You and your friend Liam are viewing a news report about a national bank executive who was arrested for using company assets to procure real estate assets for himself and an overseas government official-a violation of the Foreign Corrupt Practices Act. The bank is arguing that it followed the Federal Sentencing Guidelines for Organizations by employing an effective compliance and ethics program, so it should receive a light punishment. A bank representative discusses the frequent emails it sends and the once-a-year teleconferences required of all employees. The rep notes that the offending employee attended all teleconferences without fail. Liam says he thinks the bank has made a good case for itself with the Department of Justice. What is your best response?
A) You note that the bank's compliance program may not be all that effective considering employees can merely delete emails or choose to perform other tasks while on a teleconference. You think the bank should receive a harsher punishment.
B) You agree with Liam. The bank has a strong compliance program in place, which the offending employee completed. As a result, the bank should receive a reduced sentence.
C) Even one violation proves a company's compliance program ineffective; therefore, the company should receive a harsh punishment.
D) Since no other bank employees have been arrested, the compliance program is likely effective; therefore, the bank should receive no punishment.
Correct Answer:
Verified
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