BUSINESSREGISTRYFORINTERNATIONALBRIBERYANDEXTORTION (BRIBEline)2011UNITEDSTATESREPORT

This report summarizes information about bribe demands made in the United States and reported to BRIBEline between July 11, 2007 and November 15, 2011. The objective of this reportistoidentifypatternsinreportedbribedemandsintheUnitedStates. The2011BRIBElineUnitedStatesReportistheseventhBRIBElinereportpublishedbyTRACE. Pleasevisitwww.BRIBEline.orgtoreadBRIBElinecountryreportsonBrazil,Mexico,Ukraine, Russia,IndiaandChina. KeyFindings: Nearly 60% of all bribe demands reported to have occurred in the United States were made by a person associated with the government, including government officials (16%),thepolice(14%),rulingpartyofficials1(8%),employeesofstateownedentities (7%),membersofthemilitary(5%),cityofficials(4%),stategovernmentofficials(1%), orjudgesandjudicialrepresentatives(1%). Conversely, 40% of bribe demands made in the United States were reported to have been made by a representative of a private company (21%) or by a bribe seeker who wasnotreadilyidentifiablebythereporter(19%). Withrespecttothe16%ofbribedemandsreportedtohaveoriginatedfromgovernment officials,theOfficeofthePresidentorVicePresidentwascitedin60%ofthesereports as being the source of a bribe demand. These bribe demands were reported to have occurredbetween2002and2007. Sixty percent of respondents reported that a bribe demand was recurring (that is, a bribe was to be provided more than once). Of these recurring demands, over 40% reportedbeingsolicitedforabribebetweentwoandfivetimesinagivenyear,nearly 30% reported being solicited between six and 20 times in a given year, and 18% reportedbeingsolicitedmorethan100timesinagivenyear. Cashwasdemandedinover70%ofallreportedbribesolicitationsintheUnitedStates. On the other hand, noncash bribes were sought in nearly 30% of the reports. These bribe demands included being asked to assist with medical bills or tuition (10%), requestsforgiftsorotheritemsofentertainmentorhospitality(8%),asolicitationfor sexualfavors(7%),orademandtoprovidetravel(3%). Nearly half of all reported bribe demands originating in the United States were extortionate;thatis,abribewassoughtinordertoavoiddamagetoeitherpersonalor commercialinterests(27%),receivedeliveryofaproductorserviceforwhichpayment wasalreadymade(16%),ortoreceivepaymentforservicesalreadyrendered(5%).On the other hand, nearly 35% of all reported bribe demands in the United States were premised on obtaining an undue advantage, such as winning new business (25%),

1TheBRIBElinesurveyisavailablein21languagesandisdesignedtoelicitreportsfromallcountries.Assuch,

someoftheterminologyusedistargetedtoaninternationalaudienceandisnottailoredforaspecificcountry.

influencing a government official (5%), or receiving inappropriate favorable treatment (4%). Over25%ofallreportedbribedemandswereforbribesvaluedatmorethan$50,000; 44%ofallreportedbribedemandsintheUnitedStateswerevaluedatlessthan$5,000.

ComparativeAnalysis The2011BRIBElineUnitedStatesReportrevealsdistinctbriberypatternsintheUnitedStates relativetotheothercountriesstudiedbyBRIBEline.Todate,BRIBElinehascollecteddataon bribery patterns in Brazil, Mexico, Ukraine, Russia, India and China. In comparison to these othercountries,theUnitedStateshasthelowestpercentage(56%)ofbribesdemandsreported to have been made by all categories of government officials and, conversely, the highest percentageofbribedemandsreportedtohavebeenmadebypeopleassociatedwithcompanies (21%), as opposed to government officials. In addition, the United States has the lowest percentage (44%) of relatively small bribes, those valued at less than $5,000, but by far the highest percentage (25%) of demands for bribes valued at more than $50,000. The rate of recurrence(repeatedrequestsforabribepaymentinagivenyear)intheUnitedStates60% of all reported bribe demands falls in the middle of the other countries studied to date. Of these recurring bribe demands, however, the percentage of bribes made in the United States thatweretorecurmorethan100timesinagivenyear(18%)issecondonlytoChinaat19%. The following chart compares key findings from the 2 0 1 1 United States BRIBEline Report with relevant data in theBrazil,Mexico,Ukraine,Russia,IndiaandChinaBRIBElineReports.

BRIBElineDimension United States 56% 21% 60% 18% 73% 28% 48% 34% 44% 25% Brazil Mexico Ukraine Russia India China

Bribedemandsmadebyindividualsassociatedwith thegovernmentasagroup Bribesoriginatingwitharepresentativeofaprivate company Bribedemandsfromasinglesourcemademore thanonetimeinagivenyear(recurrence) Ofrecurringbribedemands,percentofbribes mademorethan100timesinagivenyear Bribedemandsforcash Bribedemandsfornoncashitems Extortionatedemands Bribedemandsmadetogainanundueadvantage Bribedemandsforamountslessthan$5,001 Bribedemandsforamountsmorethan$50,000

81% 6% 48% 15% 73% 28% 41% 32% 58% 8%

85% 3% 57% 15% 81% 19% 44% 28% 65% 6%

92% 2% 66% 7% 87% 14% 58% 16% 82% 4%

91% 3% 56% 4% 88% 12% 63% 16% 87% 5%

91% 2% 47% 9% 92% 8% 77% 12% 79% 5%

85% 3% 73% 19% 77% 23% 54% 32% 51% 10%

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Methodology BRIBEline, a project managed by TRACE, is an anonymous, online reporting tool that collects dataaboutbribesolicitationsmadebyofficial,quasiofficialandprivatesectorindividualsand entities. BRIBEline is a secure, multilingual website available in 21 languages. BRIBEline focusesondemandsidebriberyonly;noinformationisrequestedorcollectedaboutthosewho pay,oroffertopay,bribes. TheBRIBEline2011UnitedStatesReportsummarizesinformationabout73incidentsofbribe demandsmadeintheUnitedStatesandreportedtoBRIBElineintheperiodfromJuly11,2007 toNovember15,2011. Fullsurveyresultsfromthe2011UnitedStatesBRIBElineReportfollow.

Whorequestedthebribe?
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Private Company Representative Other Government Official Police Ruling Party Official Employee of State-Owned Entity Military City Official Provincial or State Government Official Other International/Regional Organizations Non-Governmental Organization Official Judge or Judiciary Representative N=73 1% 1% 1% 1% 4% 5% 7% 8% 14% 16%

21% 19%

ThelargestpercentageofbribedemandsmadeintheUnitedStatesandreportedtoBRIBEline originatewithprivatecompanyrepresentatives(21%ofallreporteddemands)orfromanother source(19%)thatisnotreadilyidentifiablebythereporterasagovernmentofficial,memberof themilitaryorpolice,oranotherspecificcategory. The majority of bribe demands in the United States 56% were requested by a person associatedwiththegovernment,includingagovernmentofficial(16%),amemberofthepolice (14%),arulingpartyofficial(8%),anemployeeofastateownedentity(7%),amemberofthe military(5%),acityofficial(4%),aprovincialorstategovernmentofficial(1%)orajudgeor representativeofthejudiciary(1%). With respect to the 16% of bribe demands originating from government officials, specific government offices and agencies cited by survey respondents as being the source of a bribe demandincludetheOfficeofthePresidentorVicePresident(representingapproximately60% of all such bribe demands), as well as the various government agencies responsible for Agriculture(17%),VisasandImmigration(17%),andTaxation(9%).

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Iftherequestforthebribewasrecurring(i.e.abribewastobeprovidedmore thanonce),approximatelyhowfrequentlydidtherequestrecurinagivenyear?

43%

27% 18% 9% 2% 5 times or fewer 6-20 times 21-50 times N=44 51-100 times More than 100 times

Sixtypercentofsurveyrespondentsreportedthattheyreceivedmultiplebribedemandsfrom the same source or that a bribe was to be provided more than once in a given year. Seventy percentofthosewhoreportedreceivingrecurringbribedemandsweresolicitedbetweentwo andtwentytimesinagivenyear.Nearly20%ofthesereportersindicatedtheyweresolicited forabribemorethan100timesinagivenyear.

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 Whichbestdescribestheprimaryformofthebriberequested? Cash or Cash Equivalent 73% Other benefit (assistance with visas, medical 10% care, scholarships for higher education, etc.) Gift, Entertainment or Hospitality 8% Sexual Favors 7% Travel 3% N=73 Similar to all other countries studied to date by BRIBEline, cash (or its equivalent) is the overwhelmingly preferred form of bribe in the United States. Nearly 30% of demands in the UnitedStates,however,wererequestsfornoncashbribes,includingageneralOtherbenefit (forexample,beingaskedtohelpexpeditevisasorsecuremedicalcareorscholarships)(10%), providing gifts, entertainment and hospitality (such as jewelry or tickets to sporting events) (8%),grantingsexualfavors(7%),orfinancingpersonaltravelexpenses(3%). -6-

 Pleaseindicatetheprimarynatureoftherequestedbribe: Avoiding harm to you or your business' interests 27% Winning new business 25% Receiving timely delivery of a service to which 16% the reporter is entitled Other 16% Receiving payments for services already 5% rendered Exercising influence with or over another 5% government official Receiving inappropriate favorable treatment 4% such as in a court ruling N=73 Nearlyhalfofsurveyrespondentsreportedbeingthevictimofextortionatedemands,including avoiding personal harm or harm to business interests (27%), receiving timely delivery of a servicetowhichthetargetofthebribedemandisalreadyentitled(16%)orbeingaskedfora bribeinordertoreceivepaymentforservicesalreadyrendered(5%). In 34% ofall bribe demands reported, an item of value was demandedin order to gainsome formofpreferentialtreatment,suchastheprospectofwinningnewbusiness(25%),apromise to exercise influence with or over a government official (5%) or the opportunity to receive inappropriatefavorabletreatment(4%).

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 Valueoftherequestedbribe? 19% 14% 12% 11% 10% 8% 8% 7% 5% 5% N=73 Nearly half of all bribe demands made in the United States (49%) were valued at less than $10,000and25%werevaluedatgreaterthan$50,000. -8-

Inwhatyearwasthebribereported?
26%

16% 14% 10% 7% 4% 1% Before 2002 2002 2003 2005 2006 N=73 2007 2008 2009 2010 2011 4% 5% 12%

Nearly 75% of bribe demands made in the United States and reported to BRIBEline occurred betweenJanuary1,2006andNovember15,2011.

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