TRACE’s Global Enforcement Report 2018

TRACE’s Global Enforcement Report (GER) provides graphic and textual analyses of all known investigations and enforcement actions involving transnational commercial bribery since the passage of the U.S. Foreign Corrupt Practices Act. The GER derives its data primarily from the TRACE Compendium, TRACE’s database of transnational corruption cases.

The 2018 GER, TRACE’s ninth annual compilation, provides anti-bribery enforcement data from 2018 and summarizes 42 years of anti-bribery enforcement activity.

Key Findings

  • While the number of open U.S. investigations into foreign-bribery allegations dropped slightly in 2018, there was a notable increase in the number of open investigations worldwide, with an expanding range of investigating countries. Europe in particular saw its number of open investigations climb by approximately 37%, and the region now accounts for more than half of all foreign-bribery investigations.

  • The past year saw a notable growth in U.S. enforcement, with the number of U.S. enforcement actions increasing by more than half, approaching the record-setting volume of 2016. The pace of enforcement actions by non-U.S. authorities remained essentially steady.

  • There was also an increase in the number of investigations concerning bribery of domestic officials by foreign sources, showing a rise of approximately 15%. The total cumulative number of domestic enforcement actions also demonstrated a healthy growth of approximately 22%.

  • The Financial Services industry remained the most heavily investigated by United States agencies in connection with foreign-bribery allegations, accounting for approximately 17% of all such investigations. In other jurisdictions, however, the focus remained elsewhere—most prominently the Extractive Industries, Engineering/Construction, and Aerospace/Defense/ Security—with Financial Services accounting for only 6% of open investigations.


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