Case: You are the chief compliance officer (CCO) of Xerox and have been asked by a business director (BD) to attend a strategy meeting. The business wants to expand into Russia. The BD states that he’s heard of the law called the FCPA. He wants to know what it is and does it impact his efforts to develop business in Russia? He has already made payments to a local government official to secure building permits. The amounts he paid totaled $25,000 and the permits were issued by a government employee. The government employee now demands a higher payment for additional permits. Xerox employees in Russia are excited about the expansion and see bribery as a way of conducting business that is acceptable in Russia
Please make a memo to the BD, Mr. Burns and provide an overview of the following:
1.What is the role of the CCO?
2.What controls or programs should the company implement to reduce these risks?
3.How might the CCO help the expansion in Russia but allow the company to remain compliant with laws and regulations
4.What are the consequences of violating this law?
5.How would an effective compliance officer manage this situation?
6.Could you stop the expansion if you felt the risk was too great?
7.What skills will you need to be effective in this situation?