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November 2015
Compendium Roundup

This month saw a flurry of activity across the globe. The former Chief Executive Officer of Vimpelcom Ltd., Jo Lunder, was arrested by Norwegian police in connection with an investigation of alleged illicit payments made by Vimpelcom to the daughter of the Uzbek president. While he has been released, he is still under investigation. The company disclosed this month that it had reserved USD $900 million for potential fines and penalties, and according to news reports, the company is discussing a settlement with U.S. authorities that would involve USD $775 million in fines and penalties. Mobile Telesystems OJSC ("MTS") and TeliaSonera AB are also being investigated by U.S. authorities for alleged illicit payments made by those companies to the daughter of the Uzbek president. 

November 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 the one you think is most deserving of the top spot:
  1. Former New York Assembly Speaker Sheldon Silver Convicted of Corruption Charges - This week, Sheldon Silver, the ex-New York Assembly Speaker and attorney, was convicted on seven counts of honest services fraud, extortion, and money laundering... More
  2. Ex-Petrobras Executive Admits to Paying Bribes in Texas Refinery Deal - The ongoing internal investigation by Petrobras, the Brazilian state-run energy company, has uncovered yet another bribery scheme... More
  3. Scottish Authorities Settle First UK Bribery Act "Failure to Prevent Bribery" Offense with Brand-Rex Limited for £212,800 - The Scottish cabling company Brand-Rex Limited made headlines this past month when it agreed to pay £212,800 ($320,550 USD) to settle a breach of the UK Bribery Act, according to a press release of Scotland's Crown Office & Procurator Fiscal Service (Scotland's Prosecution Service), after disclosing to authorities in June 2015 that it had failed to prevent bribery by one of its third parties... More
  4. HP Inc. and Pemex Settle RICO Allegations - In early November, technology company HP Inc. and Mexico's national oil company, Petroleos Mexicanos (Pemex), agreed to settle allegations that HP had been involved in a global scheme of providing kickbacks in exchange for government contracts... More
Vote now on TRACE Trends: A Compliance Conversation
In an effort to help companies establish practical and sustainable guidelines for third party reporting, TRACE invites you to participate in a brief, 3-question survey.
The deadline for completion is Thursday, December 3, 2015. Survey results will be posted in the TRACE Resource Center. To access the survey, click here
Featured Resource: TPMS Premium Access
In November, TRACE announced the addition of Premium Access to our Third Party Management System (TPMS). This new account type expands management capabilities for TRACE due diligence customers with a new suite of user-friendly tools and advanced features that are designed to enable organizations to develop a more efficient workflow for third party risk management and due diligence.

For a list of Premium features, download our informational flyer here and view a video demonstration here. To inquire about pricing details and schedule a live demonstration, please write to
TRACE Week of Giving
TRACE is excited to announce the return of our annual holiday giveaway. The TRACE Week of Giving will begin Monday, December 7 and continue until Friday, December 11. Last year, we received more than 1,500 responses from members and customers eager to take advantage of these year-end discounts and free resources.

Past prizes have included passes to TRACE events, discounts on TRACE due diligence services, free consultations with our compliance advisors and more.

To participate in the TRACE Week of Giving, check your email every day for that day's giveaway and write to to enter to win.
FIFA's Compliance Failures
TRACE recently released a new animated training vignette that explores FIFA's compliance failures over the last several decades and illustrates just how badly wrong things can go when an organization doesn't value good governance. This brief video underscores the importance of transparency, leadership values and oversight and demonstrates how shoddy governance never occurs in isolation.  

This video is also available in French and will soon be available in Spanish. Visit the TRACE website for updates.
*TRACE president, Alexandra Wrage, served on the FIFA Independent Governance Committee from November 2011 until she resigned in April 2013. She and TRACE accepted no compensation or expenses from FIFA. 
Initiatives: Advancing Commercial Transparency
TRACE recently announced a groundbreaking partnership with PYXERA Global and Invest in Africa that will raise compliance standards in Ghana and create "champions for change." As part of this initiative, TRACE will work with PYXERA Global and Invest in Africa to offer TRACEcertificationa globally recognized due diligence review and compliance credential, to small and medium-sized enterprises in Ghana at no cost for one year. TRACE Certified entities will be invited to attend an anti-bribery training workshop* in Accra, Ghana on January 21, 2016, hosted by TRACE International and PYXERA Global. To view the agenda for this event, click here

*Employees of TRACE Member companies and their intermediaries are also invited to attend the workshop. For more information and registration details, please write to

Nominations for the 2016 Innovation in Anti-Bribery Compliance Award (IACA) are now being accepted. With the IACA, TRACE seeks to honor a company that has developed and implemented an innovative compliance program and, in keeping with TRACE's philosophy, is willing to share its experience with the global compliance community.

The deadline for submissions is February 12, 2016. For more information, or to submit a nomination, please click here.
Applications are now being accepted for the 2016-2017 TRACE Scholar ProgramThe law schools participating in this cycle of the program are:  Georgetown University University of Washington School of Law; and  King's College, Cambridge UniversityThis year, TeliaSonera, a major telephone company and mobile network operator in Europe, will fully fund a fourth TRACE Scholar at one of the institutions. 

For more information, view the press release announcement here or visit our website here for applications details. 
Catch up on TRACE Trends blog posts from November using the links 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

December Webinars: 

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
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 Member companies, this event offers practical compliance advice and an opportunity for companies to benchmark with their peers in an interactive environment. 

The agenda for this event is under development. If you are interested in speaking or would like to propose a discussion topic, please write to Virna Di Palma at

Members are encouraged to register early to guarantee their place. To register for this event, click here

Hosted by: C5
1-2 December 
*Pia Vining, Senior Director, attending 

Hosted by: ACI
1-3 December

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

Hosted by: United States Naval Academy
24 January 
*Alexandra Wrage, President and Founder, speaking

13th Annual Pharmaceutical Compliance Congress
Hosted by: CBI
26-27 January 
Washington, DC
Compliance & Legal Risk Leaders Summit
Hosted by: C5
26-27 January 

10th Houston FCPA Bootcamp
Hosted by: American Conference Institute
26-27 January 
*A TRACE Representative will be attending this event. 

For a complete list of upcoming events, visit the Upcoming Events Calendar on our website.
New Partner Firm - Armenia
9 G. Lusavorich Str.
0015, Yerevan
Republic of Armenia
TEL: (+374 10) 56.11.11
FAX: (+374 10) 51.31.33
David Sargsyan (

10 November 2015
Heavy Lift PFI
11 November 2015
12 November 2015
New York Times
13 November 2015
The Economic Times (India)
17 November 2015
Main Justice 
17 November 2015
TRACE (Press Release)

19 November 2015 
TRACE (Press Release)

2 December 2015
TRACE (Press Release)

2 December 2015
Alexandra Wrage, Forbes



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