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Vanessa is the Chief Financial Officer for a US company. It is a large multinational company whose annual revenues exceed $5.0B and its shares are
Vanessa is the Chief Financial Officer for a US company. It is a large multinational company whose annual revenues exceed $5.0B and its shares are trade on the New York Stock Exchange. The FCPA accounting and record-keeping provisions clearly apply to the company. A first ever Securities and Exchange audit in the US home office reveals that several payments to unidentified individuals in foreign entities in different countries were lumped together as "Other Miscellaneous Expenses" and stated as $20,000 on one line item with no further explanation. The SEC states this is likely a FCPA violation. What is Vanessa's best response?
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Vanessas best response in this situation would be to take the following steps Cooperate with the SEC Vanessa should fully cooperate with the Securitie...Get Instant Access to Expert-Tailored Solutions
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