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

    SBM Offshore Finalizes US$238 Million FCPA Settlement With USDOJ

    Earlier this month, the Dutch company SBM Offshore N.V., a supplier to the offshore-drilling industry, announced that it had set aside US$238 million in connection with an investigation by the U.S. Department of Justice into alleged FCPA offenses in Brazil, Angola, and other countries. 

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

    Halliburton settles with SEC over FCPA allegations

    Nearly six years after formally disclosing its internal investigation into potential FCPA violations in connection with its operations in Angola, the Halliburton Company and a former officer have entered into settlement agreements with the Securities and Exchange Commission, consenting to the agency’s entry of a cease-and-desist order on 27 July 2017.

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