Compendium

Compendium

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

     

    Deutsche Bank Reaches US$16.2 Million FCPA Settlement with SEC

    The SEC issued a consensual cease-and-desist order against Deutsche Bank requiring the company to pay a total of approximately US$16.2 million.

    The complete Compendium summary for this case may be accessed here

     


     

    Microsoft Reaches US$25.4 Million FCPA Settlement with DOJ and SEC

    Between 2012 and 2015, Microsoft’s subsidiaries made improper payments to various government officials in order to obtain business.

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