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June 10, 2010

Global Enforcement Report 2010 Is First of Planned Annual Releases

The good news is enforcement of international anti-bribery laws is increasing. The bad news is many countries have yet to leave the anti-bribery enforcement starting line.

TRACE International released its first-ever summary of worldwide anti-bribery activity today, and it is evident from its data that enforcement is gaining momentum. The TRACE Global Enforcement Report (GER) 2010 summarizes 33 years of enforcement activity by nations around the world.

The TRACE GER 2010 is based on data collected in the TRACE Compendium, a compilation of information about international anti-bribery investigations, formal cases and legal decisions the organization maintains as a public, online tracking tool. The enforcement activities collected date to 1977, when the United States passed and began to enforce the Foreign Corrupt Practices Act (FCPA).

“There is considerable activity to report, which means that transparency is being prioritized and laws prohibiting bribery of foreign officials are increasingly being enforced,” said Alexandra Wrage, President of TRACE. “Although some of the conclusions from our analysis merely confirm expected enforcement trends, TRACE GER 2010 includes some surprises.”

One of those unexpected findings is that in terms of enforcing so-called “inbound” bribery – or enforcement actions brought against a foreign company or individual for offering a bribe to a country’s own officials – South Korea and Italy are the most aggressive enforcers. South Korea leads the enforcement pack in this category, with 12 of the 96 inbound global enforcements recorded; Italy has recorded nine.

The TRACE GER 2010 shows that the U.S.’s role as the anti-bribery first mover has given it a clear lead in terms of the number of total enforcement actions to date for “outbound” bribery; that is, cases and investigations brought against companies and individuals for offering to bribe government officials of other countries. Of the 515 outbound, or foreign, enforcement actions reported in the TRACE Compendium, more than 75 percent, representing 390 bribery enforcement actions, are U.S. matters. The remaining 25 percent are the result of the combined efforts of 21 other nations.

The United Kingdom ranks a distant second highest in the number of outbound bribery actions, with 4.3 percent of the total, comprising 22 bribery enforcement reports.

Although anti-bribery enforcement activity is increasing, and new entrants in the enforcement arena have emerged, much work remains. Of the 193 nations recognized by the United Nations, only 22 have enforced a foreign anti-bribery law in the past 25 years.

According to Wrage, TRACE will publish the GER on an annual basis, with TRACE GER 2010 serving as the organization’s baseline measurement.

“This report summarizes data on the key dimensions of international bribery enforcement, including outbound bribery, inbound bribery, the countries in which alleged bribes are most frequently paid, and the industries in which bribery enforcement cases originate,” she said. “Future Global Enforcement Reports will identify and update the trends in these areas, as well as include other timely analyses of emerging patterns of enforcement as such actions continue to increase around the world.”

To view the TRACE Global Enforcement Report 2010, please visit

A Lesson from the City of London Police
TRACE UK Anti-Bribery Symposium


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