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

    TechnipFMC plc pays US$296.2 million to resolve FCPA violations. 

    TechnipFMC plc (“TechnipFMC”) reached a resolution with the U.S. Department of Justice over FCPA violations stemming from two independent bribery schemes: one in Brazil involving Technip and one in Iraq involving FMC Technologies.

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



    Walmart Reaches US$282.7 Million FCPA Settlement with DOJ and SEC

    The SEC issued a consensual cease-and-desist order against Walmart for books-and-records and internal-controls failures spanning more than a decade of aggressive international growth.

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