Trace International INC FY2020 filing

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

501(c)(6) business league; gifts are not tax-deductible as charitable contributions.
$1.7M paid to officers and key staff.
Mission: Form 990 Part I, line 1 · Status: IRS Pub. 78 · Pay: Part VII

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FY2020 · 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
Pay to officers and key staff
$1.7M
to officers and key staff · 25% of spending
Worth a look: pay to officers and key staff is 25% of spending; over 20%.
Pt VII · Sec A
3 mo
of spending, in cash
Plus $6.9M in investments, Pt X · Ln 11–13
Fine: 2.8 months of spending in cash; 1 to 3.
Pt X · Ln 1–2 · Pt I · Ln 18
Liabilities
$5.6M
51% of total assets
Fine: liabilities are 51% of assets; 50% to 65%.
Pt X · Ln 26
Independent board members
3
of 4 voting members
Looks good: 3 of 4 voting members are independent, a majority.
Pt VI · Ln 1a–1b
Looks goodFineWorth a lookConcernNo data yetTap a box for the reason.
Revenue
$5.3M
-24% vs prior year
Spent
$6.8M
Net assets
$5.4M
By yearFY2019–FY2024
Revenue
$5.3M
FY2020▼ -24%
Tap a bar for its year
Revenue by fiscal year
FY2019$6.9M
FY2020$5.3M
FY2021$5.4M
FY2022$5.7M
FY2023$5.6M
FY2024$5.4M
Expenses
$6.8M
FY2020▼ -26%
Tap a bar for its year
Expenses by fiscal year
FY2019$9.2M
FY2020$6.8M
FY2021$5.6M
FY2022$5.6M
FY2023$6.1M
FY2024$6.0M
Net assets
$5.4M
FY2020▼ -18%
Tap a bar for its year
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 FY2020 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

Who runs it and what they're paid

9 people listed on the 990; $1.7M paid to officers and key staff.

Part VII, Section A · reportable compensation
$906,753Pt VII · Sec A
SR. Director Due Diligence
$244,407Pt VII · Sec A
SR. Dir Global Strategy &
$170,315Pt VII · Sec A
Dir Compliance Training &
$143,055Pt VII · Sec A
Manager, IT
$126,230Pt VII · Sec A
Dir Compliance Resources & Dpo
$123,706Pt 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.

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3 programs · in their own filed words · FY2020
01

Program -3

Roundtables: a roundtable was held in new york city (16 attendees). Roundtables facilitate benchmarking among senior level compliance executives from trace member companies. There was no charge for trace members to attend.

Pt IX · col B
02

Program-1

Workshops - trace held a workshop in mexico city (93 attendees) for the employees and third parties of trace members companies. This workshop provided a comprehensive overview of local and international anti-bribery regulations, enforcement trends and compliance best practices.

Pt IX · col B
03

Program-2

Online training: trace provides its members with unlimited use of its customizable training platform and multilingual online training library. Full length and refresher courses cover critical compliance issues including bribery, money laundering, human trafficking and economic sanctions,and are available in up to 29 languages.

Pt IX · col B

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 FY2020 990, line by line.

1The main four
Money inPt VIII
$5.3M
Ln 12
Fees for servicesLn 2g$5.2M
Investment incomeLn 3$92K
Money outPt IX
$6.8M
Ln 25
Owns and owesPt X
$5.4M
net assets · Ln 32
Cash and savingsLn 1–2$1.6M
Total assetsLn 16$11.1M
LiabilitiesLn 26$5.6M
PeoplePt VI, VII
9
listed · VII A
PaidVII A6
Voting boardVI 1a4
IndependentVI 1b3
2In more detail
Revenue in detailPt VIII
Fees for servicesLn 2g$5.2M
Investment incomeLn 3$92K
Gains on assetsLn 7−$3K
Total revenueLn 12$5.3M
Assets in detailPt X, end of year
CashLn 1$842K
SavingsLn 2$749K
Cash and savings togetherLn 1–2$1.6M
InvestmentsLn 11–13$6.9M
Land, buildings, equipmentLn 10c$94K
Other assetsLn 15$1.3M
Total assetsLn 16$11.1M
LiabilitiesLn 26$5.6M
Net assetsLn 32$5.4M
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 FY20End FY20
Cash and savingsLn 1–2$1.1M$1.6M
InvestmentsLn 11–13$6.9M$6.9M
Land, buildings, equipmentLn 10c$127K$94K
Total assetsLn 16$11.1M$11.1M
LiabilitiesLn 26$4.4M$5.6M
Net assetsLn 32$6.6M$5.4M
4Every line
Statement of functional expensesPt IX · every line
LineTotalProgramsManagementFundraising
Grants to domestic organizationsLn 1$214K
Grants and assistance to foreign recipientsLn 3$34K
Pay of current officers, directors and key staffLn 5$907K
Other salaries and wagesLn 7$2.9M
Pension plan contributionsLn 8$524K
Other employee benefitsLn 9$185K
Payroll taxesLn 10$407K
Legal feesLn 11b$20K
Accounting feesLn 11c$26K
Other fees for servicesLn 11g$13K
Advertising and promotionLn 12$61K
Office expensesLn 13$40K
Information technologyLn 14$256K
OccupancyLn 16$194K
TravelLn 17$3K
Conferences, conventions and meetingsLn 19$39K
Depreciation, depletion and amortizationLn 22$200K
InsuranceLn 23$35K
Other expenses (24a–d)Ln 24$698K
All other expensesLn 24e$87K
Total functional expensesLn 25$6.8M

Filing history

YearMoney inMoney outIn minus outNet assetsDownload
FY2024 Latest $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 Viewing $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 R · Related orgs G · Fundraising L · Interested persons I · Grants A · Public support F · Foreign J · Pay O · Explanations
See the full FY2020 990 (6 parts)
Part I · Summary $5,313,051 revenue, 12 lines filed
I-8 Contributions and grantsPrior year $0$0
I-9 Program service revenuePrior year $6,754,376$5,220,755
I-10 Investment incomePrior year $193,328$92,296
I-11 Other revenuePrior year $0$0
I-12 Total revenuePrior year $6,947,704$5,313,051
I-13 Grants and similar amounts paidPrior year $1,442,030$247,489
I-14 Benefits paid to membersPrior year $0$0
I-15 Salaries and benefitsPrior year $5,359,302$4,906,273
I-16a Professional fundraising feesPrior year $0$0
I-17 Other expensesPrior year $2,369,543$1,670,529
I-18 Total expensesPrior year $9,170,875$6,824,291
I-19 Revenue less expensesPrior year −$2,223,171−$1,511,240
Part VI · Governance 3 of 4 board members independent, no flags
VI-1a Voting members of the governing body4
VI-1b Independent voting members3
VI-2 Family or business relationship among officers or directorsNo
VI-12a Written conflict of interest policyYes
VI-13 Written whistleblower policyYes
VI-14 Document retention and destruction policyYes
VI-15a Process for setting top official's payYes
Part VIII · Statement of revenue $5,313,051 across 4 lines filed
VIII-2a-f Program service revenue, itemized rows (sum of 2a–2f as filed)Related to mission $5,220,755$5,220,755
VIII-3 Investment incomeExcluded from tax $94,949$94,949
VIII-7 Net gain or loss on sales of assetsRelated to mission −$2,653−$2,653
VIII-12 Total revenueRelated to mission $5,218,102 · Unrelated business $0 · Excluded from tax $94,949$5,313,051
Part IX · Statement of functional expenses $6,824,291 across 20 lines filed
IX-1 Grants to domestic organizations$213,717
IX-3 Grants and assistance to foreign recipients$33,772
IX-5 Pay of current officers, directors and key staff$906,753
IX-7 Other salaries and wages$2,882,967
IX-8 Pension plan contributions$524,109
IX-9 Other employee benefits$185,067
IX-10 Payroll taxes$407,377
IX-11b Legal fees$19,568
IX-11c Accounting fees$25,804
IX-11g Other fees for services$13,056
IX-12 Advertising and promotion$60,834
IX-13 Office expenses$40,046
IX-14 Information technology$255,739
IX-16 Occupancy$194,464
IX-17 Travel$2,954
IX-19 Conferences, conventions and meetings$38,941
IX-22 Depreciation, depletion and amortization$199,517
IX-23 Insurance$34,772
IX-24 Other expenses (24a–d)$697,849
IX-24e All other expenses$86,985
IX-25 Total functional expenses$6,824,291
Part X · Balance sheet $11,076,298 assets, 16 lines filed
X-1 Cash, non-interest-bearingStart of year $386,874$841,922
X-2 Savings and temporary cash investmentsStart of year $749,545$749,451
X-4 Accounts receivableStart of year $1,006,413$802,530
X-9 Prepaid expenses and deferred chargesStart of year $171,751$170,804
X-10c Land, buildings and equipment, netStart of year $126,622$94,407
X-11 Publicly traded securitiesStart of year $6,878,466$6,871,073
X-14 Intangible assetsStart of year $313,875$225,447
X-15 Other assetsStart of year $1,423,374$1,320,664
X-16 Total assetsStart of year $11,056,920$11,076,298
X-17 Accounts payable and accrued expensesStart of year $438,767$934,888
X-19 Deferred revenueStart of year $2,632,500$3,315,882
X-25 Other liabilitiesStart of year $1,367,756$1,390,732
X-26 Total liabilitiesStart of year $4,439,023$5,641,502
X-27 Net assets without donor restrictionsStart of year $6,617,897$5,434,796
X-32 Total net assets or fund balancesStart of year $6,617,897$5,434,796
X-33 Total liabilities and net assetsStart of year $11,056,920$11,076,298
Part XI · Reconciliation of net assets $5,434,796 net assets at year end
XI-1 Total revenue$5,313,051
XI-2 Total expenses$6,824,291
XI-3 Revenue less expenses−$1,511,240
XI-4 Net assets at start of year$6,617,897
XI-5 Net unrealized gains (losses) on investments$328,139
XI-9 Other changes in net assets$0
XI-10 Net assets at end of year$5,434,796

Form 990 e-file (XML) FY2020 from the IRS · Classification, formation year and address from the IRS Business Master File

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