“Most companies have their arms around how to do due diligence or training,” said Alexandra Wrage, president of TRACE. “But they were careening around. . . complaining they couldn’t get a good grasp on the scope of gifts, hospitality, and travel” that might lead to possible violations of anti-bribery laws.

Few compliance departments have the resources to track every gift. So Wrage and TRACE have come up with a tool to do just that.
By requiring each employee to enter information on a short form—such as type of gift, to whom, at what company or government entity, at what cost—the tool allows a chief compliance officer to search the data a number of ways to look for patterns.