Remember: it’s a two-fer

Given the subject matter, many of my posts could easily be on a compliance with law site.  But there are nuances.

Take, for example, the Foreign Corrupt Practice Act. You’d think that if you don’t operate in foreign environments or don’t pay bribes, you don’t need to worry.


The point I want to make here is that there are two substantive parts of the law.  The first deals with the offer or payment of anything of value to a foreign official to obtain or retain business.  The second is the books and records provision.  A bribe or offer thereof is a separate and distinct offense from the offense of recording the bribe in your books as “entertainment,” or similar.

“SEC Warning Sinks Avon,”” Wall Street Journal, November 1, 2013 B3  Avon’s stock price drops 20% after company announces Feds are seeking bigger penalties for bribery allegations.

Not mentioned in the article is how Avon accounted for the alleged bribes.  But they have paid more than $340 million in legal “and related costs.”

So, information includes how you chose to characterize an expense in your books.


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Filed under Business Case, Compliance, Content, Controls, Definition, Governance, Information, Internal controls, Legal, Requirements, Risk, Value

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