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TRACE Launches Leading Edge Anti-Bribery Compliance Software

ANNAPOLIS, Md., Oct. 18, 2011 /PRNewswire/ -- TRACE announced today the launch of its Gifts & Hospitality Tracking Software, available to TRACE members at no cost.  The TRACE software solution addresses a key focus of recent Foreign Corrupt Practices Act (FCPA) enforcement actions against corporations and individuals for the bribery of government officials:  improprieties surrounding corporate gifts, hospitality and travel.  

Prosecutors and securities regulators in the U.S. and abroad are increasingly focused on the role that gifts and hospitality play in improperly influencing government decision-making.  Determining when a gift becomes a bribe is a subjective determination, based on many factors. Robust anti-bribery compliance programs must ensure that senior management has the data necessary to confirm that gifts made and hospitality provided on behalf of a corporation - across all of its employees and in all of its countries of operation - are "reasonable," "proportionate," and "bona fide" and therefore not intended to improperly influence the recipient.

Before addressing the challenge of determining whether gifts and hospitality are reasonable, proportionate and bona fide, companies have struggled even to identify the scope and frequency of these expenditures. Corporations have been given little guidance about what information to collect and track in order to satisfy regulatory concerns.  In addition, corporate compliance budgets typically do not have sufficient funds to design a centralized data collection tool devoted to this specific risk area.

The TRACE software addresses this information gap by enabling member companies to track key information about gifts and hospitality made and received by their employees.  This two-way tracking meets the requirements of the FCPA, as well as the new UK Bribery Act, which criminalizes not only the offer or payment of a bribe, but also accepting or agreeing to accept a bribe.  

TRACE's Gifts & Hospitality Tracking Software aggregates data across organizations so that compliance executives can identify worrisome trends and patterns as they emerge.  For example, the software will reveal:

  • whether multiple employees in the organization have given gifts to a particular government official, any one of which is innocuous, but which in the aggregate may be excessive or create the appearance of impropriety; and
  • whether there is an increase in gifts, hospitality or travel contemporaneously with material corporate events, such as receiving regulatory approval for the opening of a new facility.

"TRACE is committed to ensuring that our member companies have the practical and cost-effective tools they need to keep them near the front of the pack in terms of anti-bribery compliance," said TRACE founder and president Alexandra Wrage.  "When designing this software solution, we studied recent enforcement actions and guidance from U.S. and European regulators, which emphasize that anti-bribery compliance programs should not only be routinely audited, but also dynamic.  That is, corporations should be continuously collecting relevant information to monitor the bribery risks they confront and making adjustments as appropriate.  We also tapped one of our greatest assets, our nearly 200 multinational member companies - all strongly committed to anti-bribery compliance - to make sure we understood and addressed the challenges they face in monitoring gifts and hospitality."


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, please visit

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