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FCPA Regulation

By: Alina Momin
Disclaimer: Some information in this presentation comes from outside sources

Presented by: Alina Momin
Mentor: Rozina Mohammad
Location: Weatherford International
Profession: Senior Accountant
Topic: FCPA Regulation; Anti-Bribery; Anti-Corruption
Class: ISM-Multidisciplinary Spring 2015
Teacher: Mrs. Click

What is ISM?
ISM is a course designed for students wishing to
mentor an adult professional in a chosen career. With the
mentor and the teacher- facilitator, each student will create
a unique plan of study and receive individual instruction.

Course Requirements


Complete an in-depth mentorship in an area of interest

Document a minimum of 2-3 hours of mentorship activities per
Complete a journal entry each week.
Complete an ISM Professional Portfolio showcasing all
assignments completed during the course and the final project.
Complete all of the required assignments.
Complete a Mid Term Presentation.
Develop a product and presentation at the
collegiate/professional level that is presented to a panel of
graders at the conclusion of the semester.
Present a Final Presentation at the end of the semester.

Mentor Information
The University of Texas at Austin
Bachelor of Business Administration (BBA) in Finance
2008 2012
Senior Accountant
Investigations Group
Office of Global Compliance
At Weatherford

Why did I choose this mentorship?

I wanted to try something that was outside of the medical

field because that was what my previous mentorship was.

I am planning on majoring in Business so it would be

helpful to find someone who has been through it.

Project Topic
FCPA Regulation, anti-bribery, and anti-corruption
with a focus on internal controls to prevent the occurrence
of fraud relative to FCPA

What is Weatherford?
Weatherford is one of the largest multinational oilfield
services companies.
Their product and service portfolio spans the life cycle
of the well, and includes capability in drilling and
formation evaluation, well construction, and completion.
The Company provides innovative solutions,
technology, and services to the oil and gas industry, and
operates in over 100 countries.

Accountant Responsibilities

Assist in the identification and evaluation of financial risk

areas by conducting anti-corruption focused compliance
reviews of Weatherford's Global Business Units.

Assist in conducting internal investigations with focus on

matters involving financial integrity issues and other
potential Weatherford Code of Business Conduct

Assist with compliance ad-hoc projects such as Mergers &

Acquisitions and training

What is Fraud Accounting?

Fraud accounting is a deliberate manipulation of
accounting records in order to make a company's financial
performance or condition seem better than it actually is.

What is the FCPA Regulation?

The Foreign Corrupt Practices Act of 1977 was
enacted for the purpose of making it unlawful for certain
classes of persons and entities to make payments to
foreign government officials to assist in obtaining or
retaining business.


An issuer is generally a company (U.S. or foreign) that has a

class of securities

Adomestic concern is any business form with a principal place

of business in the U.S. or organized under U.S. law.

Anything of value could be gifts such as cars, jewelry, etc;

excessive travel and entertainment expenses; educational or
executive training expenses; promises of future employment; shares
or dividends of a company; and many others

Obtain or retain business includes payments to a foreign

official to secure a foreign government contract.

How did FCPA law come into play?

The FCPA was enacted and signed by President Jimmy Carter in December

Law came to place after news and disclosure of questionable foreign

corporate payments

Congressional attention was mostly focused on major oil and gas


FCPA has two major provisions: antibribery provisions,

books/records/internal control provisions

Prohibit the corrupt payment of money or anything of value to a foreign

official in order to obtain or retain business.

Do other countries have FCPA-like laws?

FCPA was the first-ever domestic statute governing the conduct of

domestic companies in its interactions (both direct and indirect) with
foreign officials in foreign markets.

In enacting the FCPA, Congress also instructed the Executive Branch to

seek broad international support for FCPA-like laws in other countries

However, just because a country has a law like the FCPA does not mean
that the law is actively enforced.

Reasons for low enforcement activity can include lack of political will
and prosecutorial resources as well as unique attributes of a countrys

Why is FCPA important?

Applies to:
Employee or agent of a firm
Foreign persons subject to the jurisdiction of the
United States courts

How do the enforcement agencies typically

find out about FCPA issues?

FCPA enforcement actions can originate:

Voluntary disclosures
International law enforcement cooperation
U.S. embassy
Civil society
Media reporting
Sting operations
Competitor complaints or concerns
Whistleblower complaints

Internal Controls: Prevention

Attorney general opinions

Domestic concerns and issuers can contact the Attorney

General for guidance

Internal Controls: Preventions

Compliance programs

Employees understand and will follow corporate policy

Receive regular training on anti-bribery laws

Be informed of the proper contact channels and

procedures for guidance and/or reporting possible FCPA

Tangible Product
For my tangible product I will be making a playbook
on banking because thats also one of the jobs of an

I hope that you learned a lot about what the FCPA
regulation is and learn ways to control fraud from the
With the help of my mentor I have figured out what I
want to major in within business.

I would like to thank my mentor, Rozina Mohammad,
my graders, my parents, and Mrs. Click for giving me the
opportunity to be here today!