Anti-Corruption Practices Flashcards
7 cards from real CCEP practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.
Read the first 7 Anti-Corruption Practices flashcards as text
A sales executive claims that a $5,000 dinner for a government minister was 'promotional expenditure.' What compliance concern does this raise?
Answer: The expenditure may constitute an improper benefit to a foreign official under anti-bribery laws
Lavish hospitality for government officials can constitute a corrupt payment under the FCPA and UK Bribery Act even when labeled as promotional expenditure.
Which type of anti-corruption due diligence is typically most critical when acquiring a company operating in a high-risk jurisdiction?
Answer: Pre-acquisition due diligence to identify successor liability risks
Pre-acquisition due diligence is critical because acquirers can inherit FCPA liability for pre-acquisition conduct, making early identification of risks essential to deal structuring.
Under the FCPA, what affirmative defense is available to a company that made payments that are lawful under the written laws of the foreign country?
Answer: The 'local law' defense
The FCPA provides a 'local law' affirmative defense when a payment was lawful under the written laws and regulations of the foreign official's country.
A company's subsidiary in a foreign country engages in bribery without the knowledge of the parent company's executives. Which factor would most likely still expose the parent to FCPA liability?
Answer: The parent failed to implement adequate internal controls over the subsidiary
Failure to implement adequate anti-corruption internal controls over subsidiaries can expose a parent company to FCPA accounting provisions liability, even without direct knowledge of bribery.
What is 'politically exposed person' (PEP) screening primarily used to identify in an anti-corruption compliance program?
Answer: Individuals who hold or have held prominent public positions and their close associates
PEP screening identifies individuals in prominent public roles and their close associates who present elevated corruption risk due to their influence over government decisions.
Which element is required to establish a violation of the FCPA's anti-bribery provisions?
Answer: Corrupt intent to obtain or retain business or a business advantage
The FCPA requires proof of corrupt intent — that the payment was made to obtain or retain business or gain a business advantage — but does not require proof that the official was actually influenced.
When designing anti-corruption training, which approach is considered most effective for high-risk roles?
Answer: Role-specific scenario-based training tailored to the actual risks faced by those employees
Role-specific scenario-based training is most effective because it addresses the specific corruption risks that employees in high-risk positions actually encounter.