The Report offers the analysis of investigations and enforcement actions concerning transnational corruption cases from 1977 through 2019, tracked in the TRACE Compendium, TRACE’s online database.

The paper focuses on two types of bribery:

• bribery of foreign officials (improper payments made by a foreign company to a government official who is not a citizen of the government undertaking the enforcement event);
• bribery of domestic officials (improper payments made by a foreign company to a government official who is a citizen of the government undertaking the enforcement event).

1. Investigations

According to TRACE International, in total, there were 328 investigations concerning alleged bribery of foreign officials being conducted by authorities in 37 countries as of December 2019. European countries account for a total of 165 investigations (50%), while the United States was conducting 121 investigations, which represents 37% of all ongoing investigations. The Asia Pacific region accounts for 8% of ongoing investigations, followed by the Americas (excluding the United States) with approximately 3%, the Middle East with approximately 1%, and Africa with fewer than 1%. In the Russian Federation there was just 1 investigation of an alleged case of bribery of a foreign official.

As regards bribery of domestic public officials by foreign companies, since 1977 89 countries launched 269 investigations. Brazil was conducting the most investigations (32), followed by India (17), China (14) and Nigeria (13). Throughout the indicated period the Russian Federation was conducting 3 investigations concerning alleged bribery of domestic officials by foreign companies.

The extractive industries represent the highest number of bribery investigations (20%) of all non-U.S. investigations, followed by engineering/construction (18%), and aerospace/defense/security with approximately 15%. In the United States the extractive industries faced the most investigations (19%), followed by financial services (16%) and manufacturers/service providers (12%).

2. Enforcement actions in transnational bribery cases

TACE International highlights that over the last year enforcement numbers in cases involving bribery of foreign officials dropped with a 45% decrease in non-U.S. enforcement actions and a 19% decrease in U.S. enforcement actions

According to the Report, from 1977 through 2019, 23 countries concluded 420 enforcement actions concerning alleged bribery of foreign officials with 279 enforcement actions undertaken by the United States (66%) and 115 enforcement actions undertaken by countries in Europe (27%). Countries in the Asia Pacific region were responsible for approximately 3% of the total enforcement actions, followed by the Americas (excluding the United States) with 2%, and the Middle East with fewer than 1%. The Russian Federation did not undertake any enforcement actions concerning alleged bribery of foreign officials.

Over the same period of time there have been 106 enforcement actions concerning alleged bribery of domestic officials. Algeria and China have brought the most enforcement actions concerning alleged bribery of domestic officials (10 per each), followed by Brazil (8), Nigeria (7), Germany (6) and South Korea (6).

The extractive industries represent the highest number of bribery enforcement actions (25%) of all non-U.S. bribery enforcement actions, followed by engineering/construction (18%) and manufacturers/service providers (14%), while in the United States the extractive industries have seen the most enforcement actions (18%), followed by manufacturers/service providers (15%) and aerospace/defense/security (12%).

TRACE International develops training and guidance materials on anti-corruption compliance in the private sector. The TRACE Global Enforcement Report is addressed to private companies operating abroad: the provided analysis allows these entities to get acquainted with the data on bribery in different countries and take it into account when conducting corruption risk assessment.