2021 TRACE Bribery Matrix: Post-Trump U.S. still outside top 20

TRACE first launched its Bribery Risk Matrix in 2014, providing chief compliance officers reliable information about commercial bribery risk worldwide. To arrive at each country’s score, the matrix analyzes four specific domains:

• Domain 1: Business interactions with government.
• Domain 2: Anti-bribery deterrence and enforcement.
• Domain 3: Government and civil service transparency.
• Domain 4: Capacity for civil society oversight.

After dropping from 15th to 23rd last year, the United States saw no change in its position in the 2021 edition of the matrix released Wednesday. “Over the past five years, the business bribery risk environment in the United States worsened significantly when compared with global trends,” TRACE found.

“According to our 2021 data, the business bribery risk environment in the United States worsened under the last presidential administration, which exploited long-term structural issues,” said TRACE President Alexandra Wrage. “Judicial independence deteriorated, threatening to undermine a critical curb on executive power.”

“Other checks on government power declined as well, including independent audits, civic oversight, and press freedom and independence,” Wrage added. “Despite [President Donald] Trump’s public disdain for the [Foreign Corrupt Practices Act], the law remained in full effect under a committed FCPA team at the Department of Justice, but anti-corruption safeguards degraded overall. Taken together, this should serve as a wake-up call for the current administration: The United States is not invulnerable to the conditions that perpetuate business bribery.”

The United Kingdom ranked ninth, while Canada ranked 10th. The matrix ranks 194 countries total.

The countries that posed the highest commercial bribery risk overall, according to the matrix, are North Korea, with a total risk score of 94; Turkmenistan (86); Eritrea (81); Venezuela (81); Somalia (80); and South Sudan (80).

The countries that presented the lowest risk of commercial bribery—as also observed in last year’s matrix—are Denmark (2); Norway (5); Finland (7); Sweden (7); and New Zealand (8).

According to the matrix, the countries that have improved the most over the last five years regarding the underlying factors of commercial bribery risk are Uzbekistan, the Gambia, Armenia, Malaysia, and Angola.

Egypt, Venezuela, Turkey, Poland, and Hungary have seen business bribery risk environments worsen significantly over the past 10 years, according to TRACE. Additionally, commercial bribery risk increased among all the member nations of the Gulf Cooperation Council over the past year.

Risk scores by domain

Domain 1. The matrix found Denmark posed the lowest risk of bribery in Domain 1 concerning business interactions with government, with an overall risk score of 1. Other countries with low risk scores in this domain included Singapore (2); New Zealand (5); Hong Kong (7); and the United Arab Emirates (7).

Those that pose a high risk of bribery in Domain 1, indicating many government touchpoints, included North Korea (100); Turkmenistan (91); Venezuela (82); and Cambodia (80). Turkmenistan, Venezuela, and Cambodia each showed modest improvement year-over-year.

Domain 2. Denmark (1), once again, showed the lowest level of commercial bribery risk concerning the quality of its anti-bribery deterrence and enforcement. Other countries that scored well in this domain included Finland (2), Norway (4), and New Zealand (7).

On the flip side, North Korea (100) showed the highest level of risk, followed by Eritrea (97); South Sudan (96); and Somalia (94).

Domain 3. Those countries that demonstrated the highest level of government transparency and civil service included Sweden (1), Finland (2), Norway (3), and New Zealand (3). Scoring poorly for the second year in a row were Yemen (100), Somalia (97), Eritrea (97), and South Sudan (95).

Domain 4. Countries that boasted the highest capacity for civil society oversight are Denmark (1), Norway (2), Sweden (5), and Finland (5). The highest risk scores belonged to North Korea (100), Eritrea (92), and Turkmenistan (89) once again.