Anti-Corruption & Bribery Prevention Flashcards
7 cards from real CEA 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 & Bribery Prevention flashcards as text
A third-party due diligence program primarily helps a company manage corruption risk by:
Answer: Identifying red flags about agents or distributors before engaging them
Due diligence on third parties helps identify corruption risk factors—such as government connections, reputation issues, or unusual fee requests—before the relationship begins.
Which of the following is a recognized 'red flag' when evaluating a potential sales agent in a high-risk country?
Answer: The agent requests an unusually high commission with no clear business justification
Requests for unusually high or vaguely justified commissions are a classic red flag indicating potential bribe pass-through to officials.
An 'adequate procedures' defense under the UK Bribery Act allows a company to avoid liability for Section 7 offenses if it can show:
Answer: It had put in place adequate procedures to prevent bribery by associated persons
Section 7 provides a complete defense only if the organization demonstrates it had adequate procedures designed to prevent the relevant conduct.
Which principle in anti-corruption compliance requires that the seriousness of controls be proportionate to the level of risk faced?
Answer: Risk-based approach
A risk-based approach calibrates the intensity of anti-corruption controls to the actual corruption risks the organization faces, ensuring resources are allocated effectively.
When a company discovers a potential FCPA violation during an internal investigation, which action is generally recommended first?
Answer: Preserve relevant documents and data to prevent spoliation
Preserving documents is a critical first step to avoid obstruction-of-justice issues and to ensure the investigation has an accurate factual record.
Which of the following best describes 'books and records' provisions under the FCPA?
Answer: Requirements to maintain accurate financial records that fairly reflect all transactions
The FCPA's books-and-records provisions require issuers to keep accurate books and records that fairly reflect transactions and do not conceal corrupt payments.
A company operating in a country where 'speed money' to customs officials is culturally routine should:
Answer: Prohibit such payments and find compliant alternatives regardless of local norms
Companies subject to the FCPA or UK Bribery Act must prohibit corrupt payments even where locally practiced, as neither law provides a 'local custom' exception.