CES Professional Ethics & Compliance 2

Question 1

The Foreign Corrupt Practices Act (FCPA) prohibits U.S. companies from bribing foreign government officials primarily to:

Accepted Answer

Obtain or retain business

Answer

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

Question 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:

Accepted Answer

Refuse to comply and report the request to the BIS

Answer

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

Question 3

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

Accepted Answer

A legal payment to speed routine government actions

Answer

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.

Question 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:

Accepted Answer

Report the issue to the EAR Voluntary Self-Disclosure program

Answer

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

Question 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:

Accepted Answer

Refuse and escalate the issue to the board or legal counsel

Answer

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

(CES) Certified Export Specialist Practice Test

(CES) Certified Export Specialist Practice Test

CES Professional Ethics & Compliance 2