The Global Business Bribery Risk Index for the Compliance Community
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New content is regularly added to the TRACE Resource Center.
Country Bulletins + Gifts & Hospitality Guidelines for:
Armenia, Netherlands, Japan.
Click here to login to the Resource Center.
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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.
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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:
- 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.
- 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.
- 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.
- 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.
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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.
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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 info@TRACEinternational.org.
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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.
To participate in the TRACE Week of Giving, check your email every day for that day's giveaway and write to info@TRACEinternational.org to enter to win.
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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.
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Initiatives: Advancing Commercial Transparency
*Employees of TRACE Member companies and their intermediaries are also invited to attend the workshop. For more information and registration details, please write to workshop@TRACEinternational.org.
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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.
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For more information, view the press release announcement here or visit our website here for applications details.
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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.
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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 info@thetasa.org.
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Save the date! The 12th Annual TRACE Forum will be held at the St. Regis Hotel in Washington, DC, March 2-3, 2016. Designed 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 dipalma@TRACEinternational.org.
Members are encouraged to register early to guarantee their place. To register for this event, click here.
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DECEMBER
Hosted by: C5
1-2 December
Copenhagen
*Pia Vining, Senior Director, attending
Hosted by: ACI
1-3 December
Bogota
Hosted by: Duxes Events
9-11 December
Hong Kong
*Michelle Juan, Regional Consultant, speaking
JANUARY
Hosted by: United States Naval Academy
24 January
Annapolis
*Alexandra Wrage, President and Founder, speaking
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New Partner Firm - Armenia
AMERIA CJSC
9 G. Lusavorich Str.
0015, Yerevan
Republic of Armenia
TEL: (+374 10) 56.11.11
FAX: (+374 10) 51.31.33
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10 November 2015
Heavy Lift PFI
11 November 2015
WSJ
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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Sincerely,

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