Instructions and Information The questions below provide you the opportunity to hone your legal skills and evaluate your knowledge of the legal topics covered in this module. Note, the textbook will help you answer these questions yet you may need to also do some research on your own. Review Question for Chapter 13

Sebastian is developing an anti-corruption program for his employer, which is a large multinational fashion corporation, based in the United States. To date, his employer does not have an anti-corruption policy. During his audit of the companys records in furtherance of this project, he discovers that a subsidiary of the company has been paying bribes to government officials in a foreign country to enable the importation of the companys products without the proper paperwork or inspections. Sebastian knows that paying bribes is illegal under the Foreign Corrupt Practices Act (FCPA). Sebastians employer has not been caught yet, and there is no indication that the U.S. Department of Justice knows anything about this activity. Indeed, Sebastian believes that his employer is above suspicion, due to its excellent and long-standing business reputation. However, Sebastian is also aware of another recent case involving a different company, where the United States declined to enforce the FCPA, even though an employee of that company bribed a foreign government official. The reason that the government did not prosecute the case was because the company had established an extensive anti-corruption policy and had cooperated fully with the investigation. What should Sebastian do? His choice is simple, yet difficult: Does he report the illegal activity that he has discovered, even though his company could be prosecuted and face grave consequences resulting from a loss of reputation? Or, should he keep quiet and hope that knowledge of the bribery never surfaces? What are the consequences of each of these paths?