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February 2016 

Compendium Roundup

There were a number of enforcement actions in the United States this month. VimpelCom Ltd. agreed to pay more than US $835 million in disgorgement and penalties to settle charges brought by the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) that the company violated the anti-bribery and books and records and internal controls provisions of the U.S. Foreign Corrupt Practices Act (“FCPA”) by making at least US $114 million in improper payments to a relative of the President of Uzbekistan to enter and remain in the Uzbek telecom market. The settlement includes disgorgement and penalties paid to settle charges by the Public Prosecution Service of the Netherlands.

PTC Inc. agreed to pay more than US $28 million to the DOJ and the SEC to resolve allegations that the Company violated the anti-bribery and books and records and internal controls provisions of the FCPA by providing approximately US $1.5 million in travel, gifts and entertainment to officials to secure and retain sales to Chinese state-owned entities. PTC subsidiaries spent more than US $274,000 on gifts and entertainment for Chinese officials and paid US $1.1 million for Chinese officials to travel to places like New York, Las Vegas and Honolulu.

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February 2016 Quiz: Are You Up-to-Date on This Month's Anti-Corruption News?

There were many developments this month in the world of anti-bribery compliance.  Are you up-to-date on the latest news?  Take our quiz below to find out.  Better yet, share with your compliance teammates and see how your compliance chops stack up!  

Test your knowledge. 

Featured Resource: Automated Third Party Risk Assessment

Say goodbye to clumsy, unwieldy spreadsheets and automate your risk assessment and vetting process with TRACEsort. TRACEsort makes it easy for organizations to collect and assess third party risk information through multilingual or custom-built questionnaires. The software integrates seamlessly withTRACE risk-based due diligence services, allowing users to designate risk tiers and initiate the due diligence process automatically upon completion of the assessment.

To schedule a live demonstration of the software, please write to

From the Member Resource Center:Assessing Third Party Risk

For many companies seeking to operate in foreign markets, local third parties are essential partners. They play a key role in generating sales, navigating local bureaucracy and understanding business customs. But while intermediaries may be helpful in opening doors, they can also present considerable bribery risk, particularly if they are involved in highly government-regulated activities.

This brief guide to assessing third party risk breaks down the risk factors present when working with resellers and distributors, detailing areas of higher and lower risk. 

The Assessing Third Party Risk: Resellers and Distributors guide is available in the members-only TRACE Resource Center
For more information about TRACE Member Resources and to inquire about membership, please write

TRACE Trends: A Compliance Conversation

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/Member Webinars

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 Center. For more information, contact  

Upcoming Spring Webinars: 


Regulatory Compliance
and the Era of Big Fines
in Nigeria

Date: 9 March 2016
Time: 1:00 - 2:00 PM EST
Faculty: Simeon Obidairo, Partner, Aluko & Oyebode 


Evaluating Foreign Criminal Charges Against Potential Business Partners and Intermediaries
Date: 16 March 2016
Time: 1:00 - 2:00 PM EST
Faculty: Thomas Firestone, Partner, Baker & McKenzie LLP


Investigative Journalism, the Media, and Corporate Due Diligence in Eastern Europe
Date: 29 April 2016
Time: 1:00 - 2:00 PM EST
Faculty: Nikolay Zyryanov & Paul Radu, Executive Director, Organized Crime and Corruption Reporting Project


Leveraging Corporate Compliance Programs to Address Human Rights Challenges: Risks and Opportunities
Date: 18 May 2016
Time: 11:00 am - 12:00 pm EST
Faculty: Sarah Altschuller, Counsel, Foley Hoag’s Corporate Social Responsibility (CSR)

To apply for the TASA program and receive access to upcoming live and recorded webinars, please write or visit

Save the Date! GAIN 2016

The Global Anti-Bribery In-House Network (GAIN)conference will be held in London, UK, October 5-6, 2016. This high-level event provides an in-depth analysis of the latest international anti-bribery regulatory and enforcement developments. 

The agenda for this event is under development. To propose speaker or panel topics, please write to Virna Di Palma

For more information on upcoming TRACE events, please write to

TRACE Spring Events

TRACE Member companies receive complimentary access to TRACE Anti-Bribery Workshops to train local employees and third parties. 

Bucharest, Romania
Corporate Compliance Conference 
March 24, 2016
Marriott Hotel Bucharest

This workshop will be hosted by TRACE in partnership with Wolf Theiss, EY Romania and the US Embassy in Bucharest.

View agenda.   

Vilnius, Lithuania
Anti-Bribery Workshop
March 29, 2016
Kempinski Hotel

This workshop will be hosted by TRACE in partnership with the Baltic Institute on Corporate Governance.

View agenda.   


Shanghai Workshop
April 19, 2016
Four Seasons 

View agenda.  

Singapore Roundtable*
April 21, 2016
Fullerton Singapore

View agenda.

*Space is limited to 20 participants. Registration is first-come, first-served. To request an invitation, please write

Bangalore Workshop
April 25, 2016

View agenda

For more information on upcoming events, please write

Partner Events


Gennext Counsel and Awards 2016
Hosted by: ARA Legal Media Group
3 March 2016
Mumbai, India
*Chitra Nair, India Regional Consultant, attending
3rd Annual Forum on Trade Compliance in the Middle East
Hosted by: C5
8 March 2016
Dubai, United Arab Emirates
*Dano Santos, MENA Regional Consultant, attending 

Breakbulk China
Hosted by: Breakbulk
14 March 2016
*Michelle Juan, APAC Regional Consultant, attending 

OECD Anti-Bribery Ministerial Meeting
Hosted by: OECD
16 March 2016
Paris, France
*David Ireland, Europe Regional Consultant, attending

Women in Compliance Awards 2016
Hosted by: C5
17 March 2016
London, United Kingdom
*Alexandra Wrage, President, attending

European Fraud Conference
Hosted by: Association of Certified Fraud Examiners 
20 March 2016
Brussels, Belgium 
*Alexandra Wrage, President, speaking

SCCE's 2016 European Compliance & Ethics Institute
Hosted by: SCCE
20 March 2016
Prague, Czech Republic
*Alexandra Wrage, President, speaking

7th Middle East Summit on Compliance, Anti-Corruption & Financial Crime
Hosted by: ACI
21 March 2016
Dubai, United Arab Emirates
*Dano Santos, MENA Regional Consultant, attending
Mexico Summit on Anti-Corruption and Compliance 
Hosted by: ACI
29 March 2016
Mexico City, Mexico
*Martha Mallory, LATAM Regional Manager, attending


3rd Summit on FCPA, AML and OFAC Risks for Private Equity & Hedge Funds
Hosted by: ACI
5 April 2016
New York, NY 
*Virna Di Palma, Senior Director, Global Strategy, attending
9th A.C.E.S Compliance Summit
Hosted by: Momentum
5 April 2016
McLean, VA
Global Anticorruption & Compliance Summit
Hosted by: Corporate Parity
7 April 2016
Amsterdam, The Netherlands
*Jake Storey, Strategic Advisor – Maritime Initiatives, attending
Women in Compliance Conference Europe
Hosted by: C5
19 April 2016
Brussels, Belgium
2016 OECD Integrity Forum
Hosted by: OECD
19 April 2016
Paris, France
*TRACE Representativesattending
7th Ghana Summit – Oil, Gas & Power
Hosted by: CWC Group
20 April 2016
Accra, Ghana
*Melanie Dickson, Project Manager, speaking
Global Anti-Corruption & Compliance in Extractive Industries
Hosted by: Resourceful Events
26 April 2016
London, UK
*Jake Storey, Strategic Advisor – Maritime Initiatives, attending
10th Advanced Forum on FCPA Anti-Corruption for the Life Sciences Industry
Hosted by: ACI
27 April 2016
New York, NY
*Virna Di Palma, Senior Director, Global Strategy, attending

News & Press

Argentine government surveyors accused of ‘extortion’ payments
February 5, 2016
Wilhelmsen Ship Management is certified by TRACE International, Inc.
February 9, 2016
Wilhelmsem Ship Management
Kapco Global Completes TRACEcertification
February 11, 2016
Kapco Global
TRACE to host an anti-bribery workshop in Vilnius
February 12, 2016
Colombian President approved new law to crack down on corruption
February 19, 2016
The Latin American Corporate Counsel Association (LACCA)
Caviar, champagne at Harrods: Some Mexican anti-graft busters live large
February 19, 2016
FIFA: How Soccer’s Governing Body Resists Evolution
February 23, 2016
Wall Street Journal
FIFA To Meet To Replace Disgraced President Sepp Blatter
February 24, 2016
NPR radio broadcast
FIFA’s new president: Who will take over from Blatter?
February 25, 2016
CBC News
The Daily Record announces Top 100 Women
February 26, 2016
The Daily Record
FIFA: A New Start?
February 27, 2016

5 Leadership Lessons from the FIFA Scandal
February 29, 2016
Corporate Counsel


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