CCT Enforcement and Penalties 5

Question 1

What does 'debarment' mean in the context of federal government contracting enforcement?

Accepted Answer

A prohibition on a company or individual from participating in federal contracts for a specified period

Answer

Debarment excludes a contractor from award of federal contracts and subcontracts, protecting the government from doing business with non-responsible parties.

Question 2

Under the Dodd-Frank Act, what protections are specifically afforded to employees who report potential securities law violations to their employer's internal compliance hotline?

Accepted Answer

Anti-retaliation protections apply even for purely internal reports under certain circuit court interpretations

Answer

Some federal circuits have held that Dodd-Frank anti-retaliation protections extend to employees who report internally, though the Supreme Court's Digital Realty decision narrowed this to external SEC reporters; the landscape remains nuanced.

Question 3

Which enforcement action can the OCC take against a national bank's senior officer for unsafe or unsound banking practices?

Accepted Answer

Removal from office and prohibition from the banking industry

Answer

The OCC has authority under the Federal Deposit Insurance Act to remove officers and directors from their positions and bar them from future participation in the banking industry.

Question 4

What is the 'cooperation credit' in DOJ enforcement, and how does it affect penalty outcomes?

Accepted Answer

A reduction in recommended sanctions for companies that provide substantial assistance in investigating wrongdoing

Answer

Cooperation credit is a reduction in penalties granted to companies that proactively assist the DOJ by providing evidence, making witnesses available, and remediating violations.

Question 5

Under EPA's self-disclosure policy, companies that voluntarily discover and disclose environmental violations may receive what primary enforcement benefit?

Accepted Answer

Penalty reductions of up to 100% for gravity-based penalties

Answer

EPA's Audit Policy allows qualifying companies that self-disclose discovered violations to receive up to 100% reduction in gravity-based civil penalties.

(CCT) Certified Compliance Technician Practice Test

(CCT) Certified Compliance Technician Practice Test

CCT Enforcement and Penalties 5