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March 2016 

Compendium Roundup

This month, like the last, saw a number of enforcement actions in the United States based on the Foreign Corrupt Practices Act (“FCPA”). Qualcomm Incorporated agreed to pay US $7.5 million in penalties to settle charges brought by the U.S. Securities and Exchange Commission (“SEC”) that the company violated the FCPA by providing gifts, travel, internships and employment to Chinese foreign officials or their family members.  Qualcomm allegedly provided internships and employment to family members of employees at state-owned entities, and hospitality packages for sporting events, luxury goods and airplane tickets to foreign officials and their family members. 

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March 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: Making the Most of Membership

TRACE members benefit from access to a suite of innovative compliance tools that support global anti-bribery compliance programs including, an online resource center of local law guidance, online training, and regional anti-bribery events.

Additional benefits include:
TRACE now offers members the option to upgrade their membership to include our third party risk assessment software.
To learn more about the benefits of membership, please write to or call +1 410.990.0076 to speak to a representative.
Download a complete list of member benefits.


The findings of the sixth annual Global Enforcement Report (GER) were announced this month. Notably, the number of U.S. enforcement actions concerning bribery of foreign officials has increased slightly from the previous year, though there was a slowdown in the number of non-U.S. foreign-bribery enforcement actions. 

Download the full report here.

TRACE published the third in its biennial How to Pay a Bribe series. The collection offers an insider’s view on how bribery and corruption impact international business, making it an excellent instructional tool for compliance practitioners. 

Purchase your copy here.

TASA/Member Webinars

TASA: TRACE Anti-Bribery Specialist Accreditation®webinars are available to TRACE members at no additional charge. For more information, contact  

Upcoming Spring Webinars: 

Combatting Modern Day Slavery: One Community at a Time

Date: 06 April 2016
Time: 11:00 - 12:00 PM EST; 4:00 - 5:00 PM GMT
Faculty: William Shepherd, Partner, Holland & Knight
Investigative Journalism, the Media, and Corporate Due Diligence in Eastern Europe

Date: 29 April 2016
Time: 9:00 - 10:00 AM EST; 2:00 - 3:00 PM GMT
Faculty: Paul Radu, Executive Director, Organized Crime and Corruption Reporting Project, and Nikolay Zyryanov, Global Youth Anti-Corruption Network Coordinating Board Member
Leveraging Corporate Compliance Programs to Address Human Rights Challenges: Risks and Opportunities
Date: 18 May 2016
Time: 11:00 am - 12:00 pm EST; 4:00 - 5:00 PM GMT
Faculty: Sarah Altschuller, Counsel, Foley Hoag’s Corporate Social Responsibility (CSR)
Combatting Judicial Corruption in Sub-Saharan Africa

Date: 25 May 2016
Time: 11:00 am - 12:00 pm EST; 4:00 - 5:00 PM GMT
Faculty: Herbert A. Igbanugo, Shareholder, Igbanugo Partners Int'l Law Firm, PLLC
Compliance Issues in the Media and Entertainment Sector
Date: 8 June 2016
Time: 12:00 - 1:00 pm EST; 5:00 - 6:00 pm GMT
Faculty: Kristy Grant-Hart, Founder and Managing Director, Spark Compliance Consulting

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

TRACE Spring Events

Train your local employees and third parties at an upcoming TRACE workshop or participate in a high level roundtable discussion. 

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.  


Dubai Roundtable
May 2, 2016
Ritz-Carlton, DIFC

View agenda.

Amsterdam Roundtable
May 31, 2016
Intercontinental Amstel

View agenda.   

Oslo Roundtable
June 02, 2016
Venue TBD

View agenda.

Zurich Roundtable
June 03, 2016
Venue TBD

View agenda.

Registration is limited to one representative per company on a first-come, first-served basis. To request an invitation, please write to  

Partner Events


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
*Alexandra Wrage, TRACE President, speaking
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 Representatives, attending
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
Anti-Corruption Compliance and Risk Management Master Class 2016 in partnership with BDO International
Hosted by: American Chamber of Commerce in India
28 April 2016
New Delhi, India
*Alexandra Wrage, TRACE President, speaking


Sport Resolutions 2016 Conference
Hosted by: Sport Resolutions
5 May 2016
London, UK
*Alexandra Wrage, TRACE President, speaking
18th Annual New York Conference on the Foreign Corrupt Practices Act
Hosted by: ACI
16 May 2016
New York, NY
*Virna Di Palma, Senior Director, Global Strategy, attending
Compliance Week 2016 Conference
Hosted by: Compliance Week
23 May 2016
Washington, D.C.
*Andy Hughes, Senior Business Development Manager, attending
6th Brazil Summit on Anti-Corruption
Hosted by: ACI
24 May 2016
Sao Paulo, Brazil
*Virna Di Palma, Senior Director, Global Strategy, attending
8th Anti-Corruption Compliance in China Summit 2016
Hosted by: Duxes
26 May 2016
Beijing, China
*Michelle Juan, Business Development Consultant, APAC, speaking
8th Russia and CIS Summit on Anti-Corruption
Hosted by: ACI & C5
31 May 2016
Moscow, Russia
DICO FORUM Compliance
Hosted by: DICO
31 May 2016
Berlin, Germany
*Alexandra Wrage, TRACE President, speaking and David Ireland, Business Development Consultant, Europe, attending

News & Press

The Morning Risk Report: U.S. Preparing Companies for Investigations
3 March 2016
The Wall Street Journal
FCPA chief: VimpelCom got big break for expediting foreign bribery probe
3 March 2016
Global Investigations Review
The Morning Risk Report: U.S. Anti-Bribery Enforcement Overtakes Globe
9 March 2016
The Wall Street Journal
Report: It's Not Just The U.S. That's Fighting Bribery
9 March 2016
Corporate Counsel
Are anti-bribery experts focusing on the wrong numbers?
10 March 2016
Compliance Week
Thoughts from the SCCE Utilities & Energy Compliance & Ethics Conference
11 March 2016
FCPA Compliance Report
Due Diligence Reduces Risk of Supply-Chain Corruption
14 March 2016
Society For Human Rights Resource Management
Non-U.S. Anti-Bribery Actions Fell Steeply in 2015: Report
16 March 2016
Bloomberg BNA
When a Kleptocrat Comes Calling: Global Money Laundering and the ABA
16 March 2016
The American Lawyer
Training Tools: Prompting Conversations About Bribe Schemes
24 March 2016
Corporate Counsel
Tackling corporate compliance issues, corruption, anti-bribery legislation and money laundering
25 March 2016
Alexandra Wrage: The pros and (substantial) cons of an ISO anti-bribery standard
20 March 2016
The FCPA Blog 

30 March 2016
The Sydney Morning Herald

31 March 2016
The Age


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