TRACE Releases 2011 Global Enforcement Report on Bribery

By Trace, PRNE
Monday, August 15, 2011

WASHINGTON, August 16, 2011 -

- Enforcement Up in the U.S., Down in Other Nations in Past Year


The United States enforced its foreign anti-bribery laws at a stepped up pace in 2010, while other countries around the world stepped back from enforcement activities, according to a report released today by TRACE International.

The organization’s Global Enforcement Report (GER) 2011, its second annual compilation of worldwide anti-bribery activity, summarizes 34 years of reported enforcement activity by nations around the world.  

“It is good news that the U.S. continued its aggressive enforcement of bribery, but disappointing that the pace of most other countries slowed - or stalled - last year,” said Alexandra Wrage, President of TRACE.  “The U.S. has amassed 14 times as many anti-bribery enforcement actions as the next most active country.  It sends a particularly unfortunate message when most countries worldwide have not yet pursued a single enforcement action.”

The GER 2011 cites as new developments:

  • The U.S. doubled its foreign bribery enforcement rate in 2010-2011, compared to the number of actions pursued in 2009-2010;
  • Foreign bribery enforcement actions by countries other than the U.S. declined from 2009-2010 levels;
  • Nigeria joined South Korea and Italy in the lead for domestic bribery enforcement against foreign companies, recording 11 new actions in 2010-2011;
  • Domestic bribery investigations against foreign companies or individuals were initiated for the first time in 2010-2011 in six countries - Croatia, Cuba, Georgia, Israel, Latvia and Poland; and,
  • The financial services sector experienced the most rapid increase in bribery enforcement actions, with known cases or investigations increasing from 11 in 2009-2010 to 26 in 2010-2011.

The annual TRACE GER is based on data collected in the TRACE Compendium, a compilation of information about reported international anti-bribery investigations, formal cases and legal decisions the organization maintains as a public, online tracking tool. Enforcement activities in the Compendium date to 1977, when the United States passed and began to enforce the Foreign Corrupt Practices Act (FCPA).

GER 2011 shows the U.S.’s position as first mover in bribery enforcement combined with the strong showing in 2010 gives it a commanding lead in terms of the number of total enforcement actions to date for “outbound” bribery, which are cases and investigations brought against companies and individuals for bribing government officials of other countries.  Of the 632 outbound, or foreign, enforcement actions in the TRACE Compendium to date, 74% — representing 468 bribery enforcement actions — are being pursued by U.S. authorities.  The remaining 26% represent the combined efforts of 23 other nations, with the United Kingdom ranking a distant second to the U.S., with 32 total reported enforcements.

This year’s report includes aggregated information from 1977 through July 2011 on numerous measures of country-level anti-bribery activity by the U.S. and other nations, including both inbound and outbound enforcement.


TRACE is a non-profit membership association that pools resources to provide practical and cost-effective anti-bribery compliance solutions for multinational companies and their commercial intermediaries (sales agents and representatives, consultants, distributors, suppliers, etc.). TRACE provides several core services and products, including: due diligence reports on commercial intermediaries; model compliance policies; an online Resource Center with foreign local law summaries, including guidelines on gifts and hospitality; in-person and online anti-bribery training; and research on corporate best practices.

For additional information about TRACE and the TRACE Compendium, visit

Jamie Moss, newsPRos, +1-201-493-1027

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