TRACE International

Nonprofit profile at a glance

EIN
651162716
IRS 990 coverage
2013–2024
Official website data refreshed
Sep 2026
Forms available
Form 990 2024
Location
Annapolis, MD, United States
Phone
+1 410.990.0076
Rating confidence
Limited
Sector
Chambers of Commerce & Business Leagues

Official website

Reported finances

Revenue
$5,416,498
Expenses
$5,970,277
Assets
$8,848,487
Liabilities
$4,498,192

Source: IRS Form 990. Selected filing: tax year 2024. Amounts in USD.

Leadership & pay

10 people listed

Executive titles in this filing

  • ALEXANDRA WRAGE (PRESIDENT)

Highest reported compensation

  • ALEXANDRA WRAGE (PRESIDENT): $1,621,063 total reported compensation
  • SUNSIERAY MCCALL (SENIOR DIRECTOR II, COMPLIANCE TRAINING): $371,999 total reported compensation
  • LISA ROTHERT (SENIOR DIRECTOR, OPERATIONS): $296,662 total reported compensation

Source: IRS Form 990. Selected filing: tax year 2024. Names and roles reflect this filing, not necessarily current officeholders.

Overview

Mission

TRACE International is a non-profit business association dedicated to anti-bribery, compliance, and good governance globally.

What it reported doing in 2024

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 available in over 35 languages featuring proprietary innovations like the infowheel and my course dashboard. The lms team also created and launched a custom-built, proprietary language selector in the trace lms to simplify course access.-trace hosted 17 virtual webinars on various compliance-related topics (e.g. Anti-corruption compliance and enforcement in the us, apac and the eu, trade compliance, the intersection of data analytics and compliance, etc.). Each webinar had an average attendance of 56 participants. All trace webinars are offered at no cost and are available to trace members. 7 of the 17 webinars offered were also offered to the public in support of marketing and business development initiatives.

Operating model

Revenue model
Earned-program. 95% of the money available for current operations came from fees and other program revenue.
Distribution model
Cannot be determined from the filing. The filing does not provide enough consistent spending detail to tell whether the nonprofit works directly or through others.

The verdict

- The available evidence is not sufficient to produce an overall rating for this filing. This is not a warning sign.

Rating breakdown

  • Financial Efficiency: NotEnoughData
  • Transparency & Controls: 56
  • Accountability: 83
  • Sustainability: 24
  • Growth: 0

Detailed rating inputs

Financial Efficiency

  • Mission deployment rate: Limited
  • Program expense ratio: Limited
  • Fundraising efficiency: Limited

Transparency & Controls

  • Consistency checks: 88.9%; rating input score 89; 3rd percentile among comparable filings
  • Pay-setting controls: 2 of 6 controls in place; rating input score 33
    • Compensation committee: Missing
    • Independent consultant: Pass
    • Other Form 990s reviewed: Missing
    • Written employment contract: Missing
    • Compensation survey or study: Missing
    • Board or committee approval: Pass
  • Foreign activity oversight: Scored; rating input score 0
  • Grant itemization coverage: 81.9%; rating input score 82; 22nd percentile among comparable filings
  • Major donor itemization: Limited
  • Related-party transparency: Limited

Accountability

  • Independent voting board: 80%; rating input score 80; 14th percentile among comparable filings
  • Governance controls: 7 of 9 controls in place; rating input score 88
    • Conflict-of-interest policy: Pass
    • Whistleblower policy: Pass
    • Document-retention policy: Pass
    • CEO compensation review process: Pass
    • Other executive compensation review process: Limited
    • Form 990 shared with the board: Pass
    • Board meeting minutes documented: Pass
    • Audit committee oversight: Pass
    • Independent financial-statement audit: Fail

Sustainability

  • Operating margin: -10.2%; rating input score 13; 13th percentile among comparable filings
  • Total-asset coverage ratio: 1.48; rating input score 51; 51st percentile among comparable filings
  • Liabilities to assets ratio: 0.51; rating input score 21; 21st percentile among comparable filings
  • Officer compensation ratio: 47.5%; rating input score 1; 1st percentile among comparable filings

Growth

  • Program expense growth: Limited
  • Revenue growth: -3.2% per year; rating input score 0; 5th percentile among comparable filings
  • Asset growth: -1.2% per year; rating input score 0; 9th percentile among comparable filings

Details

  • What they do: 6 programs and campaigns described on the official site · 1 operating location identified
  • Where the money goes: Financial trends and filed revenue, expense, asset, and liability detail
  • Governance: 4 of 5 board members independent · 7 of 9 filing controls reported
  • Programs: 4 filed program accomplishments · $4.3M in reported program spending
  • Leadership: top reported pay $1.6M · 10 people listed · 2 of 6 pay-setting controls reported
  • Consistency: 11 of 12 current checks pass · 1 finding to review
  • Schedules: 6 filed schedules · includes foreign activity, grants, and executive pay
  • Filing history: 11 filing years from 2013 to 2024
  • Contacts: How to reach this organization
  • Money network: 8 filed money-flow records
  • Related organizations: 2 filed related-organization links
  • Grant readiness: Federal tax and exclusion status, award history, and grant-maker relationships.
  • People: Everyone the filings name, and which of them the filings identify by more than a name.

Key Signals

Signals prioritize questions for review. They are not findings of misconduct.

  • High — Transparency & Controls: Foreign activity oversight scored 0/100.
  • High — Growth: Revenue growth scored 0/100.
  • High — Sustainability: Operating margin scored 13/100.
  • High — Growth: Asset growth scored 0/100.
  • Review — Accountability: Governance controls: Independent financial-statement audit not reported.
  • Review — Transparency & Controls: Domestic grant itemization did not reconcile in the filed values.
  • Review — Sustainability: Total-asset coverage ratio scored 51/100.
  • High — Sustainability: Officer compensation ratio scored 1/100.
  • High — Sustainability: Liabilities to assets ratio scored 21/100.