraud scheme.  According to the SEC, the whistleblower was a "company insider" who provided material information that enabled the SEC to solve a case it may otherwise have been unable to detect.   The SEC's whistleblower program originated in 2011; the highest whistleblower reward to date under the program was a payment of over $30 million in 2014.
  4. U.K.'s Serious Fraud Office cooperates with DOJ to win forfeiture by Griffiths Energy of $6.8 million - the SFO won an appeal this month when a U.K. High Court upheld an order freezing $6.8 million in proceeds from the sale of 800,000 shares in Griffiths Energy International Inc., a Canadian oil and gas company now going by the name of Caracal Energy Inc.  The forfeiture stems from bribery charges against the company for illicit payments made to government officials in Chad for oil development rights.  The SFO became involved in the matter in 2014 when it responded to the DOJ's request for mutual legal assistance.
  5. Mead Johnson Nutrition fined $12 million for improper payments to health care professionals in China - the baby food manufacturer entered into a settlement with the SEC this month, agreeing to pay $12 million in penalties and fines.  Mead Johnson made over $2 million in illicit payments through "distributor allowances" to health care professionals (HCPs) at state-owned hospitals in China in exchange for the HCPs' promotion of Mead John's infant formula to new and expectant mothers.  The company failed to maintain accurate and complete records and had insufficient internal controls to prevent these types of improper payments that were not in accordance with the company policies.

    (Read the TRACE Compendium summary here.)
  6. FIFA expels former FIFA official Chuck Blazer amid corruption probe - earlier this month, FIFA expelled American Chuck Blazer from international football ("soccer") as allegations of widespread corruption throughout the organization have surfaced.  Blazer pled guilty to several fraud charges, including racketeering and wire fraud and money laundering conspiracies, stemming from a U.S. federal investigation.  Blazer is cooperating with U.S. prosecutors and has admitted involvement in various fraudulent schemes, including receipt of a $10 million bribe in exchange for his support of South Africa's successful bid to host the 2010 World Cup and receipt of kickbacks in relation to Gold Cup sponsorship and media rights deals.

Vote now on the TRACE Blog.

Featured Resource: Coming Soon - TPMS Premium Access

Since the launch of our Third Party Management System (TPMS), we have been working on several enhancements and new features to improve the customer experience. The TPMS boasts time-saving features such as the Intermediary Directory, a searchable database of pre-vetted third parties for hire. At the request of many customers, the TPMS platform will soon offer Premium Access. Some of the new features will include:

  • Document repository (upload documents such as agreements, contracts, and other third party materials not produced by TRACE).
  • Internal messaging system (user to user and user to intermediary).
  • Ability to easily identify reasons for rejection or clearance in spite of red flags. 
  • Multiple levels of approvals across business and legal departments.
  • Ability to upload a custom logo for display in place of the TRACE logo.  
  • Ability to add an intermediary to account management without first ordering a due diligence report.

Premium Access will be available this fall for a nominal fee. Basic access will remain complimentary for all TPMS users. If you would like to learn more, please contact

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



Upcoming Webinar:

Human Trafficking in the Supply Chain - Complying With Federal, State and Foreign Requirements

Date: 26 August 2015

Time: 1:00-2:00 PM Eastern Time

Faculty: Michael R. Littenberg, Partner and Head of Public Companies Practice, Schulte Roth & Zabel LLP


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
*The contingent fee of US$2550 double/US$2950 single includes flights to and from Miami, accommodations, mandatory educational tours and some meals. Interested participants must register by August 7. 
7-10 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
Agenda under development. 
 12 November

The complete agenda for this exclusive event is now available. Speakers include former DOJ and SEC prosecutors, TRACE Partner Law Firms, and senior compliance executives from Dell, Schneider-Electric, Standard Chartered Bank, Holcim Group Services, Mubadala, Avon Cosmetics, HSBC Holdings and many other TRACE Member Companies. Register now for this highly anticipated event. 

Venue: Mandarin Oriental, Hyde Park
View the agenda
13-14 October


16th International Anti-Corruption Conference (IACC)

Hosted by: IACC Council and Transparency International

2-4 September


2nd Annual Forum on Anti-Corruption: Spain Edition

Hosted by: C5

29-30 September


FCPA Bootcamp

Hosted by: American Conference Institute

29-30 September

San Francisco, CA

3rd Oil & Gas Anti-Corruption & Compliance Exchange

Hosted by: Momentum Events 

29-30 September
Houston, TX

*Katya Lysova, Associate, Member Services and Advocacy, speaking

Latin American Compliance Congress for Life Sciences

Hosted by: CBI
29-30 September
Miami, FL

*Martha Mallory, Latin American Regional Manager, speaking


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

International Regulatory Updates



K&L Gates LLP 

China's Ministry of Finance launched a Government Procurement Agency Registration system on January 1, 2015, replacing the old certification system. Under the new system, companies planning to engage in government procurement agent service has to register online at the official government procurement website before engaging in agency services. The Ministry of Finance and its local branches will then carry out post registration supervision against those registered companies.

Effective March 1, 2015, China's Procurement Regulation defines government official related to procurement projects to have "conflict of interest" with the supplier, and thus must withdraw from procurement activities, if the government official (i) has had an employment relationship with the supplier within the last 3 years; (ii) has been a director or supervisor in the supplier's company within the last 3 years; (iii) has a controlling interest or shares in the supplier's company within the last 3 years; (iv) are the spouses, lineal relatives, collateral relatives within three generations or relatives by affinity and marriage of the legal representatives or persons-in-charge of the suppliers; or (v) any other situations that may affect the government official's procurement activities, a "catch-all" conflict of interest provision.

On June 19, 2015, the Ministry of Supervision under the Central Discipline Inspection Commission released a mobile app to build up a whistle-blowing platform for the public to report corruption-related problems conveniently. The new app allows the public to anonymously submit up to 2 pictures or videos and 500 words evidencing that officials accept bribes or break the frugality rules constantly emphasized by China's Communist Party. Furthermore, the app system divides the corruption activities into 11 specific categories, including enjoying luxurious meals, entertainment, etc., to facilitate a quick and clear report.


New Partner Firm - Ethiopia

Teshome Gabre-Mariam Bokan Law Office

Teshome Gabre-Mariam Bokan (

6th Floor Park Lane Tower, Bole Sub-City, Kebele 03/05

P.O. Box 101485

Addis Ababa


Tel: +251 116 670 049

Direct: +251 11 551 8484/4096/3500

Mobile: +251 911 200 493

News & Press

1 July 2015
Eye on Annapolis

6 July 2015
The FCPA Blog

FCPA Professor

22 July 2015
Heavy Cargo News

Reuters, Mica Rosenberg



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