About TRACE TRACE Foundation

TRACE Foundation

The TRACE Foundation was established to promote, support and fund research, investigative journalism, publications, videos and related projects that encourage greater commercial transparency and advance anti-bribery education. The Foundation also awards scholarships, prizes and grants to individuals and entities working toward these goals and seeks generally to propagate understanding of the sources of corruption and the development of effective measures to reduce the scope and extent of the problem.

The TRACE Foundation receives funding from TRACE International and TRACE Inc., two entities that share its mission. The Foundation has an independent board and exclusive decision making authority over the selection and execution of its projects and disbursement of its funds.

TRACE Foundation Initiatives 

TRACE Prize for Investigative Reporting – Uncovering Commercial Bribery

The award recognizes reporting that uncovers business bribery with the goal of increasing commercial transparency.

Nominees may be print, broadcast or online reporters from any country who have investigated bribery schemes, business activities that create serious conflicts of interest or similar misconduct. Entries must have appeared in print or online during the previous year to be eligible for consideration. Multiple entries per author are permitted, as are team entries produced by groups of journalists. Learn more


A New Anti-Corruption Video Series for Children 

Bribe BustersBribe Busters is an animated video series for children created by TRACE International and released on International Anti-Corruption Day 2016. The videos are available in English, French, and Spanish, with Arabic coming soon.

The series is one of the many initiatives that TRACE International has developed in support of its mission of advancing commercial transparency worldwide. Through Bribe Busters and the accompanying comic books, TRACE International provides communities around the world with the tools to educate children on corruption and to prepare them to be the next generation of leaders in the fight against it.

To learn more about Bribe Busters, and to download the videos and comic books, visit the Bribe Busters homepage

TRACE Scholar Program

TRACE Initiatives - TRACE Scholar ProgramThe TRACE Scholar Program is aimed at developing exceptional leaders in the field of anti-bribery who are committed to advancing commercial transparency.

Students or professionals from developing countries with a demonstrable interest or background in anti-bribery who wish to pursue an LLM degree are invited to apply for this prestigious fellowship. The program funds tuition, lodging and travel. TRACE Scholars spend an academic year at the participating university of their choice where they study relevant courses focused on business ethics, rule of law, governance and/or economic development. Following their course of study, TRACE Scholars take part in a paid summer internship at TRACE headquarters in Annapolis, Maryland.

TRACE Scholars study with students from a diverse range of backgrounds to further enrich their understanding of regional challenges in reducing bribery and corruption. The TRACE Scholar Program develops informed, committed and visible leaders in this field, in support of the work of TRACE and its larger mission.

Candidates must apply directly to their university of choice. Please note that participating universities set their own application procedures and deadlines. Up to four scholarship places are available. For general inquiries, write to a TRACE Representative

Participating Universities, 2017-2018

Peter A. Allard School of Law, University of British Columbia
Application details available here.

University of Washington School of Law
Application details available here.

Georgetown Law
Application details available here.

King’s College, Cambridge University
Application details available here.

TRACE Foundation Board Members

Alexandra Wrage

President and Founder, TRACE.

Alexandra Wrage is president and founder of TRACE. She is the author of Bribery and Extortion: Undermining Business, Governments and Security, co-editor of How to Pay a Bribe: Thinking Like a Criminal to Thwart Bribery Schemes and the host of the training DVD Toxic Transactions: Bribery, Extortion and the High Price of Bad Business, produced by NBC. Ms. Wrage has written several compliance guidebooks and is a guest blogger for Forbes. She speaks frequently on topics of transparency and good governance and the hidden costs of corruption.

Ms. Wrage is a former member of FIFA’s failed Independent Governance Committee. She served on the 2015 and 2017 B20 Taskforces on Anti-Corruption, drafting recommendations to G20 leaders for consideration in their global economic policies.  She has held numerous ABA committee positions and has participated in anti-bribery working groups with the OECD and UN Global Compact.

Ms. Wrage was named one of the 2016 “Maryland’s Top 100 Women” by The Daily Record, one of the “Canadians Changing the World” by the Toronto Globe & Mail and received the 2014 Women in Compliance “Lifetime Achievement Award for Service to the Compliance Industry.”

Prior to founding TRACE, Ms. Wrage was international counsel at Northrop Grumman. Ms. Wrage, a Canadian-American, studied law at King’s College, Cambridge University.


Amy Sommers

Attorney and Chapter Liaison, TRACE.

Amy Sommers is an American lawyer whose career has focused on China-related matters. Her involvement in China goes back over 30 years, when she first started studying Mandarin. For over a decade, she resided in Shanghai, advising multinational companies on their strategic initiatives, during a period of rapid economic development, social change and maturation in China’s legal system. With respect to her anticorruption work, Chambers & Partners, the legal directory of outstanding lawyers around the world noted Ms. Sommers “is singled out by peers for her extensive experience advising on China-related anti-bribery and FCPA compliance issues. Interviewees attribute Sommers’ success in part to her being fluent in Chinese and being based in China for a number of years.”

She is a member of the National Committee of US-China Relations. From 2012-16, Ms. Sommers served on the board of directors of TRACE International, Inc. She has held a range of roles in the American Bar Association’s Section of International Law, is a fellow of the American Bar Foundation, and in 2016 received the Mayre Rasmussen Award for the Advancement of Women in International Law from the ABA Section of International Law in recognition for her contributions. 


Gaye Montgomery

Attorney and Founder, Montgomery Compliance Law PLLC.

After 20 years in the Law Department of the largest tobacco company in the United States, Gaye Montgomery retired from Corporate America and started her own boutique corporate compliance law firm, Montgomery Compliance Law PLLC.

Montgomery Compliance Law understands the intricacies of the modern corporate ecosystem and uses that knowledge to help businesses build and oversee effective and vibrant compliance programs that allow their companies to take calculated risks, make value enhancing business decisions and stay out of trouble.
During Gaye’s 20-year career, she acquired deep expertise and assembled a strong portfolio of skills in corporate compliance and compliance risk management, supply chain integrity, antitrust and sales, distribution and promotion. Gaye collaborated with the sales team to introduce several innovative training programs, culminating with the production of an original film, Breathing Underwater, which earned a gold World Medal at New York Festivals World’s Best TV and Film Awards.

Most recently, as head of the Global Compliance Practice Group, Gaye had management accountability for the corporation’s Anticorruption Compliance Program and counseled the company’s Risk Oversight Committee on regulatory compliance issues, including third-party risk mitigation, cyber security oversight, economic sanctions compliance and evolving expectations of executive management and public company boards to oversee enterprise risk and compliance. Under her leadership, the Global Compliance Practice Group drove the company’s transition from a mature US-centric approach to a modern global compliance approach, and she was recognized in 2016 when she was short-listed for Global Counsel Awards’ Compliance Innovator of the Year Award.

When not working to keep companies compliant, Gaye enjoys spending time with her children, singing in the church choir, volunteering with various charitable and philanthropic organizations and international travel. 


Josh Wallenstein

Former Chief Compliance Officer and Assistant General Counsel, McDermott International, Inc.

Josh Wallenstein is an accomplished attorney and compliance expert.  For the past two years, he has acted as Chief Compliance Officer and Assistant General Counsel for McDermott International. 

Mr. Wallenstein brings over a decade of broad-based legal, compliance, and risk management experience in various sectors from both private legal practice and public in-house corporate compliance positions (including Baker Hughes, Weatherford, and McDermott in the global energy sector).  Having been based in Mexico City, Dubai, and various US cities, Mr. Wallenstein’s previous roles have emphasized the international legal and compliance functions necessary to support those sectors.  Prior to his work in the compliance sector, Mr. Wallenstein also served as an Associate Attorney for Linklaters (in New York) and as Research Director for the Corporate Executive Board (in Washington, DC). 

Mr. Wallenstein is a member of the Texas, New York, and District of Columbia bars.  He holds a J.D. from Stanford Law School and a B. A. from Southern Methodist University; he is a published author and frequent public speaker on ethics and compliance-related issues.


Scott Cooper

Director, National Security Outreach, Human Rights First.

As the Director of National Security Outreach, Scott Cooper is Human Rights First’s chief ambassador to the national security community.  He leads Human Rights First’s efforts to build partnerships with members of the military and national security communities as well as national security-focused think tanks and research institutions.

Prior to joining Human Rights First, Scott spent a career in the Marine Corps.  He flew the EA-6B Prowler, serving five tours in Iraq, two in Afghanistan, one in Europe, and one in the Western Pacific.  He flew the Bosnian and Iraqi no-fly zones, the Kosovo air campaign, and in Operations Enduring Freedom and Iraqi Freedom.  He also served on the ground as a Forward Air Controller in Iraq and Afghanistan.  He commanded an EA-6B Prowler squadron and finished his career as the speechwriter to the head of Marine Corps Aviation.

An expert on civil-military relations, air power, and national security issues, he has published work in the Washington Post, the Washington QuarterlyPolicy Review, Proceedings, and the Marine Corps Gazette.  Scott holds a Bachelor of Science in Political Science from the United States Naval Academy and a Master of Arts in International Relations from the University of Maryland at College Park.


Dr. Stephen Wrage

Professor, US Naval Academy.

Dr. Wrage earned his B.A. in Classics at Amherst College.  On graduating he went to Athens for two years where he taught in a Greek school and served as assistant to the president.  Returning to the U.S. he taught at St. Albans School in Washington, worked at the Brookings Institution for Dr. Helmut Sonnefeldt and attended the Johns Hopkins School of Advanced International Studies. 

He served as assistant dean of the School of Foreign Service at Georgetown University and wrote his dissertation -- a study of human rights in American foreign policy -- at Johns Hopkins under the direction of Dr. Robert Osgood.  He has published scholarly articles and books on a variety of topics in ethics and American foreign policy and is the author of a number of widely used case studies of actual ethical quandaries experienced by officers in the American military. 

In 1995 he spent a Fulbright year in Singapore and has written about that severely controlled society for the Washington Post, the Los Angeles Times, the Asian Wall Street Journal, and the Atlantic Monthly.  In 2004 he published Immaculate Warfare, a study of the ethical, practical and command issues raised by precision guided munitions.  He is an open-ocean sailor and brews his own beer.

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