An organization operating in international markets wants to implement a critical preventive control to mitigate the risk of corrupt payments to foreign public officials. Which of the following controls is most appropriate?
Select an answer to reveal the explanation.
Short Explanation and Infographic
Let me show you how this works in the real world. You have teams operating in overseas markets where bribing public officials is practically local custom. If you don't have a crystal-clear, rock-solid policy that bans these payments and tells your team exactly what they can and cannot do regarding gifts and meals, someone will cross the line. The correct answer is A—you need that policy in place to prevent the fire before it starts. Paying facilitation fees (Option B) is extremely risky under laws like the UK Bribery Act. And relying on third parties without checking them out (Option C) or giving regional managers unchecked spending authority (Option D) is basically handing them a blank check for bribery. Put up a clear policy wall first!
Full explanation below image
Full Explanation
The correct answer is A. Preventive controls are designed to stop compliance violations before they occur. An anti-corruption policy that explicitly prohibits all forms of bribery—direct or indirect—and defines strict guidelines for corporate hospitality, gifts, and entertainment is a foundational preventive control. This policy must be supported by clear thresholds, pre-approval workflows, and regular training. Under laws like the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, having these clear rules and pre-clearance procedures prevents employees from inadvertently or intentionally committing acts of corruption.
Let's analyze why the other options are incorrect: - Option B is incorrect because while the FCPA has a narrow exception for facilitation payments, many national anti-corruption laws (such as the UK Bribery Act and domestic laws in host countries) ban them entirely. Permitting facilitation payments increases bribery risk significantly. - Option C is incorrect because third-party intermediaries are one of the most common vectors for bribery. Outsourcing payments to them without due diligence is a severe compliance failure, not a control. - Option D is incorrect because delegating approvals to regional sales managers without centralized corporate oversight removes critical checks and balances, leading to unchecked corruption risk.
Ultimately, a clear anti-corruption policy combined with regular training and compliance oversight forms the core of an effective anti-bribery framework.