The FCPA Report

The definitive source of actionable intelligence covering the Foreign Corrupt Practices Act

Articles By Topic

By Topic: Expense Reports

  • From Vol. 5 No.19 (Sep. 28, 2016)

    Experts from PwC Discuss Compliance Audits and Common Missteps

    Compliance auditing is a critical component of an effective anti-corruption compliance program, recognized both by the U.S. Sentencing Guidelines and the government’s FCPA Resource Guide. A recent Strafford program, “FCPA Compliance Audits: Lessons From Recent Investigations,” discussed regulators’ expectations regarding compliance auditing, the process for scoping and conducting a compliance audit and common audit pitfalls. David A. Wilson, a partner at Thompson Hine, led the discussion, which featured Sulaksh Shah, a partner at PwC, and James Gargas, a director at that firm. This article discusses some of the key takeaways from the program. See also our interview series, “Best Practices for Performing Compliance Program Assessments: Pamela Passman of CREATe.org” (Apr. 6, 2016); “Susan Markel of AlixPartners” (Feb. 24, 2016); and “Jeffrey Kaplan of Kaplan & Walker” (Nov. 4, 2015).

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  • From Vol. 5 No.7 (Apr. 6, 2016)

    Travel and Entertainment Corruption Risks: Internal Controls to Ensure the Program Is Working (Part Three of Three)

    A strong travel and entertainment policy that clearly delineates between an acceptable business expense and an impermissible bribe is critical to keeping a company out of FCPA trouble. But a policy alone is not enough – a company must also have sufficient internal controls in place to ensure that employees understand and follow company policies. In this final installment of The FCPA Report’s three-part series on travel and entertainment expenses, we explore the controls companies should have in place to keep their travel and entertainment programs working effectively. The first article in the series discussed the hallmarks of an appropriate T&E expense and the second looked at T&E policies. See also “Five Stages of Corruption and Myriad Internal Controls Failures: Compliance Takeaways From the VimpelCom Settlement” (Mar. 9, 2016).

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  • From Vol. 5 No.6 (Mar. 23, 2016)

    Travel and Entertainment Corruption Risks: Three Musts for a Strong T&E Policy and Five Ways a Company Can Customize Its Program (Part Two of Three)

    A strong travel and entertainment policy is the bedrock of a compliance program, but a policy that is overly complicated or doesn’t consider business realities may undermine a company’s compliance efforts. In this article, the second in a three-part series on travel and entertainment expenses, we explore three characteristics of a strong T&E compliance policy and five ways companies can customize their policy to their business. The first article in the series outlined five hallmarks of an acceptable T&E expense and the third article will investigate what internal controls a company needs to make sure that its program is functioning properly. See also “How to Build an Anti-Corruption Policy That Allows for Appropriate Business Gifts” (Sep. 19, 2012).

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  • From Vol. 5 No.5 (Mar. 9, 2016)

    Travel and Entertainment Corruption Risks: Five Hallmarks of an Acceptable Hospitality Expenditure (Part One of Three)

    Flying clients to visit factories, putting them up in hotels while they attend meetings and picking up the tab for their dinner can all be regular and acceptable business activities. But when those clients are officials of foreign governments, companies must tread carefully to ensure that genuine business expenses don’t become impermissible bribes. The abuse of travel and entertainment expenses was one of the first areas of focus for the government when it escalated FCPA enforcement over a decade ago and now many companies have established T&E compliance programs. However, as recent settlements involving T&E demonstrate, companies cannot afford to become complacent. This article, the first in a three-part series, sketches in the contours of the boundary between acceptable entertainment and corruption and identifies five hallmarks of appropriate travel and entertainment. Subsequent articles will address what a solid travel and entertainment policy should look like and how companies can actively monitor their T&E programs to prevent fraud and corruption. See also “A Guide to Detecting and Preventing Expense-Reimbursement Fraud (Part One of Three)” (Apr. 16, 2014); Part Two (Apr. 30, 2014); and Part Three (May 14, 2014).

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  • From Vol. 4 No.7 (Apr. 1, 2015)

    Checklist of Issues to Consider When Drafting and Implementing Expense-Reporting Procedures

    Insufficient controls governing the expense-reimbursement process can allow employees to bribe foreign officials without detection.  Employees can and have manipulated expense reports in order to provide improper benefits to government officials in the form of gifts, hospitality and charitable contributions and to generate pools of cash from which employees can pay bribes.  This checklist is designed to assist companies in implementing a risk-based expenditures program which can prevent such fraud.  See also “A Guide to Detecting and Preventing Expense-Reimbursement Fraud (Part One of Three),” The FCPA Report, Vol. 3, No. 8 (Apr. 16, 2014); Part Two; and Part Three.

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  • From Vol. 3 No.10 (May 14, 2014)

    A Guide to Detecting and Preventing Expense-Reimbursement Fraud (Part Three of Three)

    A lack of strong controls around the expense-reimbursement process can allow bribes to foreign officials to slip through the cracks.  To assist companies in designing best-in-class expense-reimbursement programs, The FCPA Report is publishing a three-part article series on the topic.  This, the third article in the series, provides strategies for reviewing expense reports and addressing corruption problems that are discovered.  The first article in this series discussed the risks associated with expense reports; provided advice on using travel and entertainment policies to limit expense-report fraud; and outlined strategies for utilizing the training process to decrease expense-report fraud.  The second article in the series explained how different types of expense limits can protect a company and suggested policies that companies can implement to detect and prevent expense-report fraud.  See also “A Guide to Preventing and Detecting Travel Agency Corruption (Part One of Three),” The FCPA Report, Vol. 3, No. 1 (Jan. 8, 2014), Part Two of Three, Vol. 3, No. 2 (Jan. 22, 2014), Part Three of Three, Vol. 3, No. 3 (Feb. 5, 2014). 

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  • From Vol. 3 No.9 (Apr. 30, 2014)

    A Guide to Detecting and Preventing Expense-Reimbursement Fraud (Part Two of Three)

    The manipulation of expense reports is one way to cover up a bribe, and employees can be creative about evading internal controls.  To assist companies in designing, implementing and maintaining best-in-class expense-reimbursement programs, The FCPA Report is publishing a three-part article series on the topic.  This, the second article in the series, explores how different types of expense limits can protect companies from expense-report fraud and how to implement those limits effectively.  The first article in this series discussed risks associated with expense reports; provided advice on using travel and entertainment policies to limit expense-report fraud; and outlined how to use the training process to decrease expense-report fraud.  The third article in this series will provide strategies for reviewing expense reports and addressing problems discovered during the review process.  See also “A Guide to Preventing and Detecting Travel Agency Corruption (Part One of Three),” The FCPA Report, Vol. 3, No. 1 (Jan. 8, 2014), Part Two of Three, Vol. 3, No. 2 (Jan. 22, 2014), Part Three of Three, Vol. 3, No. 3 (Feb. 5, 2014). 

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  • From Vol. 3 No.8 (Apr. 16, 2014)

    A Guide to Detecting and Preventing Expense-Reimbursement Fraud (Part One of Three)

    Employee expense reports can be prime vehicles for bribery schemes, and failing to maintain adequate controls over such reports can put a company in serious FCPA jeopardy.  Employees can manipulate, and have manipulated, expense reports in order to provide improper benefits to government officials in the form of gifts, hospitality or charitable contributions – or simply to generate pools of cash from which employees can pay bribes.  Implementing a risk-based expenditures program, defining appropriate expense limits and training employees can help to limit a company’s risk.  Such policies “help to set the framework for employees regarding company expectations for compliance and ethical business practices,” said Tara Giunta, a partner at Paul Hastings.  The FCPA Report is publishing a three-part series to help companies identify and prevent expense-report fraud.  The series will provide advice from FCPA experts regarding: spotting expense-report fraud, setting appropriate expense-report policies, monitoring expense reports and addressing anti-corruption issues raised by the monitoring process.  This, the first article in the series, will discuss the risks associated with expense reports; provide advice on using travel and entertainment policies to limit expense-report fraud; and provide strategies for utilizing the training process to decrease expense-report fraud.  See also “Ten Strategies for Avoiding FCPA Violations When Making Charitable Donations,” The FCPA Report, Vol. 1, No. 3 (Jul. 11, 2012).

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