Legal Research and Membership Services
President and Founder
Alexandra Wrage is president and founder of TRACE. She is the author of Bribery and Extortion: Undermining Business, Governments and Security, co-editor of How to Pay a Bribe: Thinking Like a Criminal to Thwart Bribery Schemes and What You Should Know about Anti-Bribery Compliance and the host of the training DVD Toxic Transactions: Bribery, Extortion and the High Price of Bad Business, produced by NBC.
Ms. Wrage hosts the popular weekly podcast: Bribe, Swindle or Steal. She is a guest blogger for Forbes and speaks frequently on topics of transparency, good governance and the hidden costs of corruption.
She was a member of FIFA’s failed Independent Governance Committee and serves on the B20 Taskforce on Anti-Corruption, drafting recommendations for G20 leaders to consider in their global economic policies.
Ms. Wrage was named one of the “Canadians Changing the World” by the Toronto Globe & Mail and one of Maryland’s “Top 100 Women” by The Maryland Daily Record. She has been awarded the Women in Compliance “Lifetime Achievement Award for Service to the Compliance Industry.”
Raised in Canada and living now in the United States, Ms. Wrage studied law at King’s College, Cambridge University. She has provided anti-bribery consulting or training in over 120 countries.
Virna Di Palma
Senior Director, Global Strategy & Communications
Virna Di Palma is an accomplished marketing, business development and communications professional who has worked in the field of anti-bribery compliance for over a decade. As Senior Director of Global Strategy and Communications, Virna oversees all business development and marketing efforts for TRACE, including program management, member acquisition and retention, public relations, event production, brand awareness, partnership development and multi-stakeholder engagement.
Prior to joining TRACE, Virna was a senior program director for the American Conference Institute where she specialized in international trade and anti-bribery compliance and launched the first-ever anti-corruption conferences in Russia, India, Brazil and the Middle East. She started her career as a global security researcher for the London-based think tank Demos, where she was a primary contributor to the publication “Bringing It Home: Community Based Approaches to Counter Terrorism.”
Virna holds a bachelor’s degree in Political Science from Northeastern University and a master’s degree in International Peace and Security from King’s College in London. She serves on the Steering Committee of the Basel Institute’s International Center for Collective Action (ICCA) and is a frequent speaker on topics related to collective action initiatives and anti-bribery. Virna is originally from Uruguay and speaks fluent Spanish. She is based in New York City.
Senior Director, Due Diligence
In this capacity Ms. Vining assists multinational companies with selecting and executing the appropriate due diligence solution. Her team of multilingual due diligence analysts and lawyers has completed reviews on thousands of commercial intermediaries in most countries and across all industries. She helps develop customized, best practices third party management programs for TRACE members and customers.
Prior to joining TRACE, Ms. Vining was a litigation specialist in the tax department of Miller & Chevalier. She graduated from the University of Helsinki, Faculty of Law, and holds an LL.M. degree from The George Washington University Law School. She speaks Finnish and Swedish.
Ms. Vining is a member of the New York bar association.
As Director of Operations, Ms. Thornton is responsible for managing the Human Resources, Information Technology and Accounting departments. She provides leadership for the organization’s day-to-day functions, as well as contributing to organizational strategies, policies and practices.
Prior to joining TRACE, she was a Vice President at American Management Systems, Inc., a computer consulting firm. She initially ran their Data Center Operations and then created a new approach for managing risk and improving business results for their large-scale application development projects. She became their senior project management expert responsible for advising large project teams on improving the quality of their client relationships and delivery processes.
Ms. Thornton has an M.B.A. in Information Technology from George Washington University.
Director, Compliance Training & Accreditation
Trained to think like a lawyer but with the business acumen of a compliance professional, Sunny has worked at the intersection of regulation, compliance, market trends and business for the past decade. As Director, Compliance Training & Accreditation, Sunny oversees both the training and the TASA Accreditation Program: TRACE’s Anti-Bribery Specialist Accreditation®, the only accreditation program of its kind, exclusively dedicated to anti-bribery compliance.
Prior to joining TRACE, Sunny held the position of Vice President, Content & Operations at Momentum, where she oversaw the development of 25+ solutions-oriented, legal, compliance and regulatory-focused corporate training programs per year specifically targeted for Fortune 500 organizations. Additionally, Sunny oversaw all corporate operations for the company including oversight over staff training and development, employee engagement and conduct, process improvement, contractor and third-party relationships. Prior to Momentum, Sunny held the position of Industry Manager, FCPA & International Trade Division at the American Conference Institute where she oversaw a product portfolio that included one of most widely-known events in the FCPA community, The International Conference on the Foreign Corrupt Practices Act.
Sunny possesses specialized subject matter expertise in global compliance topics including anti-corruption/anti-bribery law, international trade and sanctions, as well as other areas including intellectual property and litigation.
Sunny holds both a J.D. and a Master of Laws (LL.M.) in Corporate Law, Global Compliance & Ethics from Widener University’s Delaware Law School. She is based in Philadelphia where she resides with her husband and two daughters.
Manager, Legal Research
Robert Clark is the Manager of Legal Research at TRACE, where he oversees a team of lawyers responsible for the production of analytical content. Mr. Clark brings to TRACE more than ten years of experience performing careful and thorough legal analysis in both the public and private sectors. He has served as a staff attorney for the Seventh Circuit Court of Appeals in Chicago and as law clerk to the Hon. Terence T. Evans in Milwaukee. He has also worked as a commercial and appellate lawyer specializing in business-bankruptcy litigation, first with the boutique firm of Friedman Dumas & Springwater LLP in San Francisco, then as a founding partner of Dumas & Clark LLP. Before attending law school, he spent four years working as a research analyst for the City of Chicago Board of Ethics.
Mr. Clark holds a bachelor's degree from the University of Chicago, from which he graduated with honors, and is a member of Phi Beta Kappa. He also received a master's degree in religious studies from the University of Chicago Divinity School, and a J.D. cum laude from Harvard Law School. He has been admitted to the state bars of Illinois and California.
Data Protection Officer and Counsel
Mr. Antonenko is responsible for monitoring TRACE’s processes and operations for compliance with the EU General Data Protection Regulation and ensuring that the rights of data subjects are protected. He has diligently worked on resolving tensions between anti-bribery due diligence processes and the requirements of the GDPR.
Prior to joining TRACE, Mr. Antonenko practiced law for over fifteen years in a number of leading law firms in Washington, D.C. His practice included assisting clients with FCPA compliance matters and investigations, cross-border transactions, and general corporate issues. His career also included an in-house position as the associate general counsel of a leading manufacturer of critical flow control solutions, where he was primarily responsible for FCPA matters. While in-house, he worked closely with an independent compliance monitor and the U.S. Department of Justice in a post-FCPA enforcement context.
Mr. Antonenko received his Juris Doctor degree from Vanderbilt University Law School in 2002. He has been admitted to the state bars of District of Columbia and Maryland. He is a native speaker of Ukrainian and Russian.
Business Development Consultant, Europe
David Ireland has specialized in international business development throughout his 25-year career, first as a Canadian diplomat serving five years in Tokyo and then with private companies as Director of International Business Development in Toronto, Boston and Ottawa, as well as with the Australian trade development agency AUSTRADE, where he provided tailored consultancy services to Australian firms seeking to export to the Andean region. David has managed customer accounts and led business development activities in Latin America, West Africa, Western Europe and Japan.
Fluent in five languages and familiar with many cultures and business environments, David has extensive business-to-government experience in emerging markets; he worked with TRACE to ensure compliance of third party agents for his previous employer, a TRACE member.
David was born and educated in Canada: he pursued his graduate studies in International Political Economy at the Norman Paterson School in Ottawa following completion of his BA in Economics from Queen’s University. David is based in Paris and will support TRACE member companies and clients in Europe.
David Ireland est spécialiste en développement des affaires internationales depuis 25 ans. Il a commencé sa carrière en tant que diplomat canadien, dont 5 années à l’Ambassade du Canada à Tokio, suivi de postes de Directeur du Développement des affaires internationales chez des société privées à Toronto, Boston et Ottawa ainsi qu’à l’Agence austalienne de développement du commerce international AUSTRADE où il a fourni des services de consultant aux entreprises australiennes cherchant à exporter à la région andine. David a géré des comptes-clients et a dirigé des activités de promotion du commerce international en Amérique latine, l’Afrique de l’ouest, l’Europe occidentale et au Japon.
Maitrisant cinq langues avec une bonne compréhension de nombreuses cultures et milieux d’affaires, David a une grande expérience B2G (du privé auprès des gouvernements) dans les pays en voie de développement. David a collaboré avec TRACE afin d’assurer la conformité des agents tierces de son employeur précédent, un membre de TRACE.
David est né et a été éduqué au Canada: il a entammé ses études de maitrise en Economie Politique Internationale à l’Ecole Norman Paterson à Ottawa suite à ses études de premier cycle (BA) en sciences économiques à l’Université Queen’s (Kingston, Canada). David est basé à Paris, et appuie les membres de TRACE et les clients en Europe.
Business Development Consultant, APAC
As Regional Consultant for the Asia Pacific, Michelle regularly advises multinationals and SMEs on anti-bribery compliance solutions and other regulatory matters, utilizing her extensive experience in government service, corporate law and litigation. Prior to joining TRACE, Michelle was the General Counsel of the Araneta Group of Companies, a diverse group of corporations anchored on food, leisure, real estate and property development. She also worked at the Romulo Law Office, specializing in compliance issues, domestic and international arbitration, cross-border transactions, capital markets and commercial litigation. She served briefly at the Philippines’ executive and judicial departments, and was Chief of Staff at a high-profile congressional campaign, giving her unique insight into corruption challenges in the region.
Business Development Consultant, MENA
Dano has had extensive experience in business development and marketing for financial and corporate services companies in Asia and the Middle East. Before joining TRACE, he worked with the Dubai Department of Economic Development where he assisted multinational companies in setting up their operations in the region, as well as SMEs meet the government’s requirements for company formation.
Having a unique understanding of business requirements and government regulation, Dano assists local and multinational companies in the UAE and MENA region navigate the ever-increasing complexity of complying with global anti-bribery legislation and enforcement.
Business Development Manager, Latin America
Prior to joining TRACE, Martha worked at the Legal Attaché Office of the General Attorney’s Office at the Mexican Embassy in Washington D.C. specializing in mutual legal assistance, anti-corruption, white collar crime, U.S. congressional investigations, sting operations and anti-money laundering practices.
Martha studied law at Escuela Libre de Derecho in Mexico City, and holds an LL.M. in General Studies from Georgetown University Law Center with a focus on white collar, anti-corruption and internal investigations.
Martha has been admitted to the New York State Bar and is also authorized to practice law in Mexico. She is a native Spanish speaker and is currently based in Washington, D.C.
Bárbara Grossi Hamdan
Business Development Consultant, Brazil
Bárbara is a corporate and commercial lawyer, with strong experience in international business development in emerging markets. Prior to joining TRACE she assisted local businesses and multinational companies navigate complex African markets as Business Development Manager for a pan-African law firm, based in South Africa and acting in countries in Sub-Saharan Africa. Before that, she served as legal counsel for a company in the finance and technology sector headquartered in Brazil, where she was responsible for compliance with all applicable legislation and best practices.
Her set of skills and experience enables her to understand the business needs of TRACE members and clients and the challenges and particularities of doing business in different jurisdictions, particularly in Brazil, where she is based.
Bárbara received her Law degree from Faculdade de Direito Milton Campos – FDMC in Brazil, where she was also admitted as an attorney before stepping out of practice.
Bárbara é uma advogada empresarial e corporativa, com forte experiência no desenvolvimento de negócios internacional em mercados emergentes. Antes de se juntar à TRACE, ela auxiliava empresas locais e multinacionais a navegar o complexo mercado Africano como Gerente de Desenvolvimento de Negócios de um escritório de advocacia pan-Africano, baseada na África do Sul e atuando em países da África Subsaariana. Antes disso, ela atuava como advogada de uma empresa do setor financeiro e de tecnologia sediada no Brasil, onde era responsável pelo cumprimento como toda legislação aplicável e melhores práticas.
Seu conjunto de habilidades e experiência permite que ela compreenda as necessidades dos membros e clientes da TRACE e os desafios e particularidades em se fazer negócios em diferentes jurisdições, em particular no Brasil, onde ela se encontra.
Bárbara tem sua graduação em direito pela Faculdade de Direito Milton Campos – FDMC em Minas Gerais, tendo sido admitida como advogada até deixar de praticar a profissão.
Business Development Consultant, West Africa
Kofi Koomson is a development specialist with experience in local content development and project management. He has over eight years’ experience working with non-profit organizations, international agencies and multinational corporations mostly in the extractive industry in Ghana. Kofi has worked with both local businesses in Ghana and the wider region towards meeting international standards and compliance in the Oil & Gas and its related industries. He has successfully led initiatives supporting local content development in Ghana’s nascent Oil & Gas sector through the provision of trainings and assistance in operations management, health and safety, quality management and human resource management.
Kofi has worked with organizations including USAID, Pyxera Global, IFC and General Electric. He specializes in targeted outreach as well as carrying out assessments and research to support livelihood enhancement programs. Kofi led the TRACE Certify the World Campaign in Ghana where nearly 100 local businesses completed TRACEcertification.