A thick envelope arrived in the mail from Trace International, the firm of anti-bribery compliance experts. The title caught me off guard: How to Pay a Bribe. I would have thought Trace would be focused on how to stop bribes. Then, of course, I read the subtitle: Thinking Like a Criminal to Thwart Bribery Schemes. It’s…
Tag: TRACE International
New Anti-Bribery Compendium
Trace International has launched an online, fully-searchable database containing summaries and analyses of international anti-bribery enforcement actions and investigations in the U.S. and throughout the world. The Trace Compendium summaries are searchable by name or by numerous other criteria, including year, substantive criteria, enforcement authority, and enforcement result. Want the actions involving officials in Thailand?…
Approaching the Sphinx: The DOJ’s Opinion Release Procedure under the FCPA
Alexandra Wrage of the WrageBlog shares her experiences using the Department of Justice’s opinion release procedure under the Foreign Corrupt Practices Act: Approaching the Sphinx: The DOJ’s Opinion Release Procedure. Ms. Wrage takes us through the experiences of TRACE International in obtaining FCPA Opinion Procedure Release 08-03. The opinion release procedure for the Foreign Corrupt…
Data on Bribe Demands in China
An anonymous online survey by TRACE International found that, of those business people visiting China who were asked for more than one bribe, almost 20 percent reported that they had been solicited more than 100 times. TRACE set up an online bribe-reporting system that allows people to file reports in different languages about bribe demands….
Bribery’s Broken Windows
Alexandra Wrage of TRACE international wrote Bribery’s Broken Windows (.pdf) for the Q1 edition of Ethisphere. She tackles the credibility issue with allowing facilitating payments to low level officials, but saying “no” to senior ranking official. She advocates that the companies should prohibit payments at all levels. She looks to the New York subway system’s…
TRACE and FCPA Opinion Procedure Release 08-03
The Summer 2008 newsletter from TRACE International provides some more background on FCPA Opinion Procedure Release 08-03. TRACE points out that this release was the first time that the DOJ has approved the payment of a specific dollar amount to government officials.
Legal Expenses
Mark A. Srere and Amy J. Conway-Hatcher of Morgan, Lewis & Bockius LLP wrote Legal Expenses for The Recorder (CAL LAW). The article compares the results of U.S. Department of Justice and SEC investigation against Lucent with FCPA Opinion Procedure Release 08-03. Lucent spent millions of dollars on hundreds of trips for Chinese government officials…