Strategic Partners


TRACE is a non-profit membership association that pools resources to provide practical and cost-effective anti-bribery compliance solutions for multinational companies and their commercial intermediaries (sales agents and representatives, consultants, distributors, suppliers, etc.).

TRACE provides several core services and products, including: due diligence reports on commercial intermediaries; model compliance policies; an online Resource Center with foreign local law summaries, including guidelines on gifts and hospitality; in-person and online anti-bribery training; and research on corporate best practices.

For multinational companies, TRACE provides a practical and cost-effective alternative to increasingly expensive and time-consuming corporate compliance. For commercial intermediaries, TRACE offers a marketing advantage by creating a bridge between them and companies doing business internationally.


Companies cannot afford to ignore the realities of doing business in today’s increasingly complex compliance environment.

Over the past ten years, an increasing number of countries have enacted anti-bribery laws to implement international anti-corruption conventions criminalizing the bribery of foreign public officials. The new laws typically state that a business will be liable for the corrupt acts and/or the improper payments made by an intermediary if management “knew or should have known” that a particular intermediary was likely to make an inappropriate payment. Thus, companies are required to conduct sufficient due diligence on prospective intermediaries to ensure that they are committed to transparent business practices regardless of business pressure, local law or custom. Anti-bribery laws, however, are deliberately vague on the issue of “sufficient due diligence.”

TRACE was founded to achieve economies of scale and set a common standard for two shared elements of anti-bribery compliance: due diligence reviews and anti-bribery training for business intermediaries and company employees based around the world.


TRACE serves two types of business enterprises: commercial intermediaries and the multinational companies who retain their services.

The term “commercial intermediary” generally refers to any third party entity that interfaces between the principal (a multinational company) and the customer (whether government or commercial). Commercial intermediaries may include sales agents and representatives, consultants, distributors, joint venture partners, financial advisors, real estate brokers, and accountants and lawyers.

To learn more about TRACE membership requirements and services applicable to your business enterprise, please select the appropriate link on the left or download the TRACE brochure.

Intermediaries can be individuals or companies; in some cases, they may even be multinational corporations in their own right. If you were referred to TRACE by a multinational corporate member for the purpose of completing a due diligence review, you would be considered for membership as a commercial intermediary.

If you are still uncertain which membership category applies to you, or you have additional questions about TRACE membership, please contact Member Services at [email protected], or call +1 410 990 0076.

Law firms interested in pro bono partnership opportunities should contact [email protected]. For more information on TRACE partner law firms, please visit our FAQ page.