Trace International INC

Not tax-deductible

Annapolis, MD501(c)(6)Community DevelopmentEIN 65-1162716

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To advance commercial transparency and raise anti-bribery compliance standards worldwide.

71¢ of each $1 spent went to programs.
Run by 3 volunteers and 87 employees.
Mission: Form 990 Part I, line 1 · Programs: Part IX · People: Part I, lines 5–6

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FY2024 · Form 990Independent: from IRS data, not the org
Download 990
IRS status
501(c)(6)
not on the IRS revocation list
Looks good: listed by the IRS and not on the revocation list.
IRS BMF · Auto-Revocation List
Tax-deductible gifts
No
Donations are not tax-deductible
Worth a look: the IRS does not list gifts to it as deductible.
IRS Pub. 78 · IRS BMF
Latest return
FY2024
latest Form 990
Looks good: the latest return is for FY2024, 2 tax years back; within 2 tax years.
IRS e-file · Filing history
Surplus or deficit
1 of 6
filings with a surplus
Average deficit $805K a year · 14% of revenue · last 6 filings
Concern: a surplus in 1 of the last 6 filings.
Pt I · Ln 19 · 6 filings
Spent on programs
71%
of spending
Fine: 71% of spending went to programs; 65% to 75%.
Pt IX · Ln 25 · col B
Pay to officers and key staff
$2.7M
to officers and key staff · 45% of spending
Concern: pay to officers and key staff is 45% of spending; over 30%.
Pt VII · Sec A
Cash reserves
2 mo
of spending, in cash
Fine: 2.0 months of spending in cash; 1 to 3.
Pt X · Ln 1–2 · Pt I · Ln 18
Liabilities
$4.5M
51% of total assets
Fine: liabilities are 51% of assets; 50% to 65%.
Pt X · Ln 26
Independent board members
4
of 5 voting members
Looks good: 4 of 5 voting members are independent, a majority.
Pt VI · Ln 1a–1b
Looks goodFineWorth a lookConcernNo data yetTap a box for the reason.
Revenue
$5.4M
-3% vs prior year
Spent
$6.0M
To programs
71%
Net assets
$4.4M
By yearFY2019–FY2024
Revenue
$5.4M
FY2024▼ -3%
Revenue by fiscal year
FY2019$6.9M
FY2020$5.3M
FY2021$5.4M
FY2022$5.7M
FY2023$5.6M
FY2024$5.4M
Expenses
$6.0M
FY2024▼ -2%
Expenses by fiscal year
FY2019$9.2M
FY2020$6.8M
FY2021$5.6M
FY2022$5.6M
FY2023$6.1M
FY2024$6.0M
Net assets
$4.4M
FY2024▼ -11%
Net assets by fiscal year
FY2019$6.6M
FY2020$5.4M
FY2021$5.4M
FY2022$4.9M
FY2023$4.9M
FY2024$4.4M

From the FY2024 Form 990 · figures checked against the IRS filing · see the original

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Is it real?

Yes. Never revoked by the IRS. Latest filing on record: FY2024. IRS ruling in Feb 2003.

IRS Pub. 78 · IRS Auto-Revocation List · IRS Business Master File

Where the money goes

71 cents of each dollar spent went to programs.

Program services 71% · $4.3M

Form 990 Part IX, line 25. Every line is in By the numbers.

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Who runs it and what they're paid

10 people listed on the 990; $2.7M paid to officers and key staff.

Part VII, Section A · reportable compensation
$1,595,834Pt VII · Sec A
Senior Director II, Compliance Training
$350,988Pt VII · Sec A
Senior Director, Operations
$282,322Pt VII · Sec A
Senior Director, Member Services
$211,025Pt VII · Sec A
Senior Manager, Information Systems & Dpo
$167,797Pt VII · Sec A
Manager, Data Science & Analytics
$108,054Pt VII · Sec A
Board Member
$0Pt VII · Sec A
Board Member
$0Pt VII · Sec A

Alexandra Wrage’s $1.6M as President is at the 100th percentile of top reported officer pay among 2832 $1–10M community development nonprofits. Peer set: organizations in the same NTEE major field of work and revenue-size band, compared on each org’s own highest-paid officer/key-employee, from Form 990 Part VII / 990-PF Part VIII. Descriptive placement, not a verdict on whether the pay is appropriate.

Compensation history total reportable pay by year · 8 named individuals · Part VII

NameFY2024FY2023FY2022FY2021FY2020FY2019
Alexandra Wrage$1,595,834$1,076,520$1,081,399$1,051,261$906,753$1,035,532
Pia Vining———$466,550$244,407$309,240
Sunsieray McCall$350,988$185,920$166,155$148,720$143,055$128,250
Lisa Rothert$282,322$169,518$161,729$155,295——
Virna Dipalma—$268,895$164,763$194,561$170,315$220,769
Pia Mikkola-Vining$211,025$120,548————
Beverly Gryder$167,797$150,997$144,747$136,668$126,230—
Robert Clark—$148,768$134,898$105,583—$124,584

Total reportable compensation (Form 990 Part VII column D / Schedule J column E) by filing year, matched by name within this organization. The Schedule J base / bonus / deferred breakdown is not parsed into this dataset.

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Questions the 990 asks

The form asks each of these directly. These are the filed answers.

  • Family or business ties among officersPt VI · Ln 2No
  • Top official's pay set by an independent reviewPt VI · Ln 15aYes

Programs and updates

Promotes fair business practices and higher anti-bribery standards globally.

Provided by the organization

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3 program services account for $3.1M of program spending, described in the organization's own filed words · FY2024.
01

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…

$1.8Mprogram expense
02

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.

$661Kprogram expense
03

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.

$617Kprogram expense

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Funders

Who pays for it.

From grant filings on record. Receipts are incomplete: individual donors are never listed.

Grants

Schedule I · this organization's grantmaking
Grants paid · 12 grants · $3.1M · 2019–2024
Trace FoundationMD · FY2024$200,000
Trace FoundationMD · FY2023$300,000
Trace FoundationMD · FY2022$500,000
Trace FoundationMD · FY2021$500,000
Trace FoundationMD · FY2020$200,000
Trace FoundationMD · FY2019$1,300,000

By the numbers

The FY2024 990, line by line.

1The main four
Money inPt VIII
$5.4M
Ln 12
Fees for servicesLn 2g$5.0M
Investment incomeLn 3$397K
Money outPt IX
$6.0M
Ln 25
Programscol B$4.3M
Owns and owesPt X
$4.4M
net assets · Ln 32
Cash and savingsLn 1–2$979K
Total assetsLn 16$8.8M
LiabilitiesLn 26$4.5M
PeoplePt VI, VII
10
listed · VII A
PaidVII A6
Voting boardVI 1a5
IndependentVI 1b4
2In more detail
Revenue in detailPt VIII
Fees for servicesLn 2g$5.0M
Investment incomeLn 3$397K
Gains on assetsLn 7$108K
Total revenueLn 12$5.4M
Assets in detailPt X, end of year
CashLn 1$722
SavingsLn 2$978K
Cash and savings togetherLn 1–2$979K
InvestmentsLn 11–13$5.6M
Land, buildings, equipmentLn 10c$47K
Other assetsLn 15$1.4M
Total assetsLn 16$8.8M
LiabilitiesLn 26$4.5M
Net assetsLn 32$4.4M
OperationsPt I, VI
EmployeesI 587
VolunteersI 63
Fiscal year endsHeaderDecember
Conflict-of-interest policyVI 12aYes
Whistleblower policyVI 13Yes
Records policyVI 14Yes
3Year over year
Balance sheet, start vs end of yearPt X · col A, B
LineStart FY24End FY24
Cash and savingsLn 1–2$1.2M$979K
InvestmentsLn 11–13$5.9M$5.6M
Land, buildings, equipmentLn 10c$74K$47K
Total assetsLn 16$10.7M$8.8M
LiabilitiesLn 26$5.9M$4.5M
Net assetsLn 32$4.9M$4.4M
4Every line
Statement of functional expensesPt IX · every line
LineTotalProgramsManagementFundraising
Grants to domestic organizationsLn 1$262K
Pay of current officers, directors and key staffLn 5$880K
Other salaries and wagesLn 7$2.7M
Pension plan contributionsLn 8$125K
Other employee benefitsLn 9$126K
Payroll taxesLn 10$239K
Legal feesLn 11b$4K
Accounting feesLn 11c$22K
Investment management feesLn 11f$18K
Other fees for servicesLn 11g$438K
Advertising and promotionLn 12$9K
Office expensesLn 13$34K
Information technologyLn 14$365K
OccupancyLn 16$192K
TravelLn 17$98K
Conferences, conventions and meetingsLn 19$207K
Depreciation, depletion and amortizationLn 22$35K
InsuranceLn 23$37K
Other expenses (24a–d)Ln 24$141K
Total functional expensesLn 25$6.0M

Filing history

YearMoney inMoney outIn minus outNet assetsDownload
FY2024 Latest Viewing $5.4M$6.0M−$554K$4.4M 990 PDF
FY2023 $5.6M$6.1M−$469K$4.9M 990 PDF
FY2022 $5.7M$5.6M$134K$4.9M 990 PDF
FY2021 $5.4M$5.6M−$205K$5.4M 990 PDF
FY2020 $5.3M$6.8M−$1.5M$5.4M 990 PDF
FY2019 $6.9M$9.2M−$2.2M$6.6M 990 PDF

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Schedules filed Part IV

III · Programs I · Grants R · Related orgs G · Fundraising L · Interested persons A · Public support F · Foreign M · Noncash
See the full FY2024 990 (4 parts)
Part VIII · Statement of revenue $5,416,498 across 4 lines filed
VIII-2a-f Program service revenue, itemized rows (sum of 2a–2f as filed)Related to mission $5,019,456$5,019,456
VIII-3 Investment incomeExcluded from tax $289,337$289,337
VIII-7 Net gain or loss on sales of assetsExcluded from tax $107,705$107,705
VIII-12 Total revenueRelated to mission $5,019,456 · Unrelated business $0 · Excluded from tax $397,042$5,416,498
Part IX · Statement of functional expenses $5,970,277 across 19 lines filed
IX-1 Grants to domestic organizations$262,388
IX-5 Pay of current officers, directors and key staff$880,370
IX-7 Other salaries and wages$2,738,256
IX-8 Pension plan contributions$125,003
IX-9 Other employee benefits$125,632
IX-10 Payroll taxes$238,893
IX-11b Legal fees$4,154
IX-11c Accounting fees$22,350
IX-11f Investment management fees$17,932
IX-11g Other fees for services$437,997
IX-12 Advertising and promotion$8,649
IX-13 Office expenses$33,975
IX-14 Information technology$365,197
IX-16 Occupancy$192,059
IX-17 Travel$98,096
IX-19 Conferences, conventions and meetings$206,661
IX-22 Depreciation, depletion and amortization$34,970
IX-23 Insurance$36,902
IX-24 Other expenses (24a–d)$140,793
IX-25 Total functional expenses$5,970,277
Part X · Balance sheet $8,848,487 assets, 15 lines filed
X-1 Cash, non-interest-bearingStart of year $478,753$722
X-2 Savings and temporary cash investmentsStart of year $759,917$978,396
X-4 Accounts receivableStart of year $974,397$671,800
X-9 Prepaid expenses and deferred chargesStart of year $130,650$116,513
X-10c Land, buildings and equipment, netStart of year $73,676$47,249
X-11 Publicly traded securitiesStart of year $5,890,606$5,638,321
X-15 Other assetsStart of year $2,439,206$1,395,486
X-16 Total assetsStart of year $10,747,205$8,848,487
X-17 Accounts payable and accrued expensesStart of year $253,059$256,076
X-19 Deferred revenueStart of year $3,343,307$2,860,570
X-25 Other liabilitiesStart of year $2,266,775$1,381,546
X-26 Total liabilitiesStart of year $5,863,141$4,498,192
X-27 Net assets without donor restrictionsStart of year $4,884,064$4,350,295
X-32 Total net assets or fund balancesStart of year $4,884,064$4,350,295
X-33 Total liabilities and net assetsStart of year $10,747,205$8,848,487
Part XI · Reconciliation of net assets $4,350,295 net assets at year end
XI-1 Total revenue$5,416,498
XI-2 Total expenses$5,970,277
XI-3 Revenue less expenses−$553,779
XI-4 Net assets at start of year$4,884,064
XI-5 Net unrealized gains (losses) on investments$20,010
XI-9 Other changes in net assets$0
XI-10 Net assets at end of year$4,350,295

Form 990 e-file (XML) FY2024 from the IRS · Classification, formation year and address from the IRS Business Master File

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