Fraud Management: Risk and Compliance
Discussion #2 – Bribery Law, SOX, and the FCPA

Which practices might put corporations in violation of anti-bribery laws? Has the ambiguity in the FCPA been lifted with the recent release of new guidance (A Resource Guide to the U.S. Foreign Corrupt Practices Act)?

What constitutes a foreign official? How does the FCPA deal with government ownership of a foreign business? Does the guide address an effective compliance program?

Your role in this discussion: After answering the above questions, apply your answers to Wal-Mart’s recently revealed problems in Mexico. Identify what they did wrong? Who got paid off? How does Sarbanes-Oxley apply? What is the downside for false certification?

Your response to the question posted must be approximately 250-500 words. Your response must have a clear, well formulated thesis; development using textual quotes and references; and sentence structure, grammar, punctuation, spelling count. Your response should be insightful, thoughtful, and analytical.