2025-10-31T08:59:10-05:00 2024-12-31 520982413 GROSS MENDELSOHN & ASSOCIATES PA 1801 PORTER STREET SUITE 500 BALTIMORE MD 21230 990 2024-01-01 651162716 TRACE INTERNATIONAL INC TRAC 4109900076 151 WEST STREET 300 ANNAPOLIS MD 21401 ALEXANDRA WRAGE PRESIDENT 4109900076 2025-10-31 1 1 JENNIFER ROCK P01083312 4106855512 2025-10-31 2024 2025-03-06 01:10:19Z ALEXANDRA WRAGE 151 WEST STREET 300 ANNAPOLIS MD 21401 7489882 0 X WWW.TRACEINTERNATIONAL.ORG X 2002 DC SEE SCHEDULE O 5 4 36 0 0 0 0 0 5280584 5019456 280810 397042 32975 0 5594369 5416498 348894 262388 0 0 4186999 4108154 0 0 0 1527534 1599735 6063427 5970277 -469058 -553779 10747205 8848487 5863141 4498192 4884064 4350295 X SEE SCHEDULE O 0 0 1778382 ONLINE TRAINING -THE TRACE ELEARNING CONTENT DEVELOPMENT TEAM PUBLISHED 20 NEW COURSES ON TOPICS INCLUDING TRADE AND EXPORT CONTROLS, INSIDER TRADING, CONFLICTS OF INTEREST AND COMPLETED NEARLY 50 CUSTOMIZATION PROJECTS FOR TRACE MEMBERS.-THE TRACE LMS AND TECHNICAL SUPPORT TEAM LAUNCHED A FULLY REDESIGNED, MULTILINGUAL PLATFORM AVAILABLE IN OVER 35 LANGUAGES FEATURING PROPRIETARY INNOVATIONS LIKE THE INFOWHEEL AND MY COURSE DASHBOARD. THE LMS TEAM ALSO CREATED AND LAUNCHED A CUSTOM-BUILT, PROPRIETARY LANGUAGE SELECTOR IN THE TRACE LMS TO SIMPLIFY COURSE ACCESS.-TRACE HOSTED 17 VIRTUAL WEBINARS ON VARIOUS COMPLIANCE-RELATED TOPICS (E.G. ANTI-CORRUPTION COMPLIANCE AND ENFORCEMENT IN THE US, APAC AND THE EU, TRADE COMPLIANCE, THE INTERSECTION OF DATA ANALYTICS AND COMPLIANCE, ETC.). EACH WEBINAR HAD AN AVERAGE ATTENDANCE OF 56 PARTICIPANTS. ALL TRACE WEBINARS ARE OFFERED AT NO COST AND ARE AVAILABLE TO TRACE MEMBERS. 7 OF THE 17 WEBINARS OFFERED WERE ALSO OFFERED TO THE PUBLIC IN SUPPORT OF MARKETING AND BUSINESS DEVELOPMENT INITIATIVES. 660805 GLOBAL EVENTS-TRACE HELD TWO ANNUAL FORUM EVENTS IN 2024: A TWO-DAY IN-PERSON FORUM WAS HELD IN ANNAPOLIS, MD AND A 2-DAY IN-PERSON FORUM WAS HELD IN LONDON, UK. EACH EVENT HAD ATTENDANCE OF APPROXIMATELY 75 MEMBERS AND SPEAKERS. THERE WAS NO CHARGE FOR PARTICIPATION. WE ALLOWED ONE REPRESENTATIVE PER MEMBER COMPANY AND ONE REPRESENTATIVE TO THE WAIT LIST. SPEAKERS AND ATTENDEES AT EACH EVENT INCLUDED ENFORCEMENT OFFICIALS, SENIOR LEVEL COMPLIANCE EXECUTIVES AND OUTSIDE COUNSEL. PANEL DISCUSSIONS PROVIDED ATTENDEES WITH PRACTICAL COMPLIANCE GUIDANCE AND FACILITATED BENCHMARKING. -ROUNDTABLES: TRACE HOSTED TWO EXECUTIVE ROUNDTABLE EVENTS -- ONE IN SINGAPORE AND ONE IN HOUSTON. ATTENDANCE AT EACH ROUNDTABLE EVENT WAS LIMITED TO 10-20 SENIOR LEVEL COMPLIANCE EXECUTIVES FROM TRACE MEMBER COMPANIES, TO FACILITATE ENGAGING DISCUSSIONS AND BENCHMARKING. THERE WAS NO CHARGE FOR TRACE MEMBERS TO ATTEND. 616893 LIVE MEMBER SUPPORT AND SERVICES-TRACE CONDUCTED AN ANALYSIS OF OUR OUTREACH EFFORTS TO DETERMINE WHICH COMMUNICATION METHODS WERE MOST EFFECTIVE IN REACHING MEMBERS TO ENSURE AWARENESS OF THE MEMBERSHIP BENEFITS AVAILABLE TO THEM. BASED ON THE RESULTS, THE MEMBER SERVICES TEAM UPDATED ITS OUTREACH FREQUENCY AND METHODS TO BEST SERVE ITS MEMBERS AND INCREASE ENGAGEMENT. TRACE ALSO STREAMLINED ITS LIVE SUPPORT OPERATIONS TO REDUCE COSTS AND IMPROVE EFFICIENCY. 1204551 1204551 4260631 0 0 0 1 0 0 0 0 0 1 0 0 1 1 1 0 0 0 1 1 1 0 0 0 0 0 1 0 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 13 0 1 36 1 0 0 0 0 0 0 1 0 X 5 4 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 0 0 X X ALEXANDRA WRAGE 4109900076 151 WEST STREET SUITE 300 ANNAPOLIS MD 21401 ALEXANDRA WRAGE PRESIDENT 40.00 X X 1595834 0 25229 BAPSY DASTUR BOARD MEMBER 1.00 X 0 0 0 LEE NELSON BOARD MEMBER 1.00 X 0 0 0 ANDREA LO GAGLIO BOARD MEMBER 1.00 X 0 0 0 HENTIE DIRKER BOARD MEMBER 1.00 X 0 0 0 BEVERLY GRYDER SENIOR MANAGER, INFORMATION SYSTEMS & DPO 40.00 X 167797 0 17179 SUNSIERAY MCCALL SENIOR DIRECTOR II, COMPLIANCE TRAINING 40.00 X 350988 0 21011 PIA MIKKOLA-VINING SENIOR DIRECTOR, MEMBER SERVICES 40.00 X 211025 0 32403 LISA ROTHERT SENIOR DIRECTOR, OPERATIONS 40.00 X 282322 0 14340 KSENIYA HUSAK MANAGER, DATA SCIENCE & ANALYTICS 40.00 X 108054 0 6820 2716020 0 116982 6 0 1 0 0 MEMBERSHIP DUES 541900 4700116 4700116 TRAINING PROGRAM 541900 311580 311580 OTHER PROGRAM REVENUE 541900 7760 7760 5019456 289337 289337 2181089 2073384 107705 107705 107705 5416498 5019456 0 397042 262388 880370 2738256 125003 125632 238893 4154 22350 17932 437997 8649 33975 365197 192059 98096 206661 34970 36902 TAXES 135993 HUMAN RESOURCES 4800 5970277 478753 722 759917 978396 974397 671800 130650 116513 390228 342979 73676 47249 5890606 5638321 2439206 1395486 10747205 8848487 253059 256076 3343307 2860570 2266775 1381546 5863141 4498192 X 4884064 4350295 4884064 4350295 10747205 8848487 -553779 20010 0 X X 1 X 0 1 0 0 0 0 4700116 17772 14607 3165 77674 53173 24501 294782 275199 19583 47249 SECURITY DEPOSITS 9666 DEFERRED COMPENSATION INVESTMENTS 706702 OPERATING LEASE RIGHT-OF-USE ASSETS 679118 1395486 125125 DEFERRED COMPENSATION 706702 OPERATING LEASE LIABILITIES 549719 1381546 X PART X, LINE 2: THE ORGANIZATION HAS BEEN RECOGNIZED BY THE INTERNAL REVENUE SERVICE (IRS) AS A TAX-EXEMPT ORGANIZATION, AS DEFINED BY SECTION 501(C)(6) OF THE INTERNAL REVENUE CODE (IRC), THAT IS PUBLICLY SUPPORTED AND, THEREFORE, NOT A PRIVATE FOUNDATION. INCOME THAT IS NOT RELATED TO EXEMPT PURPOSES, LESS APPLICABLE DEDUCTIONS, IS SUBJECT TO FEDERAL AND STATE INCOME TAXES. THE ORGANIZATION HAD NO UNRELATED BUSINESS INCOME FOR THE YEARS. ACCORDINGLY, NO PROVISION FOR INCOME TAXES IS REFLECTED IN THESE STATEMENTS. THE ORGANIZATION'S FEDERAL EXEMPT ORGANIZATION TAX RETURNS ARE SUBJECT TO EXAMINATION BY THE IRS, GENERALLY FOR A PERIOD OF THREE YEARS AFTER THE RETURNS ARE FILED. 1 SOUTH ASIA 1 PROGRAM SERVICES PROGAM SUPPORT CONSULTANT 108175 NORTH AMERICA 1 40 PROGRAM SERVICES PROGRAM SUPPORT CONSULTANTS/ GLOBAL EVENTS/SPECIAL PROJECTS 3138647 EUROPE (INCLUDING ICELAND & GREENLAND) - ALBANIA, ANDORRA, AUSTRIA, BELGIUM 1 PROGRAM SERVICES PROGRAM SUPPORT CONSULTANTS/ GLOBAL EVENTS/SPECIAL PROJECTS 168825 EAST ASIA & THE PACIFIC 3 PROGRAM SERVICES PROGRAM SUPPORT CONSULTANTS/ GLOBAL EVENTS/SPECIAL PROJECTS 64457 CENTRAL AMERICA AND THE CARIBBEAN 1 PROGRAM SERVICES PROGRAM SUPPORT CONSULTANTS 16865 NORTH AMERICA GRANTS PROGRAM SUPPORT 215000 EUROPE (INCLUDING ICELAND & GREENLAND) GRANTS PROGRAM SUPPORT 25971 1 46 0 0 1 46 3737940 0 3737940 EUROPE (INCLUDING ICELAND & GREENLAND) 2024 SYMPOSIUM SPONSORSHIP 25971 WIRE 0 COST 0 0 0 0 0 0 1 TRACE FOUNDATION 151 WEST STREET ANNAPOLIS MD 21401 475363033 501(C)(3) 200000 0 GENERAL SUPPORT INTERNATIONAL CENTER FOR JOURNALISTS 750 17TH STREET NW SUITE 300 WASHINGTON DC 20036 112724905 501(C)(3) 15000 0 SPONSORSHIP - GALA TRIBUTE TO JOURNALISTS, SILVER LEVEL 2 PART I, LINE 2: TRACE PROVIDES CHARITABLE AND SPONSORSHIP FUNDING TO VARIOUS ORGANIZATIONS WHOSE MISSIONS WE SUPPORT, TYPICALLY ON A NON-DESIGNATED BASIS, AT THE DISCRETION OF TRACE PRESIDENT AND BOARD. WE DO NOT HAVE A FORMAL POLICY GOVERNING SUCH CONTRIBUTIONS BUT ENSURE THAT RECIPIENT ORGANIZATIONS ARE REPUTABLE AND IN GOOD STANDING PRIOR TO FUNDING. X X 0 1 0 ALEXANDRA WRAGE PRESIDENT 607598 0 247543 0 740693 0 20700 0 4529 0 1621063 0 740693 0 SUNSIERAY MCCALL SENIOR DIRECTOR II, COMPLIANCE TRAIN 180601 0 42031 0 128356 0 9575 0 11436 0 371999 0 128356 0 LISA ROTHERT SENIOR DIRECTOR, OPERATIONS 163821 0 39330 0 79171 0 13019 0 1321 0 296662 0 79171 0 PIA MIKKOLA-VINING SENIOR DIRECTOR, MEMBER SERVICES 145449 0 39649 0 25927 0 9959 0 22444 0 243428 0 25927 0 BEVERLY GRYDER SENIOR MANAGER, INFORMATION SYSTEMS 149207 0 18590 0 0 0 9387 0 7792 0 184976 0 0 0 PART II AMOUNTS INCLUDED IN OTHER REPORTABLE COMPENSATION ON SCHEDULE J REPRESENT AMOUNTS DISTRIBUTED FROM A NON-QUALIFIED DEFERRED COMPENSATION PLAN FORM 990, PART I, LINE 1, DESCRIPTION OF ORGANIZATION MISSION: TRACE IS A NON-PROFIT BUSINESS ASSOCIATION, HEADQUARTERED IN THE UNITED STATES AND REGISTERED IN CANADA, DEDICATED TO ANTI-BRIBERY, COMPLIANCE AND GOOD GOVERNANCE. MEMBERS OF THE TRACE COMPLIANCE COMMUNITY INCLUDE HUNDREDS OF MULTINATIONAL CORPORATE AND SME COMPANIES LOCATED WORLDWIDE AND REPRESENTING ALMOST EVERY INDUSTRY. TRACE'S SHARED SERVICES MEMBERSHIP MODEL PROVIDES MEMBER COMPANIES WITH PRACTICAL AND AFFORDABLE COMPLIANCE SOLUTIONS AND THE OPPORTUNITY TO SHARE COMPLIANCE BEST PRACTICES. TRACE OFFERS SEVERAL MEMBERSHIP PLAN OPTIONS OFFERING ACCESS TO RESOURCES RELATED TO THE FOLLOWING PROGRAM AREAS: ONLINE COMPLIANCE TRAINING, ONLINE MEMBER RESOURCES, LIVE MEMBER SUPPORT, GLOBAL EVENTS AND SPECIAL PROJECTS. *ONLINE COMPLIANCE TRAINING* TRACE OFFERS MULTILINGUAL COMPUTER-BASED COMPLIANCE COURSES ON TOPICS SUCH AS ANTI-BRIBERY, CONFLICTS OF INTEREST, SEXUAL HARASSMENT, CONFLICT MINERALS, ETC. COURSES ARE AVAILABLE IN UP TO 29 LANGUAGES AND MANY ARE CUSTOMIZABLE. DEPENDING ON THE MEMBER'S ELECTED MEMBERSHIP PLAN, THEY CAN ASSIGN TRAINING COURSES BOTH TO THEIR EMPLOYEES AND THIRD PARTIES (E.G. SUPPLIERS, VENDORS, INTERMEDIARIES, CONSULTANTS, AGENTS, AFFILIATES, BUSINESS PARTNERS, ETC.). COURSES CAN BE DEPLOYED VIA TRACE'S CUSTOMIZABLE LEARNING MANAGEMENT SYSTEM (LMS) AND/OR APPROVED COMPANY AND SUBSIDIARY INTERNAL LMS PLATFORM(S). OPTIONAL TRAINING PACKAGES ARE AVAILABLE TO ALL CORPORATE MEMBERS SEEKING ENHANCED TRAINING OR LMS CONTENT CUSTOMIZATIONS AND SUPPORT. ADDITIONALLY, MEMBERS ARE INVITED TO ATTEND TRACE WEBINARS ON VARIOUS COMPLIANCE-RELATED TOPICS, TO HELP THEM STAY CURRENT ON COMPLIANCE TOPICS AND DEVELOPMENT. TRACE ALSO OFFERS A FOUNDATIONAL ANTI-BRIBERY TRAINING PROGRAM CALLED "TRACEPRO AND A CUSTOMIZABLE CONFLICTS OF INTEREST QUESTIONNAIRE THAT COMPANIES CAN DEPLOY VIA THE LMS. *ONLINE MEMBER RESOURCES* TRACE OFFERS ONLINE MEMBER ACCESS TO THE FOLLOWING RESOURCES - COUNTRY-SPECIFIC SUMMARIES OF LOCAL LAWS, LOCAL GIFTS AND HOSPITALITY GUIDELINES, AS WELL AS OF E-GOVERNMENT RESOURCES THAT ARE AVAILABLE - TRAINING AIDS AND MEMES - MODEL POLICIES, CONTRACTS AND COMPLIANCE CHECKLISTS - BENCHMARKING DATA -TRACE PARTNER FIRMS DIRECTORY ACCESS TO A LIST OF HUNDREDS OF REPUTABLE LAW FIRMS AND LAWYERS WITH ANTI-BRIBERY PRACTICES THROUGHOUT -SUMMARIES OF TRANSNATIONAL BRIBERY CASES & GLOBAL ENFORCEMENT ACTIONS AS WELL AS RISK OF BRIBERY BY COUNTRY -ACCESS TO A CUSTOMIZABLE ONLINE SYSTEM FOR TRACKING AND APPROVING BOTH INCOMING AND OUTGOING GIFTS, MEALS, TRAVEL AND ENTERTAINMENT EXPENSES. *LIVE MEMBER SUPPORT* TRACE'S MULTILINGUAL MEMBER SERVICES TEAM PROVIDES MEMBERS WITH LIVE SUPPORT AND ENDEAVORS TO KEEP THEM INFORMED OF COMPLIANCE-RELATED DEVELOPMENTS AND SERVICES THAT MAY BE OF INTEREST. WHILE TRACE DOES NOT PROVIDE LEGAL ADVICE, TRACE'S LEADERSHIP TEAM IS AVAILABLE FOR STRATEGY CALLS AND TO ASSIST MEMBERS IN IDENTIFYING HELPFUL COMPLIANCE *GLOBAL EVENTS* TRACE CORPORATE MEMBERS ARE INVITED TO ATTEND TRACE'S VARIOUS IN-PERSON EVENTS. TRACE TYPICALLY HOSTS AN ANNUAL FORUM EVENT DESIGNED FOR MEMBER LEGAL AND COMPLIANCE OFFICERS, AND VARIOUS INTERNATIONAL WORKSHOPS, SOME OF WHICH ARE RESTRICTED TO MEMBER EMPLOYEES, AND OTHER OF WHICH ARE OPEN TO MEMBER SUBSIDIARIES AND THIRD PARTIES. *SPECIAL PROJECTS* THE TRACE COMPLIANCE COMMUNITY AIMS TO SPREAD GLOBAL ANTI-BRIBERY AND ANTI-CORRUPTION AWARENESS THROUGH VARIOUS INITIATIVES AND SPECIAL PROJECTS (E.G. PUBLICATIONS, FILMS, A BLOG, PODCAST AND INTERVIEWS) AND BY SUPPORTING OTHER ORGANIZATIONS. FORM 990, PART VI, SECTION B, LINE 11B THE FORM 990 IS REVIEWED BY TRACE'S INTERNAL ACCOUNTING MANAGER, SENIOR DIRECTOR OF OPERATIONS, AND THE PRESIDENT. THE FORM 990 IS THEN PRESENTED TO THE BOARD OF DIRECTORS FOR REVIEW PRIOR TO FILING. FORM 990, PART VI, SECTION B, LINE 12C THE ORGANIZATION RELIES ON SELF-REPORTING OF CONFLICTS. EMPLOYEES ARE REQUIRED TO SIGN HANDBOOK WHICH INCLUDES THIS POLICY. FORM 990, PART VI, SECTION B, LINE 15A THE PRESIDENT'S COMPENSATION IS DETERMINED BY THE COMPENSATION COMMITTEE WITH THE BOARD OF DIRECTORS, BASED ON PERFORMANCE. THE COMPENSATION COMMITTEE REQUESTED AN EXTERNAL REVIEW BY AN INDEPENDENT CONSULTING FIRM IN 2014 AND VIEWED THE PRESIDENT'S COMPENSATION AS CONSISTENT WITH THE CONSULTING FIRM'S REPORT RECOMMENDATIONS. FORM 990, PART VI, SECTION C, LINE 19 THIS INFORMATION IS AVAILABLE TO THE PUBLIC UPON REQUEST AT THE OFFICE OF TRACE INTERNATIONAL, INC. THE 990 IS ALSO AVAILABLE AT GUIDESTAR.ORG. FORM 990, PART XII, LINE 2C: THE BOARD OF DIRECTORS ASSUMES RESPONSIBILITY FOR THE OVERSIGHT OF THE REVIEWED STATEMENTS AND SELECTION OF AN INDEPENDENT ACCOUNTANT.