CCCP International Compliance Programs 3

Question 1

Which element is considered the cornerstone of an effective international third-party due diligence program?

Accepted Answer

Risk-tiered screening calibrated to the third party's country, sector, and access to government officials

Answer

Risk-tiered due diligence allocates investigative resources proportionally, applying enhanced scrutiny to third parties operating in high-risk environments or with significant government interaction.

Question 2

Under the FCPA, which of the following parties qualifies as a 'foreign official' for purposes of the anti-bribery provisions?

Accepted Answer

An employee of a state-owned enterprise in a foreign country

Answer

FCPA defines 'foreign official' broadly to include employees of state-owned enterprises, as these entities are considered instruments of the foreign government.

Question 3

What does the 'books and records' provision of the FCPA require of issuers?

Accepted Answer

Maintaining records that accurately and fairly reflect transactions and dispositions of assets

Answer

The FCPA's books and records provisions require issuers to make and keep books that accurately reflect transactions and to maintain a system of internal accounting controls.

Question 4

A company operating in multiple jurisdictions must navigate conflicting data privacy laws. Which approach best addresses this challenge in an international compliance program?

Accepted Answer

Apply the most restrictive standard as the global baseline while documenting jurisdiction-specific derogations

Answer

Applying the highest applicable standard globally ensures compliance across all jurisdictions while allowing documented exceptions where local law is more permissive.

Question 5

Which international sanctions regime is administered by the U.S. Treasury Department's Office of Foreign Assets Control (OFAC)?

Accepted Answer

U.S. economic and trade sanctions programs targeting specific countries, entities, and individuals

Answer

OFAC administers U.S. economic and trade sanctions programs based on foreign policy and national security goals, targeting countries, regimes, terrorists, drug traffickers, and proliferators.

(CCCP) Certified Corporate Compliance Professional Practice Test

(CCCP) Certified Corporate Compliance Professional Practice Test

CCCP International Compliance Programs 3