The TRACE Compendium is a user-friendly and fully searchable database of comprehensive, yet succinct, summaries of international anti-bribery enforcement actions. Most actions included in the TRACE Compendium are Foreign Corrupt Practices Act (“FCPA”) enforcement actions brought by the U.S. Department of Justice (“DOJ”) and/or the U.S. Securities and Exchange Commission (“SEC”). However, the TRACE Compendium also includes the growing number of international anti-bribery enforcement actions brought by enforcement authorities outside of the United States, particularly amongst signatories to the OECD Anti-Bribery Convention.

Enforcement activity included in the TRACE Compendium share two characteristics: first, the conduct at issue – the bribery – must cross an international border; second, the bribery must be of a government official.  Domestic anti-bribery investigations and enforcement matters involving commercial bribery purely between private parties are not included in the TRACE Compendium.

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    TRACE Compendium Alert

    SEC Issues Cease-and-Desist and USD 9.2MM Payment Order to The Dun & Bradstreet Corporation

    On 23 April 2018, the SEC issued an administrative order with the consent of The Dun & Bradstreet Corporation (“D&B”) to conclude its six year investigation into alleged FCPA violations stemming from two of D&B’s indirect Chinese subsidiaries -- Shanghai Huaxia Dun & Bradstreet Business Information Consulting Co., Limited (“HDBC”) and Shanghai Roadway D&B Marketing Services Co., Ltd. (“Roadway”).

    The complete Compendium summary for this case may be accessed here. 

    SEC Issues Cease-and-Desist and $950,000 Civil Penalty Order to Kinross Gold Corporation

    On 26 March, 2018, the SEC issued an administrative order with the consent of Kinross Gold Corporation— a Canadian Gold mining company—to conclude its investigation into the company’s alleged FCPA violations. The SEC ordered Kinross to cease and desist from committing any future violations of Sections 13(b)(2)(A) & (B) of the Exchange Act and to pay a USD 950,000 civil penalty. Kinross must also report its remediation and implementation of compliance measures to the SEC during a one-year term. Kinross didn't admit or deny the SEC's findings.

    The complete Compendium summary for this case may be accessed here.