5 Written questions
5 Matching questions
- Compliance Program
- Culpability Score
- a All of the following are aggravating factors of the culpability score, except:
a) the organization willfully obstructed justice.
b) the organization had an effective program to prevent and detect violations of law.
c) the currrent offense violated a judicial order, injunction, or condition of probation.
d) high-level personnel were involved in or tolerated the criminal activity.
- b (FSGO) The calculation of a degree of blame or guilt that is used as a multiplier of up to 4 times the base fine. The culpability score can be adusted according to aggravating or mitigating factors.
- c The SBDC strictly enforces the FCPA. (true/false)
- d All of the following are covered under Title II: Auditor Independance, except:
a) Prohibits specific "nonaudit" services of public accounting firms as violation of auditor independence.
b) requires the external auditor to report to the client's audit committee on specific topics.
c) Requires auditors to disclose all other written communications between management and themselves.
d) requires audit committees to be independent and undertake specified oversight responsibilities.
- e The best way to minimuze your culpability score is to make sure you have some form of program in place that can effectively detect and prevent violations of law - such as a _______ _______.
5 Multiple choice questions
- The introduction of the ______ placed more effective controls over bribing practices and less obvious forms of payment to foreign officials and politicians by American publicly traded companies pursuing internantonal growth.
- Which title required CEOs and CFOs to certify quarterly and annual reports to the SEC?
- It is estimated that Section 404 of SOX has generated auditing fees in the hundreds of millions of dollars. (true/false)
- What is the maximum term of organizational prohibition?
- Responsibilities granted to the Consumer Financial Protection Bureau include the authority to examine and enforce regulation for banks and credit unions with assets over $10 billion; the creation of a new Office of Financial Literacy; the creation of national consumer complaint hotline and the consolidation of all consumer protection responsibilities currently handled by the Office of the Comptroller of the Currency, Office of Thrift Supervision, Federal Deposit Ins. Co (FDIC), Federal Reserve, Nat. Credit Union Admin (NCUA), the Department of Housing and Urban Dev (HUD) and the Fed. Trade Comm. (FTC). (true/false)
5 True/False questions
The Death Penalty → The so-called _____ _____ is where the fine is set high enough to match all the organizations assets - and basically put the organization out of business. This is warranted where the organization was operating primarily for a criminal purpose.
True → The primary purpose of the FCPA was to control bribery and other less obvious forms of payment to foreign officials and politicians by American publicly traded companies as they pursued internantional growth. (True/false)
Aggravating → Factors that can increase the culpability score are called _______ factors
US Federal Sentencing Commision → Established in 1994 by the Comprehensive Crime Control Act, charged with developing uniform sentencing guidelines for offenders convicted of federal crimes.
False → The SEC can enforce criminal penalties of up to $2 million per violation of the FCPA against corporate and business entities. (true/false)