The July roundup of enforcement actions, TRACE news and events and this month's highlights.   
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July 2017 

This Month's Highlights

Train your local employees and third parties in São Paulo at a complimentary TRACE Anti-Bribery workshop on 21 September. July was bookended by two significant FCPA settlements with CDM Smith and Halliburton Company. Read more. Mexico has unveiled a new anti-corruption law. Find out what other companies have been using to support their compliance programs with the top three most downloaded materials in the TRACE Resource Center. Continue reading for regulatory updates on India and Sri Lanka.  

Spotlight On: São Paulo Anti-Bribery Workshop   

  Dates: Thursday, 21 September 
Location: S
ão Paulo, Brazil
Time: 8:00  – 19:00
Venue: Tivoli Mofarrej

Cost: Complimentary 
View the agenda-at-glance

Train your local employees and third party intermediaries on compliance best practices in a post “Operation Car Wash” (Lavo Jato) enforcement landscape at our complimentary São Paulo Anti-Bribery Workshop.
We invite you to join TRACE’s full-day anti-bribery training workshop on Thursday, 21 September 2017 at Tivoli Mofarrej, São Paulo. Register now.

July was bookended by two significant FCPA settlements. As June came to a close, the U.S. Department of Justice resolved its investigation into the activities of the India subsidiary of Boston-based engineering/construction firm CDM Smith. The parent company had voluntarily informed the DOJ about the misbehavior—obtaining contracts by making illicit payments to officials at India’s state-owned highway management agency—and was only required to disgorge its profits from the contracts (approximately US$4 million). Four weeks later, the Securities and Exchange Commission announced its own settlement with the Halliburton Company, resolving allegations related to the efforts made by a former company officer to steer business toward a well-connected local company in Angola (which also happened to be owned by a former Halliburton employee) to curry favor from the public official (a friend of the local company’s owner) responsible for approving Halliburton’s contracts. Halliburton agreed to disgorge the US$14 million in profits it obtained through the tainted contracts (plus interest) and to pay a US$14 million civil penalty, while the former Halliburton officer agreed to a civil penalty of US$75,000.

Outside the U.S., prosecutors in Geneva settled with Swiss company Addax Petroleum over allegations that its director-general and legal director had paid bribes to foreign officials in Nigeria. No criminal intent was established, but a penalty of approximately US$32 million was nevertheless imposed on the company.

Visit the compendium to view the complete entries, and subscribe to receive the alerts in your inbox.


TRACE Resource Center Updates 

The Top Three Materials

International Per Diem Rates by Country 
- A list of the daily monetary amounts that international governments allow their employees while traveling on business.

China Gifts & Hospitality Guidelines -  A convenient summary of the issues raised when gifts and meals are provided to foreign government officials in China.

TRACE Model Policy: Anti-Bribery Policy - This model compliance policy can be used as a foundation for internal policies focused on bribery.

New in the TRACE Resource Center

View updated Partner Firm materials: 


TRACE News and Press

Q&A Series on Anti-Bribery Compliance: Advice for Companies Operating in Indonesia
Anti-bribery compliance advice for companies operating in Indonesia.
TRACE, Corporate Compliance Insights, 21 July 2017

Mexico unveils new anti-corruption law
The impact of Mexico’s new anti-corruption law for organizations working in the region.
Jaclyn Jaeger, Compliance Week, 21 July 2017

TRACE Events and Webinars

Register now for upcoming TRACE events and webinars. 

OCTOBER NOVEMBER Bookmark our upcoming events and webinars pages below to be the first to know when new locations and dates are announced.


Regulatory Updates


In 2016, the Defense Procurement Procedure (“DPP 2016”) was updated to introduce specific provisions to stimulate growth in India’s domestic defence industry. In particular, the seller will be required to proactively confirm a number of assurances to the buyer in order to assure the buyer that the supply chain is fully disclosed, completely transparent, and not involved in bribery or corruption. DPP 2016 gives the buyer specific means of redress if the seller breaches the duty to disclose this information to the seller.

In 2016, Sri Lanka’s Cabinet of Ministers directed the Ministry of Finance to establish a Procurement Monitoring Unit (PMU). The PMU shall monitor the normal procurement process to ensure transparency and efficiency. If the PMU finds any issues with procurement, it shall notify the Cabinet Committee on Economic Management.
The 2016 Right to Information Act (Act No. 12 of 2016) identifies two additional types of “public authorities,” namely: a non-governmental organization that renders a service to the public and that is either substantially funded by the government or that was created by any government or international organization; and institutions of higher education that are either established or funded, in whole or in part, by the government.

Partner Events


London International Shipping Week
Hosted by: Shipping Innovation
London, UK, 11 – 15 September
TRACE Members receive a 15% discount off registration.

5th Oil & Gas Compliance Exchange
Hosted by: Momentum
Houston, TX, 26 September
TRACE representative speaking.  Request a meeting.

10th West Coast Conference on FCPA Enforcement and Compliance
Hosted by: ACI
San Francisco, CA, 26 – 27 September
TRACE Members receive a 10% discount off registration.

To request the discount code for the above partner events, contact us.

July 2017 Quiz: Test your Knowledge!

Are you up-to-date on this month's anti-bribery news?

Take the TRACE quiz to find out. 


Risk-Based Due Diligence

Streamline your due diligence procedures and shift screening costs to third parties. Learn more.


TRACE Matrix

Assess business bribery risk in 199 countries with the TRACE Matrix. Learn more.



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