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The Global Business Bribery Risk Index for the Compliance Community

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 Resource Center  

New content is regularly added to the TRACE Resource Center.

Country Bulletins, Gifts & Hospitality Guidelines and Partner Firm Biographies for: Canada, India, Lao PDR, Sri Lanka and United States

Write to to learn more about the Resource Center and membership.




June 2016 

Compendium Roundup

This month, there were a number of Foreign Corrupt Practices Act (“FCPA”) enforcement actions. Akamai Technologies, Inc. (“Akamai”) agreed to pay USD 671,885 to the U.S. Securities and Exchange Commission (“SEC”) to resolve allegations that Akamai’s subsidiary schemed with a third party to pay cash bribes and other expensive gifts to employees of Chinese state-owned entities to obtain and retain business contracts. Nortek Inc. (“Nortek”) also agreed to pay USD 322,058 to the SEC to resolve allegations that Nortek’s subsidiary paid improper benefits – including cash, meals, travel, accommodations and entertainment - to Chinese officials to receive preferential treatment, relaxed regulatory oversight, or reduced customs duties, taxes and fees. Lastly, Analogic Corporation (“Analogic”) agreed to pay approximately 11.5 million to the SEC and acknowledged that its subsidiary acted as a conduit for its distributors to funnel money to unknown third parties in a decade-long illicit-payment scheme. Concurrently, the subsidiary agreed to pay more than USD 3.4 million in criminal penalty to the U.S. Department of Justice (“DOJ”).  

In addition, another case was announced this month. Dutch oil and gas services company Frank’s International N.V. self-disclosed an internal investigation into the operations of its West African subsidiaries regarding matters including possible violations of the FCPA, company policies and other applicable laws to U.S. authorities. 

Visit the TRACE Compendium to view the complete entries, along with other updates from this month. 

June 2016 Anti-Bribery Quiz 

Are you up-to-date on this month's anti-corruption 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 

TRACEbasic is a new restricted party screening solution that enables companies to cost-effectively screen large volumes of names against Denied Parties and Politically Exposed Persons (PEPs) databases and quickly identify individuals and entities that present a potential source of risk. Search results are typically displayed within minutes on a user’s TRACE Third Party Management System (TPMS) dashboard. Names are searched against hundreds of global regulatory, watch and sanctions lists. 

For more information and to inquire about pricing details, please write to

TRACE risk-based due diligence solutions are innovative, cost-effective and based on robust benchmarking. Download our due diligence brochure here to learn more. 

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 Webinars: 
Anti-Money Laundering and Anti-Corruption Compliance – Intersections and Incompatibilities

Register >>
Date: 10 August 2016
Time: 10:00 am - 11:00 am EST; 2:00 - 3:00 PM GMT

Faculty: Luke Brussel, Global Head of Anti-Corruption Compliance, Vice President, First Data Corporation 

To register for upcoming webinars, click here.  

Interested in taking the TASA accreditation exam? Write to to begin the enrollment process and inquire about discounts and credits.

TRACE Roundtables 

Join TRACE for an upcoming roundtable this summer to participate in a high-level discussion on anti-bribery compliance trends and risk management strategies, as well as recent cases, including the Unaoil scandal. Upcoming roundtables will be held in Vancouver, Canada on August 11 and in Seattle, Washington on August 17


Vancouver Roundtable
August 11, 2016
Venue TBD
View agenda


Seattle Roundtable
August 17, 2016
Inn at Market
View agenda

Space is limited to 20 participants. Attendance is by invitation-only. Registration is limited to one representative per company and is on a first-come, first-served basis. To request an invitation, please write to  

TRACE Workshops 

TRACE, in partnership with DA-DESK, is pleased to announce an anti-bribery workshop scheduled on September 19, 2016 in Dubai. This full day training event will feature compliance executives  from across industries who will discuss enforcement trends, increasing transparency in the supply chain and anti-bribery best practices. The workshop will also include sessions specific to the shipping industry as part of TRACE and DA-DESK Certify the World campaign, which offers a complimentary TRACEcertified due diligence review to port agents with the aim of increasing transparency in the shipping and maritime industries. 

  Dubai, United Arab Emirates
September 19, 2016
Westin Dubai Mina Seyahi
View agenda-at-a-glance

To register for this event, please send an email including your name, title and company affiliation to workshop@TRACEinternational.orgRegistration is first come, first served and is limited to two representatives per company. Additional representatives will be added to the waitlist.  

Regulatory Updates


Willkie Farr & Gallagher LLP
Recent federal appropriations acts in the United States have established a presumption in favor of debarment for corporations with unpaid federal tax liability or felony conviction under any federal law in the prior 24 months, unless the contracting agency has considered suspension or debarment of the corporation and made a determination that debarment is not necessary to protect the interests of the government. The U.S. Department of Defense is among the federal agencies whose contracts are affected by these provisions.

Partner Events


Anti-Corruption in High Risk Markets
Hosted by: ACI
18 July 2016
Washington, D.C.

*TRACE representative attending

Conference in Corporate Governance & Responsibility: Theory Meets Practice
Hosted by: Asean CSR Network & National University of Singapore
20-22 July 2016
*TRACE representative speaking


ACCPA Compliance Conference
Hosted by: ACCPA
18-19 August 2016
Nairobi, Kenya
*TRACE representative attending


Collective Action: Evidence, Experience and Impact
Hosted by: Collective Action
21 October 2016
Basel, Switzerland

To request a meeting with the TRACE representative at any of these events, please write to

News & Press

First 5 Calls: Nigeria
1 June 2016
EDC Exportwise

TRACE Advantage: Brazil
3 June 2016
EDC Exportwise

What a Trump presidency would mean for international anti-corruption efforts
6 June 2016
Forum for International Trade Training (FITT)

TRACE Advantage: Ghana
10 June 2016
EDC Exportwise

Working to End Secret Companies
10 June 2016
The Globalist

Behind the Mask: Lessons Learned from the Panama Papers
16 June 2016
The Risk Universe

TRACE Advantage: Japan
17 June 2016
EDC Exportwise

TRACE Offers Complimentary Due Diligence Review To Port Agents In Partnership With DA-Desk To Increase Transparency In The Shipping and Maritime Industries
21 June 2016

TRACE Advantage: Kazakhstan
24 June 2016
EDC Exportwise

TRACE International, 151 West Street, Annapolis, MD 21401

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