Alexandra Wrage, president and founder of Annapolis, Maryland-based TRACE International. Courtesy photo

Anti-bribery group TRACE International released its annual report on the risk of corruption in 200 countries, and once again New Zealand and the Scandinavian countries showed the least risky culture while Somalia still ranked as the riskiest.

The 2019 TRACE Bribery Risk Matrix shows Norway, Denmark, Sweden and Finland rank just behind New Zealand in the lowest risk group.

Countries on the list that will most worry general counsel and compliance lawyers were South Sudan, Yemen, Venezuela and North Korea, which ranked with Somalia in the highest risk group.

The U.S. ranked No. 15 this year, slightly better than last year's score of No. 18, but the U.K., Netherlands, Germany, Canada and Hong Kong all ranked higher, that is, less risky.

TRACE President Alexandra Wrage told Corporate Counsel that, according to feedback from general counsel and chief compliance officers, the matrix "seems to be accomplishing its primary goal" of enabling companies to allocate resources in response to the actual risk of bribe demands in a market.

Daniel Seltzer, senior director of anti-corruption and government compliance at Accenture, said the matrix is a critical part of his company's risk assessment process. Accenture is a global management consultant and professional services company. He said the matrix's single-number rating accurately quantifies risk, and then offers "granular detail in four critical categories for those wanting to do a deeper dive."

"As the global head of anti-corruption and government compliance for a company that does business in more than 120 countries," Seltzer said, "understanding the risks of each market is a critical part of my job. And while there are a number of products on the market that purport to identify country-level risks, there is no match for TRACE's risk matrix."

Wrage said the matrix also helps compliance professionals "think about the problem of bribery as something much more complex than a simple transaction." A bribe can take a lot of different forms, she explained, in different industries and across different markets.

"The response to a bribe demand for a senior official in a thuggish, resource-rich dictatorship will be different than the response to a bribe demand from a low-level bureaucrat in a rural town in Southeast Asia," Wrage said. "The levels of corruption in both countries might be similar, but the response to each will be different."

She said, "The good news from in-house lawyers is that there's less resistance to due diligence, training and other components of a robust anti-bribery program. Employees and business partners now expect these measures and so take them in stride."

Wrage said the bad news, though, arises from the same familiarity. "There's a growing risk of 'compliance fatigue' as companies struggle to implement the same measure in new ways," she added.

Internationally she said in-house counsel are seeing most countries moving toward greater transparency. "Unfortunately, those that aren't are growing more sophisticated in their bribery schemes in order to circumvent increasingly complex compliance programs," she said.

While the slight shifts in countries and rankings might be insignificant this year, TRACE has added a new tool to the matrix offering "a better way to frame the discussion of bribery risk than simply asking who's up and who's down," Wrage said.

Called bribery risk typology, it's a system that groups together similarly situated countries to allow more meaningful comparisons, Wrage said. The typology reflects subdivisions such as state fragility, economic size and complexity, and strength of enforcement and civil society.

For example, if a general counsel wanted to steer his company away from doing business in countries with a shaky government structure and low enforcement levels, a browser search would show which countries to avoid.

Annapolis, Maryland-based TRACE is an anti-bribery business association and a provider of shared-cost risk management solutions. Its members and clients include over 500 global companies.

Its matrix is based on a complex methodology involving four domains and numerous subcategories. The research team aggregates data obtained from leading public interest and international organizations, including the United Nations, the World Bank and the World Economic Forum, into the categories.

A matrix browser helps users sort the data and identify patterns, further refined by this year's typology tool.