The GER 2014 offers both graphic and textual analyses of investigations, declinations and enforcement actions concerning the bribery of government officials from the enactment of the U.S. Foreign Corrupt Practices Act (“FCPA”) in 1977 through December 31, 2014. Whenever TRACE obtains new or improved information regarding an investigation or enforcement action, or when the status of an enforcement action changes, the TRACE Compendium is updated accordingly. The GER 2014 thus reflects several updates to the data reported in earlier editions of the GER. The TRACE Compendium and the GER 2014 cannot provide a precise and objective measurement of global anti-corruption enforcement. Instead, they are meant to provide general information on trends in international anti-corruption efforts on a broad scale. 

The GER 2014 focuses on three distinct anti-bribery enforcement events undertaken by government authorities: investigations, enforcement actions and declinations. An investigation is an ongoing investigation by a government authority into allegations of bribery of government officials by a foreign company or individual. TRACE recognizes that investigations into allegations of bribery are sometimes dropped due to insufficient evidence, or for security or political considerations; they may be closed without any resolution; or they may continue indefinitely with no other action ever being taken. However, unless publicly available information indicates that action was taken, either through an enforcement action or a declination, such an investigation is considered an ongoing investigation for the purposes of the GER 2014. An enforcement action is an adjudication of allegations of bribery of government officials by a foreign company or individual. That is, there must be a final resolution that involves fines or penalties, a guilty plea, a sentencing or a settlement of charges. A declination occurs where an investigation is terminated but there is no enforcement action. That may mean a finding after trial that a company or individual is not guilty, or an authority deciding not to bring charges. 

The TRACE Compendium and GER 2014 also include allegations of bribery against individual employees or representatives of companies (including employees of local subsidiaries of international companies). When a company and its employees or representatives face multiple enforcement actions involving substantially the same conduct, only one enforcement action is counted in the Global Enforcement Report 2014 - Page 2 ©2015 TRACE International, Inc. All rights reserved. GER 2014. If a company does not face an enforcement action but its employees or representatives do, the enforcement action is counted as one enforcement action. Enforcement actions involving third parties count as one enforcement action for that third party. Finally, while multiple different authorities in one country may be responsible for enforcement actions, only one enforcement action is counted against a company or individual.