PETROBRAS AND OTHERS CAUGHT IN THE FCPA BRIAR PATCH

摘要

Bribery and corruptions do appear to be increasing along with increasing FCPA penalties. Some of the so-called cleanest countries are being caught engaging in corrupt practices. Even with more anti-corruption policies and controls, at least one survey found no decrease in unethical behavior. There is the possibility that auditors are not specifically looking for FCPA violations by using the auditing steps and procedures suggested by this article. Even with all the normal safeguards, the tone at the top must match what is on paper as demonstrated by Petrobras and Halliburton.