Follow TRACE:
In This Issue
Quick Links
TRACE Matrix
The Global Business Bribery Risk Index for the Compliance Community

Resource Center
New content is regularly added to the TRACE Resource Center. 
International Per Diem Rates by Country

Country Bulletins + Gifts & Hospitality Guidelines for: 
Albania, Croatia, Hungary, Israel, Mexico, New Zealand, Norway, Oman, Portugal, Sweden.

Click here to login to the Resource Center.

this Email >
October 2015
Compendium Roundup

This month, Bristol-Myers Squibb Company ("BMS") agreed to pay more than USD $14.6 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 U.S. Foreign Corrupt Practices Act ("FCPA") by providing gifts, travel, meals, conference sponsorships and cash payments to secure and increase sales to state-owned or controlled hospitals in China. BMS allegedly turned a blind eye to false reimbursement claims used to provide gifts, cash and other improper payments to secure prescription sales. The U.S. Department of Justice ("DOJ") informed BMS this month that it had closed its investigation into the company.
Ng Lap Seng, chairman of Sun Kian Ip Group, was arrested this month for allegedly paying more than USD $500,000 to the former United Nations President of the General Assembly and ambassador to the United Nations for Antigua and Barbuda to influence the building of a multi-billion dollar, United Nations-sponsored conference center in Macau. The DOJ has charged Ng with conspiracy to bribe and paying a bribe to a United Nations official, as well as other related charges.
As with last month, a number of new cases were announced this month. Norwegian offshore oil equipment company Sevan Marine ASA self-disclosed results of an internal investigation of its role in the bribery, price-fixing and kickback scheme surrounding Petrobras to the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime and contacted authorities in the U.S., U.K., and Brazil. Thai authorities are investigating Australian gold mining company Kingsgate Consolidated Limited for allegedly bribing Thai officials to obtain a gold mining concession. Canadian gold mining company Kinross Gold Corporation disclosed this month that it had received subpoenas from the SEC and DOJ concerning improper payments allegedly made to government officials in Mauritania and Ghana. 
Visit the TRACE Compendium to view the complete entries, along with other updates from this month. 
October 2015 Poll: What was this month's biggest storyline?
There were 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. UK Enacts New Reporting Provision in Human Trafficking Law - a new provision under the UK Modern Slavery Act 2015 came into effect at the end of the month.  The act, which was passed earlier this year, introduces reporting requirements regarding slavery and human trafficking in the supply chain.  Under the new provision, companies that operate part of their business in the UK and have a global revenue greater than £36 million pounds (approximately $56 million USD) must publish an annual statement of the anti-human trafficking steps it has taken, or that it has taken no steps at all, to ensure that neither slavery nor human trafficking are taking place in its supply chain.
  2. SEC Prepares to Bring Civil Charges against Mondelez International (formerly Kraft) for Bribes Allegedly Paid by Cadbury India Ltd. - the SEC is reportedly preparing civil charges against Mondelez for alleged misconduct by its subsidiary Cadbury India Ltd. (now Mondelez India Foods Ltd.). Cadbury India Ltd. allegedly bribed Indian officials between 2008 and 2010 in return for factory approvals and permits, resulting in a tax exemption of more the $90 million.  Mondelez (as Kraft) acquired Cadbury in January 2010.  In 2011, both Indian and US authorities initiated investigations.  
  3. Bristol-Myers Squibb to Pay SEC over $14 million for China Bribes - between 2009 and 2014, sales representatives from the pharmaceutical company's majority-owned joint venture in China made illicit payments and provided gifts, travel, and entertainment in exchange for business opportunities amounting to more than $11 million in profits, according to the SEC's press release issued in early October.  The SEC cited Bristol-Myers Squibb's lack of effective internal controls and slow response to red flags.  The DOJ has reportedly declined to bring any parallel action against the company.  
  4. Chinese Billionaire Ensnared in UN Bribery Scheme Sentenced to Home Detention - last month, a federal judge granted release of real estate magnate Ng Lap Seng subject to home detention.  Mr. Ng is chairman of the Sun Kian Ip Group and general manager of South-South News.  He is ensnared in a corruption scandal regarding bribes allegedly accepted by John Ashe, the former UN Ambassador to Antigua and Barbuda.  Ashe reportedly accepted over $500,000 in bribes from Mr. Ng in exchange for advancing Ng's interest in building a multi-billion dollar, UN-sponsored conference center in Macau.  
TRACE released a new anti-bribery training module in early October which leverages gamification to drive user engagement. TRACE Online Training courses feature interactive scenarios that teach users to analyze cases of
potential risk and prevent violations from occurring. Two separate courses offer employees and intermediaries targeted training.

TRACE Anti-Bribery Compliance Training helps employees and intermediaries: 
  • Learn what constitutes bribery and how to identify the many forms prohibited by anti-bribery laws.
  • Recognize and avoid bribery in real world situations and acquire the skills necessary to analyze cases.
  • Gain awareness of the risks bribery poses to companies and individuals and prevent violations from occurring. 
To schedule a demo of the new course or request the addition of the course to your online training platform, please write to
Alexandra Wrage, Forbes
In September, TRACE relaunched the blog with a renewed focus on providing business-friendly content and practical insights from TRACE, our Partner Law Firms and special guest bloggers. View posts from October below or click here to subscribe to the blog and receive weekly emails when new content is published. 

TASA: TRACE Anti-Bribery Specialist Accreditation® webinars are 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

Announcing the TRACE Fall Webinar Schedule: 

The World Bank: Sanctions and Integrity Compliance
11 November 2015
1:00 - 2:00 pm EST

To register for upcoming webinars, click here

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. Stay tuned for Winter 2016 Roundtable dates. 


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 upcoming sessions. 
Mexico City
Click here to view the agenda. 
 12 November
Click here to view the agenda at-a-glance. 
21 January
Save the date! The 12th Annual TRACE Forum will be held at the St. Regis Hotel in Washington, DC, March 2-3, 2016Designed specifically for TRACE Corporate Member companies, this event offers practical compliance advice and an opportunity for companies to benchmark with their peers in an interactive environment. To learn more, write to


5-6 November
New York

11-12 November
*Michelle Juan, TRACE, speaking

Hosted by: C5
12-13 November

Hosted by: ACI
16-19 November
Washington, DC
*TRACE representatives will be attending this event. 

Hosted by: IBC Legal
16-20 November
*Severin Wirz, TRACE, speaking

16-20 November
Washington, DC
*A TRACE representative will be attending this event.  

Australian Public Sector Anti-Corruption Conference 
Hosted by: APSAC
17-19 November
*Alexandra Wrage, TRACE President, speaking

18-19 November
*Anne-Marie Zell, TRACE, speaking

19-22 November
Riviera Maya, Mexico
*Martha Mallory, TRACE, speaking


Hosted by: C5
1-2 December 
*A TRACE representative will be attending this event. 

Hosted by: ACI
1-3 December

Hosted by: Duxes Events
9-11 December
Hong Kong
*Michelle Juan, Regional Consultant, speaking

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

John Sinott, CNN

Eric Levitz, New York Magazine

GNA, Ghana News Agency

Jonathan Ungoed-Thomas, Sunday Times

Eric Randolph, Yahoo! News

14 October 2015
Fiona Tatton, Womanthology
Wendy Lauresen, Marine Executive



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