Practicum in Forensics

ACCT 564: Practicum in Forensics (S14)(rev. 140405)
This exercise is intended to familiarize you with some of the practical issues encountered in doing business abroad.
Based on our discussion of the FCPA in class, as well as your own research, answer each of the questions below. To
receive credit, you must provide both your answer to the question and a brief discussion of your reasoning for the
answer. Note: This exercise if focused on practical and legal aspects of specific anti-corruption laws and
regulations. It is not concerned with moral implications.
1. Acme is reimbursing the Deputy Minister of Energy of a West African country for his airline
tickets, hotel, and all of his meals while he is in the U.S. visiting Acme’s refinery facilities. The
Deputy Minister also insists on receiving a per diem payment for each day of his trip.
Can you oblige?
2. Continuing from the previous question, what if the Deputy Minister insists that every other
foreign oil company doing business in the country has agreed to pay the per diems?
Does that change your view?
3. The Deputy Minister asks Acme to make a significant charitable contribution to the university
attended by his son. The university, which has a first-rate engineering and natural resources
program, seems like a worthy cause.
Can you oblige?
4. Your company is trying to sell certain equipment to a local power utility in a small African nation
where you are setting up an office. The utility company is 51% owned by the provincial
government. Your sales manager is asked to pay a commission to the COO of the utility.
Your advice is?
5. Same as the previous question, except the utility is only 49% owned by the provincial
Your advice is?
ACCT 564: Practicum in Forensics (S14)(rev. 140405)
6. Acme plans to bid on a large contract to conduct oil exploration in a small Southeast Asian
country. The Minister of Energy suggests that you use a particular representative to help
negotiate the contract. When your project manager suggests using someone else, the Minister
insists that his guy is the only man for the job.
Your advice is?
7. Acme needs to get equipment through customs to ensure the safety of its operations but is told
that in order to expedite this process, it will have to pay the customs agent $100 per order.
Is this okay?
8. Continuing from the previous question, what if Acme is also advised that the process for
approving their drilling program can be expedited if a $1,000 payment is made to the office of
the Minister of Energy?
9. Continuing from the previous question, what if Acme negotiates the amount of the payment
down to $100?
10. Acme signs a contract with a representative in a certain Middle Eastern country for a 2%
commission on a natural gas exploration contract. Several months later, the representative calls
to say he will need more money to “get the job done.” When asked if he is paying bribes he
says, “Of course not, but you know what kind of place this is.”
Your advice is . . . ?

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