A Teaching Case Using the Elements of the Foreign Corrupt Practices Act (FCPA)

• In Event: Case Studies in Fraud and Forensic Accounting 1

Abstract

The case presented here is based on a Foreign Corrupt Practices Act (FCPA) violation filed by the SEC in 2014. Coupled with a web research assignment on anti-bribery anti-corruption (ABAC) acts (that is included), the case allows students to apply information gained about ABAC acts. The case has the following learning objectives: 1) Identify and recognize potential violations of the FCPA in the described business activities, 2) Discuss potential liabilities and penalties for any violations identified 3) Develop recommendations for control improvements to improve oversight of the international operations of the company, and 4) Participate in the class discussion of the case. This case was used for two semesters in a graduate-level fraud examination course. Anecdotal feedback was very positive from the students.

Author

• Constance M. Lehmann, University of Houston-Clear Lake