ACFCS Financial Crime SpecialistExam CFCS Question # 9 Topic 1 Discussion

ACFCS Financial Crime SpecialistExam CFCS Question # 9 Topic 1 Discussion

CFCS Exam Topic 1 Question 9 Discussion:
Question #: 9
Topic #: 1

Company A a multinational manufacturing corporation, recently acquired a local company in Country Z that has a high level of state involvement in ihe economy and history of corruption Before purchasing the company. Company A hired a major international law firm to conduct a due diligence review and uncover any potential violations of global anti-corruption laws When the review came back free of issues Company A completed its acquisition.

Two years later executives from Company A were conducting their first anti-corruption compliance training with employees from the Country Z office During the training session Company A executives were alerted by Country Z-based employees that the distributors the company uses may be bribing government officials Company A had not conducted a review of distributors in Country Z, and when it began to look into the allegations it found widespread potential Foreign Corrupt Practices Act (FCPA) violations.

Which are two weaknesses in Company A's anti-corruption compliance program? Choose 2 answers


A.

The due diligence review should have been exclusively conducted by local counsel from within Country Z becausetheywould be better versed in the country's culture and laws


B.

Company A failed to reach out directly togovernmentagencies within Country Z to request information on any history of corrupt payments at the company it was acquiring


C.

Company A should have conducted anti-corruption compliance training as soon as possible after acquiring the company in Country Z


D.

Company A did not include its distributors within Country Z when conducting its anti-corruption due diligence and training


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