TRACE International

TRACE International is an international nonprofit organization that provides anti-bribery risk-management, third-party due diligence, and compliance resources for multinational firms operating in complex regulatory environments. It develops standards, certification programs, and training aimed at reducing corruption-related risks for companies, intermediaries, and professional advisors across jurisdictions such as the United States, United Kingdom, Brazil, China, and Nigeria. TRACE collaborates with corporations, law firms, accounting firms, and multinational institutions to promote transparency in commercial interactions involving intermediaries, agents, and consultants.

History

TRACE emerged in the early 2000s amid heightened enforcement under statutes including the Foreign Corrupt Practices Act and the UK Bribery Act 2010, responding to concerns raised by multinational corporations, global banks, and law firms about cross-border intermediary risk. Its founding involved compliance professionals, former regulators, and ethics officers from firms active in markets such as Brazil, Russia, India, and China, responding to enforcement actions involving companies like Siemens and Halliburton. Over time TRACE expanded programs to align with guidance from bodies such as the Organisation for Economic Co-operation and Development and the United Nations Convention against Corruption, while engaging with regional initiatives in Latin America, Africa, and Asia-Pacific.

Mission and Activities

TRACE’s mission centers on promoting commercial transparency and reducing the incidence of Foreign Corrupt Practices Act-related misconduct by providing practical tools for companies and intermediaries. Activities include developing third-party vetting frameworks used by multinational firms, advising corporate compliance teams at firms such as General Electric and BP, and supporting transaction due diligence in sectors like energy, pharmaceuticals, and construction. TRACE engages with international institutions including the World Bank, International Monetary Fund, and regional development banks to integrate anti-bribery measures into project procurement, and it collaborates with law firms, accounting networks such as the Big Four (accounting firms), and global consulting firms to advance compliance best practices.

Anti-corruption Standards and Certification

TRACE administers a certification program that evaluates third-party intermediaries—agents, consultants, distributors—against anti-bribery standards, similar in intent to certification schemes promoted by Transparency International and consistent with guidance from the United Nations Global Compact. Certified parties undergo due diligence processes influenced by criteria in enforcement guidance from the United States Department of Justice and the UK Serious Fraud Office. TRACE’s standardization efforts are often referenced in corporate procurement policies and by multinational corporations seeking to mitigate exposure in transactions involving state-owned enterprises like Petrobras and Rosneft, or in projects financed by institutions such as the Asian Development Bank.

Training, Research, and Publications

TRACE produces compliance training tailored for corporate counsel, chief compliance officers, and in-house legal teams, drawing on case studies from matters involving companies like GlaxoSmithKline and Apartheid-era South Africa-era scandals for historical context. Research outputs include white papers, risk indices, and guidance on third-party risk management that cite enforcement trends from agencies including the Securities and Exchange Commission and the Department of Justice (United States). TRACE organizes conferences and workshops featuring speakers from multinational corporations, international organizations, and academic institutions such as Harvard Law School and Oxford University to disseminate best practices and empirical findings on corruption risk mitigation.

Governance and Funding

TRACE is governed by a board of directors and advisory committees composed of corporate compliance executives, former enforcement officials, and representatives from professional service firms, with connections to institutions such as American Bar Association committees and alumni of federal agencies like the Federal Bureau of Investigation. Funding sources typically include membership dues from multinational companies, fees for certification and training services, and grants or sponsorships from corporate partners and international development organizations including the United Nations Development Programme and multilateral development banks. The organization’s governance and funding model aims to preserve independence while maintaining operational relationships with consulting firms, law firms, and corporate compliance departments.

Category:Anti-corruption organizations Category:Nonprofit organizations based in Washington, D.C.