Swiss prosecutors accused Trafigura and its ex-COO, Mike Wainwright, of arranging €4.3 million in bribes to an Angolan government official between 2009 and 2011. These bribes aimed to secure favorable shipping contracts with Angola’s state oil company, Sonangol, resulting in $151 million in profits for Trafigura. In January 2025, the Swiss Federal Criminal Court convicted both Trafigura and Wainwright. Wainwright received a 32-month prison sentence, with 20 months suspended, while Trafigura was fined $3.3 million and ordered to pay $145.6 million in compensation. citeturn0search22

Missing Controls:

• Lack of Anti-Bribery Compliance Programs: No structured training or deterrents for executives.
• Failure in Third-Party Monitoring: No oversight mechanisms to ensure intermediaries acted ethically.
• Absence of Payment Transparency: No strict due diligence on high-risk transactions.
• Weak Regulatory Compliance Checks: Failure to detect bribes over an extended period.

How D360 Can Help:
Design anti-bribery and corruption (ABC) training for executives and employees.
Set up continuous third-party monitoring tools for high-risk markets.
Enforce transaction screening mechanisms to flag suspicious payments.
Develop compliance dashboards with real-time monitoring of global transactions.