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October 2016 

Compendium Roundup

The United States again led the charge in enforcement activity this month. Manufacturing firm Embraer S.A. agreed to pay more than USD 205 million in penalties, disgorgement and prejudgment interest to the U.S. Department of Justice (“DOJ”), the U.S. Securities and Exchange Commission (“SEC”), and Brazilian authorities to resolve allegations that the company made improper payments to government officials related to aircraft purchases in the Dominican Republic, India, Saudi Arabia and Mozambique. In the telecoms industry, Telia Company AB disclosed this month that U.S. and Dutch authorities proposed a settlement of their investigations into the company for approximately USD 1.45 billion. Wal-Mart Stores Inc. and Braskem SA also are allegedly in talks with U.S. officials to settle the investigations into those companies.
Cognizant Technology Solutions Corporation disclosed that it is investigating potential violations of the US Foreign Corrupt Practices Act in India, and notified both the SEC and DOJ of its investigation. The climate-control company Lennox International Inc. is investigating an alleged bribe to a customs broker or official in Russia, which it disclosed to the SEC and DOJ.
Finally, Grifols S.A., a multinational chemical and pharmaceutical company, disclosed this month that the DOJ had closed its investigation into the company related to Talecris Group, which Grifols purchased in 2010.

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

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

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: COMPLIMENTARY WEBINAR: FCPA Year-in-Review,
8 December 2016

2016 has been a record-breaking year, with more corporate enforcement actions than any prior year in FCPA history. Led by Billy Jacobson, Partner at Orrick, Herrington & Sutcliffe LLP, this webinar will provided an overview of the year’s landmark cases including Och-Ziff, VimpelCom, Embraer, Nu Skin and others and offer participants practical compliance tips for the coming year. Register here.
TRACE Members enjoy complimentary access to recorded webinars in the TRACE Member Resource Center, a comprehensive online database containing thousands of anti-bribery materials including training vignette and webinars. 

Join TRACE by November 15 and earn a free month of membership. Write to info@traceinternational.org to learn more about TRACE membership benefits and this promotion. 

Investigative Reporting

TRACE is currently accepting submissions for the 2017 Prize for Investigative Reporting. The award recognizes reporting that uncovers business bribery with the goal of increasing commercial transparency. For more information or to submit an entry, click here.  

TRACE Roundtables & Workshops

Participate in a high level roundtable discussion or train your local employees and third parties at an upcoming TRACE workshop.
Paris, France
2 December 2016

Park Hyatt Paris-Vendôme
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 workshop@TRACEinternational.org.   
TRACE, in collaboration with SNC-Lavalin and ENSAfrica, is pleased to host an anti-bribery workshop in Johannesburg as part of Certify the World
Johannesburg, South Africa
13 February 2017
Location and agenda TBC


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.  

Partner Events


Anti-Corruption: The Nordics
Hosted by: C5
1-2 November 2016
Oslo, Norway
*TRACE representative attending

Anti-Corruption Italy
Hosted by: C5
8-9 November 2016
Milan, Italy
*TRACE representative attending

Buyer-Supplier Awareness
Hosted by: USAID and PYXERA Global
9-10 November 2016
Takoradi, Ghana
*TRACE representative speaking

5th Asia-Pacific Summit on Anti-Corruption
Hosted by: ACI
15-16 November 2016
*TRACE representative attending

2nd Andean Summit on Anti-Corruption Compliance & Enforcement
Hosted by: ACI
16-17 November 2016
Bogota, Colombia

Dealing with Business Challenges and Promoting Integrity in the Region
Hosted by: The Coalition for Ethical Operations
16-17 November
Johannesburg, South Africa
*TRACE representative attending

Foreign Corrupt Practices Act
Hosted by: ACI
29 November-2 December 2016
Washington, D.C. 


17th International Anti-Corruption Conference
Hosted by: IACC
1-4 December 2016
Panama City, Panama
*TRACE representative attending
Invest in Africa’s Big Anti-Bribery Debate
Hosted by: Invest in Africa
6 December 2016
*TRACE representative speaking

2nd Anti-Corruption EMEA Summit 2016
Hosted by: Duxes
6-7 December 2016
Dubai, UAE
*TRACE representative attending
4th Anti-Corruption Compliance Asia Pacific Summit 2016
Hosted by: Duxes
6-9 December 2016
Hong Kong
*TRACE representative speaking

Business Integrity and Compliance Conference
Hosted by: KNect 365 Law
8-9 December 2016
London, UK
*TRACE representative speaking

*To request a meeting with the TRACE representative at any of these events, please write to workshop@TRACEinternational.org.

TRACE International, 151 West Street, Annapolis, MD 21401

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