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TRACE Launches Leading Edge Anti-Bribery Compliance Software
Date:10/18/2011

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 acc
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