TRACE Global Enforcement Report 2019
/The 2019 Global Enforcement Report provides an updated summary of international anti-bribery enforcement trends.
Anti-bribery enforcement is increasingly an international affair. Agencies continue to coordinate across borders in the investigation and resolution of large-scale bribery cases, from the landmark Odebrecht case to the record-setting Airbus settlement, which was reached after this report's cutoff date. This cooperation introduces additional complexity but also brings a clear benefit, not just in terms of ever-higher monetary recoveries, but in sending a unified message that corruption will not be tolerated.
2019 was a relatively slow year for enforcement actions in transnational bribery cases. Both global and U.S. enforcement numbers in cases involving bribery of foreign officials dropped, with a 19% decrease in U.S. enforcement actions and a 45% decrease in non-U.S. enforcement actions—though the resulting enforcement levels were not out of line with historical trends of anti-bribery enforcement.
While the financial services industry remained a focus for U.S. anti-bribery enforcement authorities, companies in the extractive industries faced the most U.S. investigations in 2019. There was also an increase in U.S. investigations into bribery of foreign officials in the aerospace, defense and security industries.
In non-U.S. investigations, extractives remained the most investigated industry, followed by engineering/construction and aerospace/defense/security.
As of the end of 2019, Brazil was conducting the most investigations concerning alleged bribery of domestic officials by foreign companies, followed by India and China.
China again had the highest prevalence of alleged bribery by foreign companies, with Chinese officials being the alleged recipients of bribes in more than 110 enforcement events since 1977. Iraq has the next-highest number of enforcement events, followed by Brazil.
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