CEA Anti-Corruption & Bribery Prevention 3

Question 1

A third-party due diligence program primarily helps a company manage corruption risk by:

Accepted Answer

Identifying red flags about agents or distributors before engaging them

Answer

Due diligence on third parties helps identify corruption risk factors—such as government connections, reputation issues, or unusual fee requests—before the relationship begins.

Question 2

Which of the following is a recognized 'red flag' when evaluating a potential sales agent in a high-risk country?

Accepted Answer

The agent requests an unusually high commission with no clear business justification

Answer

Requests for unusually high or vaguely justified commissions are a classic red flag indicating potential bribe pass-through to officials.

Question 3

An 'adequate procedures' defense under the UK Bribery Act allows a company to avoid liability for Section 7 offenses if it can show:

Accepted Answer

It had put in place adequate procedures to prevent bribery by associated persons

Answer

Section 7 provides a complete defense only if the organization demonstrates it had adequate procedures designed to prevent the relevant conduct.

Question 4

Which principle in anti-corruption compliance requires that the seriousness of controls be proportionate to the level of risk faced?

Accepted Answer

Risk-based approach

Answer

A risk-based approach calibrates the intensity of anti-corruption controls to the actual corruption risks the organization faces, ensuring resources are allocated effectively.

Question 5

When a company discovers a potential FCPA violation during an internal investigation, which action is generally recommended first?

Accepted Answer

Preserve relevant documents and data to prevent spoliation

Answer

Preserving documents is a critical first step to avoid obstruction-of-justice issues and to ensure the investigation has an accurate factual record.

(CEA) Certified Ethics Associate Practice Test

(CEA) Certified Ethics Associate Practice Test

CEA Anti-Corruption & Bribery Prevention 3