CCCP International Compliance Programs 2

Question 1

Which international framework provides guidance on anti-bribery management systems and is recognized as the global standard for anti-corruption compliance?

Accepted Answer

ISO 37001

Answer

ISO 37001 is the international standard specifically designed for anti-bribery management systems, providing a framework for organizations to prevent, detect, and respond to bribery.

Question 2

When a U.S. company's foreign subsidiary makes a payment to a government official to expedite a routine customs clearance, this most likely violates which law?

Accepted Answer

The Foreign Corrupt Practices Act

Answer

The FCPA prohibits U.S. companies and their foreign subsidiaries from making payments to foreign government officials to obtain or retain business, including facilitation payments above de minimis thresholds.

Question 3

A multinational company conducts an acquisition of a foreign entity and discovers pre-acquisition FCPA violations. What is the best immediate compliance action?

Accepted Answer

Conduct thorough post-acquisition due diligence and consider voluntary disclosure

Answer

Post-acquisition due diligence to uncover inherited liabilities followed by timely voluntary disclosure to the DOJ/SEC is the recommended approach and can result in reduced penalties.

Question 4

Under the UK Bribery Act 2010, what defense is available to a commercial organization charged with failing to prevent bribery by an associated person?

Accepted Answer

Having adequate procedures in place to prevent bribery

Answer

The UK Bribery Act's Section 7 offense of failing to prevent bribery has only one defense: the organization had adequate procedures designed to prevent associated persons from bribing.

Question 5

Which approach is most effective for localizing a global compliance program for operations in countries with high corruption risk?

Accepted Answer

Supplement global policies with country-specific controls and enhanced due diligence requirements

Answer

High-corruption-risk jurisdictions require supplemental controls beyond global minimums, including enhanced third-party due diligence, additional transaction monitoring, and local language training.

(CCCP) Certified Corporate Compliance Professional Practice Test

(CCCP) Certified Corporate Compliance Professional Practice Test

CCCP International Compliance Programs 2