Which of the following statements is not true?

a. The Sarbanes-Oxley Act requires CEOs to personally attest to the adequacy of internal controls.

b. The Foreign Corrupt Practices Act predates the Sarbanes-Oxley Act.

c. A CFO can delegate attestation responsibility for internal controls to a lower-level manager under the provisions of Sarbanes-Oxley.

d. Managers who violate the Foreign Corrupt Practices Act are subject to both fines and imprisonment.