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Professional Ethics & Compliance Flashcards

7 cards from real CES practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.

Read the first 7 Professional Ethics & Compliance flashcards as text
  1. The Foreign Corrupt Practices Act (FCPA) prohibits U.S. companies from bribing foreign government officials primarily to:

    Answer: Obtain or retain business

    The FCPA's anti-bribery provisions prohibit payments to foreign officials for the purpose of obtaining or retaining business.

  2. Under U.S. anti-boycott regulations, a U.S. exporter receiving a letter of credit that requires a certificate stating goods are not of Israeli origin must:

    Answer: Refuse to comply and report the request to the BIS

    U.S. anti-boycott laws require exporters to refuse such conditions and report them to the Bureau of Industry and Security (BIS).

  3. Which of the following best describes a 'facilitation payment' under the FCPA?

    Answer: A legal payment to speed routine government actions

    The FCPA contains a narrow exception for small payments to foreign officials to expedite routine non-discretionary government actions, known as facilitation or 'grease' payments.

  4. An export compliance officer discovers a colleague submitted a Shipper's Export Declaration with an incorrect Schedule B number to reduce the apparent value of a shipment. The most appropriate first action is to:

    Answer: Report the issue to the EAR Voluntary Self-Disclosure program

    Voluntary self-disclosure to BIS can significantly reduce penalties and demonstrates good-faith compliance when an export violation is discovered.

  5. A compliance officer faces pressure from the CEO to approve a shipment to a country under comprehensive OFAC sanctions to avoid losing a major customer. The officer should:

    Answer: Refuse and escalate the issue to the board or legal counsel

    A compliance officer must refuse to approve a sanctions-violating shipment regardless of business pressure and should escalate to appropriate governance levels.

  6. Which act requires U.S. persons to report requests to participate in unsanctioned foreign boycotts, even if they decline to comply?

    Answer: Export Administration Regulations anti-boycott provisions

    The EAR's anti-boycott provisions (Part 760) require U.S. persons to report boycott requests to BIS within a specified timeframe, even when they refuse to comply.

  7. An exporter's sales manager offers a foreign distributor a 'special discount' contingent on the distributor paying a local government official to secure a contract. This arrangement most likely violates:

    Answer: The FCPA, because the exporter knows the funds will bribe an official

    The FCPA prohibits U.S. companies from using intermediaries to pay bribes to foreign officials, making the company liable even if the payment is made through a third party.