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Samuel Johnson was an English writer and the author of…
audit partner resume Resume Body DIRECTOR, INTERNAL AUDIT. Internal audit executive with 20 years of operational, financial, and compliance auditing experience, including 14 years in leadership roles. Proven results establishing, organizing and managing an internal audit department while successfully meeting deadlines, quality standards, budgets and maintaining relationships with senior management. A track record of identifying financial, operational and compliance related control weaknesses and formulating recommendations to improve the johnson wrote periodical in only company's control environment. Questions Hamlet? Strong technical knowledge of the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing and Code of Ethics.
Extensive experience in the residential / commercial real estate, construction, manufacturing, mortgage banking and title industries. Construction Management Company. Samuel Johnson Wrote In Only? Developed the organization's Internal Audit Risk Assessment based on the COSO Internal Control Framework. Designed and implemented the organization's risk-based Internal Audit Plan. Present the audit plan and audit results to ap essay, the AUdit Committee of the Board of Directors. Continually identify activities subject to audit coverage and assess the degree of risk inherent in the activity in conjunction with the samuel johnson in only one newspaper Internal Audit Risk Assessment.
Lead and evaluate Internal Audit staff and resources. Manage federal contracts compliance audits. Questions Hamlet? Advise operations and corporate functions regarding the adequacy of policy, procedures and samuel johnson wrote essays one newspaper appropriate controls. Research technical accounting issues and updates. Perform due diligence reviews on potential acquisitions.
Manage the nursing Internal Audit Department budget. Perform investigations and special projects at the request of senior management and the Audit Committee. Redesigned the samuel johnson wrote in only audit report format and audit rating system. Implemented a post-audit survey of auditees to economic impact analysis, gauge customer satisfaction. Developed a uniform system of electronic workpapers and documentation. Implemented a process of continuous monitoring of audit findings.
Real Estate Developer. Developed the global Internal Audit Risk Assessment for samuel johnson wrote in only one newspaper, the organization. Designed the organization's global Internal Audit Plan. Identified the structure and staffing needs of the Internal Audit Department in order to accomplish the Audit Plan. Created the organization's Internal Audit Department Charter. Educated members of the organization about the role and responsibilities of the Internal Audit function. Developed a system for tracking and scheduling internal audits of the global organization. Created a system of detailed electronic workpapers.
Developed audit programs and executed audits of various domestic and international functions, departments and projects. Reviewed policies and procedures, advised senior management on the effectiveness of internal controls and provided actionable recommendations for improvement. Performed special projects at the request of the Co-CEOs. Presented the annual audit plan and quarterly audit results to questions, the Audit Committee of the Board of samuel johnson periodical in only Directors. Tested key financial controls identified in Sarbanes-Oxley assessments on an on-going basis and ensured that any deficiencies noted were remediated and retested. Assisted in establishing policies and procedures for the auditing activity through the creation of an Internal Audit Charter and Department Handbook.
Coordinated the example of an essay recruitment and hiring of the internal audit staff. Developed the professional capability of the audit staff and project management personnel by conducting on-the-job training, staff meetings and seminars. Directed and supervised the work of audit staff. Reviewed all audit reports prior to issuance providing recommendations for improvement, accuracy and completeness. Maintained effective working relations with executive and operational management through annual meetings with every division president and ancillary business president to review areas of risk and potential concerns.
Developed a systematic process for annual and quarterly audit scheduling based on a company-wide risk assessment and inquiries with senior management ensuring accomplishment of the department's audit plan and complete audit coverage. Collaborated with external consultants to develop risk assessments and audit programs for mortgage banking and golf club audits. Developed a uniform audit grading system based on acceptable tolerable error percentages and risk-based weighting of samuel periodical in only attributes tested. Executed audits of the company's homebuilding operations (including urban high-rise, single family and multi-family residential construction), commercial and land development, divisions, departments and economic impact analysis ancillary businesses (including title company, mortgage banking and golf club operations) to samuel johnson periodical, determine the adequacy of analysis management and samuel johnson periodical essays in only one newspaper accounting controls. KPMG Peat Marwick. Trained to impact analysis, provide comprehensive business risk assessments resulting in an internal audit plan that focused on risk management and identification of profit improvement opportunities.
Conducted opening/closing meetings with auditees and senior management. Prepared reports containing corrective improvement recommendations. Developed and revised various audit programs and audit report format. Johnson Wrote Periodical In Only? Regional public accounting firm. Prepared financial statements and schedules. Ap Essay? Bachelor of Science in Business Administration. Major in Accounting.
Member of johnson wrote periodical in only one newspaper Varsity Football Team. Earned Accreditation in Internal Quality Assessment / Validation of the Internal Audit Activity as established by the Institute of Internal Auditors. Member of the Institute of Internal Auditors. Member of the American Institute of Certified Public Accountants. Member of the Financial Executives Networking Group.
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Samuel Johnson wrote periodical essays in only one …
SAT / ACT Prep Online Guides and Tips. The SAT Essay is scored separately from the rest of the SAT now, thanks to the changes that went into effect in March 2016. While the essay is samuel wrote periodical essays in only one newspaper, now optional (you don't automatically have to take it every time you take the impact analysis a case SAT), some colleges still require students to submit SAT essay scores with their applications. Wrote Essays One Newspaper? Learning how to consistently write a perfect SAT essay will be a huge boost to your application to these schools. In this article, we'll discuss what it takes to get a perfect 8/8/8 on the SAT essay and what you need to do to train yourself to congress resume get this top score. If you’re reading this, we’re assuming that you already have a basic understanding of the SAT essay. Samuel Johnson Wrote Periodical Essays? You know the standard format of how you should write an essay – introduction, evidence paragraph 1, evidence paragraph 2, (optional) evidence paragraph 3, conclusion.
You know that you should state your thesis in nursing, the introduction. All of this will get you a 5/8 as long as you develop your points enough. If you aren’t fully aware of this, take a spin through our 15 SAT Essay tips to raise your essay score. But how do you push your essay to the next level? That’s what this article is about. feature image credit: NEW YORK 1970'S TRAILER PLATE 888-883 by Jerry Woody, used under CC BY-SA 2.0/Cropped from original.
You’ll have to practice this. The perfect SAT essay is like a puzzle that happens to samuel wrote in only one newspaper be in written form – it can be mastered, but to european of scientific research paper do it well and completely every time requires practice with a lot of samuel johnson essays, sample topics. You need to learn the format of an effective essay and how to fill out a complete essay within 50 minutes. What an SAT Essay Score of 8 Means. If you’re already scoring a 5 or above in all three areas on in an argumentative essay practice (or real) SAT essays, you have a shot at completely nailing what the graders want, represented by a score of samuel wrote periodical one newspaper, 8/8/8, with a little practice. But there’s something important to remember in your question for perfection: on the SAT essay, an 8 in all categories is not always achievable. We’ve got good news and european research paper bad news for those of you who are determined to score an 8/8/8 on the SAT essay.
Good News and wrote periodical in only one newspaper Bad News by Mike Licht, used under CC BY 2.0/Cropped from original. Because the whole essay task (reading, analyzing, planning, and writing) must be completed in 50 minutes, getting an 8 in Reading, Analysis, and resume Writing requires some luck. You have to read the article and analyze the way the author builds her/his argument, pick out the in only one newspaper most important components to the argument, find evidence to support your interpretation, and plan out your essay before you can even start writing. A lot depends on how quickly you can come up with a thesis and of scientific relevant support for whatever the prompt happens to be – you might find some articles easier to read and analyze the argumentative structure of than others. You'll need to use precise language to show mastery of English writing. And because essays with perfect scores are almost always at least two pages long, you don't have any time to spare . If you fumble on any one of these aspects, the grader might not give your SAT essay an 8/8/8. Because the essay is samuel johnson wrote periodical, so formulaic, it's always possible to nursing rguhs get a reliable 6 across the board . Sometimes you might find the author's argument to analyze harder than others, or sometimes you might find the article more difficult to get through, but you will always be able to impress them enough to get a 6/6/6. No college worth its salt is going to base your college admissions decision on getting those last two points on samuel johnson periodical essays in only one newspaper an essay you had 50 minutes to write (especially when the essay is optional). Example Of An? The goal, really, is to show that you can write a decent essay in that time, and a 6/6/6 shows that just as well as an samuel essays, 8/8/8 does. But you should aim as high as you can, so keep reading to impact study find out what it really takes to get a perfect score on the SAT essay. The Difference Between a 6 and an 8.
If we asked the College Board what the difference is between a 6 and an 8 SAT essay, they would direct us to their scoring criteria below that describes the difference between the 3 and 4 essays scores in Reading, Analysis, and Writing (a total score of johnson wrote periodical essays, 8 comes from two readers separately giving your essay a 4 in each of those three areas). We’ve marked the differences between the 3 and 4 criteria in bold. The response demonstrates effective comprehension of the source text. The response shows an impact study, understanding of the text’s central idea(s) and johnson wrote essays one newspaper important details. The response is free of substantive errors of fact and an introduction essay interpretation with regard to the text. The response makes appropriate use of samuel wrote essays one newspaper, textual evidence (quotations, paraphrases, or both), demonstrating an understanding of the source text. The response demonstrates thorough comprehension of the source text. The response shows an understanding of the text’s central idea(s) and of most important details and how they interrelate, demonstrating a comprehensive understanding of the text. The response is free of errors of fact or interpretation with regard to argumentative essay the text.
The response makes skillful use of johnson periodical essays in only, textual evidence (quotations, paraphrases, or both), demonstrating a complete understanding of the source text. A 3 essay demonstrates your understanding of the text’s central ideas, while a 4 essay also shows that you know what the details and examples in the text are and how they relate to the central idea . The response offers an european journal of scientific research paper, effective analysis of the source text and demonstrates an understanding of the analytical task. Samuel Periodical In Only One Newspaper? The response competently evaluates the author’s use of evidence, reasoning, and/or stylistic and persuasive elements, and/or feature(s) of the student’s own choosing. The response contains relevant and sufficient support for claim(s) or point(s) made. An Introduction Argumentative? The response focuses primarily on johnson wrote those features of the text that are most relevant to addressing the task. The response offers an insightful analysis of the source text and demonstrates a sophisticated understanding of the analytical task. Hamlet? The response offers a thorough, well-considered evaluation of the author’s use of evidence, reasoning, and/or stylistic and persuasive elements, and/or feature(s) of the essays in only one newspaper student’s own choosing. The response contains relevant, sufficient, and strategically chosen support for claim(s) or point(s) made. The response focuses consistently on those features of the text that are most relevant to addressing the task. The 4 essay delves into the structure of the author’s argument more deeply.
The writer not only states the techniques used in the text, but also thoroughly explains their impact on the reader. These explanations are backed up with evidence from the text that enhances the writer’s discussion of the structure of the text. The response is mostly cohesive and demonstrates effective use and an introduction in an control of language. The response includes a central claim or implicit controlling idea. The response includes an effective introduction and conclusion. The response demonstrates a clear progression of johnson wrote one newspaper, ideas both within paragraphs and throughout the essay. The response has variety in sentence structures. The response demonstrates some precise word choice. The response maintains a formal style and impact analysis a case objective tone. The response shows a good control of the conventions of standard written English and is free of significant errors that detract from the quality of writing. The response is cohesive and demonstrates a highly effective use and command of language.
The response includes a precise central claim. The response includes a skillful introduction and conclusion. The response demonstrates a deliberate and highly effective progression of ideas both within paragraphs and throughout the samuel johnson wrote periodical in only one newspaper essay. The response has a wide variety in sentence structures. Nursing Rguhs? The response demonstrates a consistent use of precise word choice. The response maintains a formal style and objective tone.
The response shows a strong command of the samuel johnson periodical conventions of congress resume, standard written English and is free or virtually free of errors . The 4 essay is written extremely well , whereas the 3 essay is written fairly well. In addition, the 4 essay is samuel johnson wrote periodical essays in only one newspaper, organized in a way that positively influences the european journal of scientific paper impact of the samuel wrote essays writer’s argument, while the 3 is thesis rguhs, just organized clearly. Let’s condense the samuel johnson wrote periodical information above. A perfect 4 essay : is extremely clear is consistent, smooth, and easy to read has few errors is not repetitive in content or language is sufficiently detailed (using evidence from the text) to fully support the writer’s thesis demonstrates that you understand the text and the author’s claim(s) In other words, you need to excel in impact analysis a case, every one of these aspects to wrote one newspaper get a perfect score. Now we’ll look at a sample 8/8/8 SAT essay, and make note of how it fits the criteria above.
The prompt (taken from The Official SAT Study Guide ) for the sample essay is as follows: Write an essay in which you explain how Peter S. Goodman builds an argument to persuade his audience that news organizations should increase the amount of professional foreign news coverage provided to research submission people in periodical, the United States. In your essay, analyze how Goodman uses one or more of the features listed in the box above (or features of your own choice) to european journal paper submission strengthen the logic and persuasiveness of his argument. Be sure that your analysis focuses on the most relevant features of the passage. The passage to which this prompt refers appears on pp. 183-185 of The Official SAT Study Guide (March 2016 Beyond) , or on slightly different pages in later editions.
You'll need the passage to follow along with the samuel wrote periodical essays sample essay below. Here’s the essay. Read it first, and we’ll have annotations below. In the ap essay hamlet article “Foreign News at a Crisis Point,” Peter S. Goodman eloquently argues the ‘point’ that news organizations should increase the amount of professional foreign news coverage provided to samuel johnson in only one newspaper people in the United States. Goodman builds his argument by using facts and evidence, addressing the counterarguments, and couching it all in persuasive and compelling language. Goodman begins the article by bombarding the reader with facts and statistics.
He states that, according to a census conducted by resume bank the American Journalism Review, the samuel wrote essays in only number of full-time foreign news correspondents in the United States dropped from 307 in 2003 to 234 in 2011. Economic A Case? In addition, the AJR survey also discovered that “the space devoted to foreign news [in American papers] had shrunk by 53 percent” in the last 25 years. Beginning the article with all of wrote essays in only, these facts and figures has a couple of strengtheing effects on Goodman’s argument. First, by starting out with hard evidence, Goodman lays the groundwork of his own credibility. He’s not just writing an opinion piece – his opinion is nursing thesis rguhs, backed by johnson wrote essays one newspaper the truth. This will bring the readers onboard and make them more likely to trust everything else he says. Congress Bank? Second, because Goodman presents these facts without much explaining/interpreting, the reader is forced to do the math herself. This engaging of the reader’s mind also ensures that Goodman has the reader’s attention. When the reader does the math to find a drop of 73 full-time foreign news correspondents employed by johnson wrote in only one newspaper US papers in just 8 short years, she will find herself predisposed to agree with Goodman’s call for more professional foreign news reporting.
In addition to nursing employing facts to johnson essays in only one newspaper his argument’s advantage, Goodman also cunningly discusses the counterargument to his position. By writing about how social media and man-on-the-ground reporting has had some positive impact on the state of foreign news reporting, Goodman heads off naysayers at the pass. It would have been very easy for Goodman to elide over the whole issue of citizen reporting, but the resultant one-sided argument would have been much less convincing. Instead, Goodman acknowledges things like “the force of social media during the Arab Spring, as activists convened and economic impact reacted to samuel periodical one newspaper changing circumstances.” As a result, when he partially refutes this counterargument, stating the “unease” many longtime profession correspondents feel over the trend of ‘citizen journalism’ feel, the reader is much more likely to believe him. After all, Goodman acknowledges that social media does have some power. Knowing that Goodman takes the power of social media seriously will make the reader more inclined, in turn, to take Goodman’s concern about the limits of social media seriously. The final piece that helps bolster Goodman’s argument that US news organizations should have more professional foreign correspondents is Goodman’s linguistic + stylistic choices. Goodman uses contrasts to draw the reader deeper into his mindset. By setting up the contrast between professional reporters as “informational filters” that discriminate good from writing argumentative essay, bad and amateur, man-on-the-spot reporters as undiscriminating “funnels,” Goodman forces the reader to samuel in only view the two in opposition and admit that professional filters are to be preferred over funnels that add “speculatio, propaganda, and other white noise” to their reporting.
In addition, Goodman drives the reader along toward agreeing with his conclusion in the penultimate paragraph of the article with the repetition of the phrase “We need.” With every repetition, Goodman hammers even further home the congress resume inescapable rightness of his argument. The use of samuel wrote periodical essays in only one newspaper, “We” more generally through the article serves to make the congress readers feel sympathetic towards Goodman and identify with him. By employing the rhetorical techniques of presenting facts, acknowledging the other side, and samuel periodical essays using persuasive language, Goodman convinces the reader of his claim. Here are our notes on resume what stands out in this essay (general comments are in purple, spelling/grammar errors are highlighted in yellow): Note that not every 8/8/8 essay needs to have exactly the same items in here, nor do you need to argue in exactly the wrote periodical one newspaper same way. But the elements in this essay make it a standout and essay and thesis statement demonstrate clear mastery. And now for the million-dollar question: What Makes This SAT Essay an 8 Rather Than a 6? Maybe you get the theory behind what makes an essay an 8/8/8, but what about in practice?
Read on samuel periodical essays one newspaper to find out what distinguishes this particular SAT essay as a perfect 8 in Reading, Analysis, and Writing. SAT graders are big on clarity, and clarity requires precise language and obvious, sound logic. Writing An Introduction Argumentative? In this essay, vivid language is used effectively and appropriately: Goodman is described as bombarding the samuel essays in only one newspaper reader with facts and figures The writer describes Goodman as arguing his point using not just language but persuasive and bank compelling language : The effect of Goodman’s argument is samuel johnson wrote periodical essays one newspaper, not just that it convinces the reader, but that the reader…will find herself predisposed to agree with Goodman’s call for more professional foreign news reporting. All of this clear and example of an introduction and thesis statement precise language helps support and explain the author's point (just as Goodman’s language supports his point in johnson in only one newspaper, the text!) Effective Analysis and Organization. The writer's clarity extends to her logic as well. Sufficient background is given to make it clear the writer read and example of an statement understood the text. The examples used are clear and logically connected within paragraphs. The writer also makes sure to identify the johnson in only what/why/what of the thesis rguhs author's argumentative devices: What are the in only one newspaper techniques the author used to persuade the resume bank reader of his claim?
Why did the author use them? What effect does their use have on samuel wrote periodical essays the reader? The organization of the essay follows the organization set out in the introduction: the writer first discusses facts and evidence, then the presentation and refutation of a counterargument, then compelling language. Organization in the essay is aided by writing an introduction transitions between all paragraphs, which create a smooth, consistent argument that is easy to follow. The clarity of the argument and the lack of errors remain consistent from johnson essays in only one newspaper, start to finish. The highlighted errors are few and do not detract or distract from the meaning of the essay. An Introduction In An Essay? The wording of the thesis statement in samuel johnson periodical in only, the introduction and the conclusion is of an and thesis, similar but not identical, and the description of how Goodman builds his argument is the same. Dos piezas by samuel wrote periodical essays in only Raul Hernandez Gonzalez, used under CC BY 2.0/Cropped from original. The author uses a variety of words (marked in congress bank, blue) and sentence structures to convey similar ideas in different ways throughout the essay. For instance, social media , man-on-the-ground (or man-on-the-spot ) reporting , citizen journalism , and amateur reporting are all different words and samuel periodical essays in only phrases used to describe the same phenomenon of non-professional foreign news correspondents.
Another example of this can be found in a case study, Paragraph 4. “Knowing that Goodman takes the power of social media seriously will make the reader more inclined…” could easily be the simpler “Goodman takes the power of social media seriously, which makes the reader more likely to agree…” This kind of periodical in only, linguistic flourish can be found in most top-scoring SAT Essays. Note that this usage is effective, and SAT vocab words aren't thrown into the essay haphazardly - it's clear, effective writing like what you might read in nursing rguhs, the New York Times. The essay is samuel wrote in only, long enough to detail 3 complex examples (discussing Goodman’s use of facts and a case study evidence, a counterargument, and vivid language) and include introductory and concluding paragraphs. With the samuel johnson essays updates to the essay rubric, College Board made it explicit that your essay should have an introduction and conclusion. In The Official SAT Study Guide (March 2016 Beyond) , they also make it clear that shorter essays will receive lower Writing scores (because if you don't write more than a couple of paragraphs, there's not enough writing by which essay graders can accurately judge your writing abilities).
But length means nothing if there isn't valuable information filling the space, so long SAT essays also need to ap essay hamlet be detailed—this author uses the space to give lots of samuel johnson periodical in only, context for her examples. Dos and Don’ts for an 8/8/8 SAT Essay. The key for of an essay introduction a perfect score on the SAT essay is to use your time wisely and stay focused on the task. To help you do this, we've compiled tips for things to do (and things to avoid). Writing as much as you can without including repetitive or irrelevant information. Revising the first and last paragraphs (they stand out in readers’ minds). Making sure you have effective transitions for a seamless essay.
Explaining the persuasive effect the author’s argumentative techniques have on the reader. Thinking of “smart-sounding evidence – analysis of how the author used a personal anecdote is just as viable as a discussion of the author’s use of logos and samuel johnson wrote in only one newspaper other rhetorical strategies. Trying to correct every single error – the writing an introduction in an argumentative grammar and the spelling do not have to be perfect to score an 8 in Writing. This doesn't mean that you should just leave sentence fragments all over the place, but it does mean that accidentally leaving off the last letter of a word or making a small subject/verb agreement error won't be the samuel johnson one newspaper end of the european research submission world (or of your perfect SAT essay score). Spend the extra time trying to write more and develop your points. Samuel Wrote Periodical In Only One Newspaper? Adding as many vocabulary words as you can – you do need some stylistic flourishes, as noted above, but you shouldn’t overdo it, or your writing will sound clunky. How to Train to Improve Your SAT Essay Score. As I mentioned above, most anyone can train to reliably get a 6 on all sections of the resume bank essay, and many can move beyond that to consistently get 8/6/6, 6/6/8, or 8/8/8.
Here’s a framework for how to do this: Read through our complete list of SAT essay prompts Memorize a list of persuasive techniques that you can find in most essay prompt articles Start by practicing with extended length time (80 minutes) so you can feel what it takes to get a top-scoring essay. If you’re struggling, you can also split up the different parts of the essay task for practice. Johnson Wrote Periodical Essays? For instance, you can practice reading and analyzing articles separately from writing the hamlet essay. Find a way to grade your essay. Samuel Johnson Periodical One Newspaper? If you can be objective about your writing , you can notice weak spots, especially if you ran out of time but know what to do (and it'll be good practice for analyzing the passage on the essay!). Otherwise, try to get help from an English teacher or a friend who’s a better writer. Start narrowing the time down to 50 minutes to a case mirror the actual test. Looking for a great way to johnson periodical prep? Check out congress resume bank, PrepScholar's online prep program.
It customizes your prep program to johnson wrote periodical your strengths and weaknesses so you get the most effective prep possible. Even better, we give detailed essay feedback from a leading SAT instructor. You'll get point-by-point comments on where you're falling short, and how to impact analysis a case study improve your weak spots to jump up in SAT essay score. Click below to sign up for our 5-day free trial. Have friends who also need help with test prep? Share this article! Laura graduated magna cum laude from Wellesley College with a BA in Music and Psychology, and earned a Master's degree in Composition from the Longy School of Music of Bard College. She scored 99 percentile scores on the SAT and GRE and loves advising students on how to excel in high school. You should definitely follow us on social media. You'll get updates on our latest articles right on your feed.
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The Foreign Corrupt Practices Act: An Overview of the Law and Coverage-Related Issues. By Stacey L. McGraw and Stacey E. Rufe  March 21, 2014. The Foreign Corrupt Practices Act (FCPA) was enacted in 1977 in response to revelations of widespread bribery of foreign officials by U.S. Johnson Wrote Periodical? companies in european paper submission order to win business.  FCPA enforcement actions by the Securities and Exchange Commission (SEC) and the Department of samuel wrote periodical essays in only Justice (DOJ), which share enforcement authority for of an statement, the FCPA, have increased in wrote periodical in only one newspaper recent years. For example, while the SEC’s website lists a total of 15 enforcement actions between 1978 and 2000, it lists 15 enforcement actions in 2011 alone.  The DOJ lists four enforcement actions in all of 2002; four DOJ enforcement actions were announced or filed in January 2014 alone. Ongoing investigations have been reported or disclosed by large companies from ap essay questions, across the spectrum, including large drug manufacturers, computer companies, media firms, and retailers, among others. FCPA investigations and the investigative costs, defense costs, penalties, and fines associated with those investigations can be significant. Samuel In Only One Newspaper? For example, since 2008, Avon Products, Inc. has spent about $340 million in legal and related costs in writing connection with an investigation alleging that Avon violated the FCPA by paying or giving improper gifts to government officials in China and other countries. Samuel Wrote Periodical One Newspaper?  In January 2014, Alcoa World Alumina LLC announced that it had agreed to plead guilty and pay $223 million in writing an introduction in an argumentative essay criminal fines and forfeitures to resolve charges that it paid bribes to a government official in the Kingdom of Bahrain. Alcoa also settled a parallel action by samuel johnson wrote periodical essays one newspaper the SEC in which it paid an additional $161 million in nursing rguhs disgorgement.  Given the increased enforcement of the FCPA and the duration and cost of investigations and related litigation, it is johnson essays in only important that counsel for insurers and insureds are familiar with the writing, law and the insurance coverage issues that may be implicated by FCPA investigations and related litigation. The FCPA contains two main components: the anti-bribery provisions, which prohibit payments to foreign officials to obtain or retain business, and the accounting provisions that require issuers to make and keep accurate books and records and to maintain an adequate system of internal accounting controls. The accounting provisions also prohibit individuals and samuel johnson periodical essays one newspaper, businesses from knowingly falsifying books and records or knowingly failing to implement internal controls.
Persons and european journal research paper submission, entities subject to the FCPA include “domestic concerns,” which are U.S. persons and businesses.  “Issuers,” which are U.S. and foreign public companies listed on U.S. stock exchanges or which are required to file periodic reports with the essays in only one newspaper, SEC, also are subject to the FCPA. Economic Analysis Study?  In addition, certain foreign persons and samuel in only one newspaper, businesses acting while in the territory of the United States may be subject to the FCPA. Nursing Thesis?  As noted above, enforcement authority for the FCPA is johnson wrote one newspaper shared by an introduction in an argumentative essay the SEC and the DOJ. The DOJ has an FCPPA unit within the Criminal Division’s Fraud Section. It has criminal enforcement authority over issuers as well as criminal and civil enforcement authority over domestic concerns for samuel periodical one newspaper, the FCPA’s anti-bribery provisions. The DOJ maintains a website dedicated to the FCPA and enforcement issues and questions. 
The SEC has authority for civil enforcement of the FCPA over issuers and their officers, directors, employees, agents, and stockholders acting on the issuer’s behalf. Economic Impact Study? The SEC has a specialized FCPA unit with attorneys in samuel johnson wrote periodical essays Washington, D.C., and in regional offices. The SEC’s FCPA Unit also maintains a website, which contains links to all SEC enforcement actions involving the FCPA, organized by year.  Other organizations involved in enforcement include the Internal Revenue Service, the Department of Homeland Security, and the Federal Bureau of congress resume Investigation, which has its own dedicated FCPA unit. Generally, the anti-bribery provisions make it unlawful to wrote periodical one newspaper, offer, pay, promise to pay, or authorize payment of money, or to economic analysis a case study, offer, give, or promise to give anything of value to a foreign official in order to obtain or retain business or secure an wrote periodical essays, improper business advantage.  Jurisdiction. The anti-bribery provisions can apply to conduct both inside and outside the United States. When the FCPA originally was enacted, its anti-bribery provisions applied only to european journal research paper submission, U.S. nationals and to U.S. firms and samuel wrote essays in only one newspaper, issuers, which can be U.S. or foreign companies. Congress amended the FCPA in 1998 to expand its scope. The anti-bribery provisions now prohibit any acts taken in furtherance of a foreign bribery scheme that occurs in the United States or uses any means of questions interstate communication, even if the actual communication takes place intrastate.  Under the alternative jurisdiction provisions of the FCPA enacted in 1998, U.S. companies or persons are subject to the anti-bribery provisions even if they act outside the United States and even if no means of interstate commerce is used. Wrote Essays?  Business purpose test.
The FCPA applies only to thesis, payments intended to influence a foreign official to johnson wrote essays in only, use his or her position “in order to rguhs, assist . . . in obtaining or retaining business for or with, or directing business to, any person.”  This “business purpose” test has been broadly interpreted to samuel in only, include bribes made in the course of business or to gain a business advantage. For example, in United States v. Kay , the Fifth Circuit held that. Congress intended for the FCPA to apply broadly to payments intended to assist the payor, either directly or indirectly, in nursing thesis rguhs obtaining or retaining business for some person, and samuel in only one newspaper, that bribes paid to foreign officials to questions, secure illegally reduced customs and tax liability constitute a type of payment that can fall within this broad coverage.  To constitute a violation of the FCPA, a payment must be made “corruptly,”  which means that there must be intent to wrongfully influence the recipient. Thus, a violation may be found even if no bribe is ultimately paid, if the identity of the recipient is not known, or even if the company does not ultimately receive a benefit as a result of the payment. The intent to influence corruptly is sufficient. Johnson? To establish criminal liability of an individual under the anti-bribery provisions, he or she must have acted willfully.  “Willfully” generally means that the person must act with a “bad purpose” or knowledge that the conduct is bank unlawful. Periodical In Only One Newspaper?  The person need not necessarily know that his or her conduct violates the FCPA specifically.  Proof of willfulness is relevant only to violations by individuals; willfulness is not required to establish corporate criminal or civil liability. An improper payment may be anything of value.  This includes not only example introduction and thesis statement cash payments; it may also include travel expenses, entertainment expenses, or expensive gifts. Gifts may also be prohibited, particularly if they are lavish or excessive. Likewise, foreign charitable contributions are not prohibited under the FCPA unless made for the purpose of improperly influencing a foreign official or made without a proper vetting of the foreign charity.
Further, an improper payment need not be made directly to a foreign official; payments to friends or family members of an official may also violate the FCPA, if made in samuel johnson wrote essays order to influence the official.  Who is a foreign official? Under the FCPA, “foreign official” means. any officer or employee of a foreign government or any department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on behalf of any such government or department, agency, or instrumentality thereof, or of a public international organization, or any person acting in an official capacity for or on bank, behalf of any such government or department, agency or instrumentality, or for or on behalf of any such public international organization.  The term “instrumentality” has been construed broadly and may include state-owned companies or other state-controlled entities.  The ownership, control, status, and function will be examined to determine whether an entity is an agency or instrumentality of a foreign government. “Foreign official” includes employees and representatives of “public international organizations.”  These are organizations that are specifically designated by executive order under the International Organizations Immunities Act, 22 U.S.C. § 288.  Currently, this includes organizations such as the World Bank, the samuel johnson periodical in only one newspaper, International Monetary Fund, the World Trade Organization, and the Organization of American States. Payments to essay and thesis, third parties.
The FCPA specifically prohibits improper payments to johnson wrote, foreign officials made through third parties or intermediaries. It prohibits payments to of an essay introduction, “any person, while knowing that all or a portion of johnson wrote such money or thing of value will be offered, given, or promised, directly or indirectly” to a foreign official. Impact Analysis?  Accordingly, liability may not be avoided simply by outsourcing the samuel johnson periodical essays one newspaper, payment of the bribe to a third party. Conduct is considered “knowing” if the person is aware that there is bank a high probability that an illegal payment is going to occur.  Congress intended to impose liability not only on those with actual knowledge but also on those who purposefully avoid actual knowledge“head in the sand” conduct.  Willful blindness to FCPA violations does not protect a company or individual from samuel johnson wrote periodical essays one newspaper, liability under the statute. Affirmative defenses. There are two possible affirmative defenses under the anti-bribery provisions: the “local law” defense and the “reasonable and bona fide business expenditure” defense.  The local law defense is applicable when the resume, company can show that a payment was lawful under the written laws of the foreign country at issue.  The “reasonable and bona fide business expenditure” defense applies if the samuel essays, company can show that the economic impact study, money spent was reasonable, bona fide, and directly related to samuel wrote essays, the performance of a contract, or marketing, promotion, or product demonstration.  In addition to these affirmative defenses, the anti-bribery provisions of the FCPA also contain a narrow exception for “facilitating or expediting payments” made in furtherance of routine governmental action that involves nondiscretionary acts.  Payments made under imminent threat of physical harm do not violate the thesis, FCPA because there is one newspaper no corrupt purpose, but economic coercion is not sufficient to excuse an otherwise improper payment. Questions Hamlet?  This exception, however, is in conflict with many local anticorruption laws.
Statute of limitations. No specific statute of limitations is provided for in the samuel essays in only one newspaper, anti-bribery provisions of the FCPA; therefore, the general five-year limitations period applies to substantive criminal violations of the act.  In cases involving conspiracies, the nursing, government may be able to reach conduct occurring before the five-year limitations period because generally the government need only prove that a single act in furtherance of the conspiracy occurred within the limitations period. The limitations period also may be extended by a tolling agreement, or the wrote in only, government may apply for journal paper submission, an extension of up to samuel johnson, three years in european journal of scientific submission order to obtain evidence from foreign countries.  The five-year limitations period also applies to civil actions for penalties.  However, the SEC may bring actions for in only one newspaper, equitable relief or disgorgement of ill-gotten gains outside the five-year limitations period. Again, the limitations period may be extended by a tolling agreement, and in cases involving foreign individuals, the limitations period is journal of scientific paper tolled for any period during which the individuals are not found within the United States.  The FCPA’s accounting provisions contain two main components. First, the books and records provisions require issuers to wrote essays in only, make and keep records that accurately and fairly reflect an issuer’s transactions and dispositions of assets. Nursing Rguhs?  Books and records provisions are intended to prevent the mischaracterization or concealment of bribes. Second, the FCPA contains provisions regulating internal controls, which require that issuers devise and maintain a system of internal accounting controls sufficient to ensure management’s control, authority, and johnson periodical one newspaper, responsibility over example essay introduction the firm’s assets.  There can be civil liability under the accounting provisions for both companies and individuals. In addition, both individuals and companies can be criminally liable for knowingly failing to comply with the FCPA’s accounting provisions.  However, the FCPA’s accounting provisions apply only to issuers; the accounting provisions do not apply to private companies. Wrote In Only?  Penalties, Sanctions, and economic analysis a case study, Remedies.
Corporations and other business entities are subject to fines of up to $2 million for each knowing violation of the anti-bribery provisions.  Individuals are subject to a fine of up to $100,000 and imprisonment for up to five years for willful violations.  For each willful violation of the accounting provisions, business entities are subject to a fine of johnson wrote in only one newspaper up to $25 million. Individuals are subject to a fine of up to $5 million and imprisonment for questions hamlet, up to 20 years for criminal violations. Johnson Periodical In Only?  Additional fines may be imposed by the courts under the Alternative Fines Act, 18 U.S.C. § 3571 (d). The DOJ may pursue civil actions for anti-bribery violations by domestic concerns and their affiliated persons and by foreign nationals and companies for violations while in the United States. The SEC may pursue civil actions against issuers and their affiliated persons for violations of the congress bank, accounting provisions. A civil penalty of up to $10,000 per violation is available for violations of the anti-bribery provisions (for both entities and individuals).  For violations of the johnson wrote, accounting provisions, the SEC may obtain a civil penalty of up to a certain specified dollar amount dependent on the egregiousness of the violation, or the gross amount of the pecuniary gain to the defendantwhichever is greater.  There also may be collateral consequences resulting from FCPA violations, including suspension or debarment from contracting with the federal government, cross-debarment by multilateral development banks (such as the World Bank), and suspension or revocation of certain export privileges. Insurance Coverage Issues.
Notice. Many, if not most, FCPA investigations originate as internal investigations by the companies. Bank? After an internal investigation is completed, a company may determine that it should “self-report” to the SEC or DOJ, at which point the SEC or DOJ may commence its own investigation. A company conducting an internal investigation should consider when it is appropriate or necessary to samuel wrote one newspaper, give notice to its insurer of a claim or potential claim. Different policies contain different notice requirements, so it is important for an introduction in an argumentative essay, insureds and insurers to essays in only, be familiar with the notice language and requirements of their policies and to proceed accordingly. Claim. Whether a government investigation constitutes a claim and when a claim arises depends on the language in study the specific insurance policy. Some policies define “claim” to samuel johnson wrote essays in only one newspaper, include government investigations, but often only european journal of scientific paper submission if such investigation is commenced by a formal order of investigation, subpoena, or other such formal document.
Because many FCPA investigations begin informally or possibly with self-reporting after an wrote periodical essays in only one newspaper, internal investigation, a claim may not arise until long after a company first becomes aware of possible FCPA violations. Moreover, a company may choose to agree to cooperate with the SEC or DOJ, thus delaying or avoiding a subpoena or other formal compulsory process or procedure that would constitute a claim under the company’s insurance policy. Congress Bank? Under some policies, an FCPA or other government investigation may not constitute a claim under any circumstances. As always, it’s important to be familiar with the particular policy language. Worldwide coverage. FCPA investigations may be followed by or proceed concurrently with investigations in other countries, such as bribery investigations under the United Kingdom’s Bribery Act 2010, which took effect in July 2011. Coverage for such foreign investigations may be available under policies that provide worldwide coverage, if the johnson wrote one newspaper, matter is otherwise covered based on nursing thesis rguhs, the language of the particular policy. Selection of defense counsel. Samuel Essays In Only One Newspaper? Insurance policies that do not contain a duty to defend typically provide that the insured must obtain the bank, insurer’s consent to its selection of samuel johnson wrote periodical one newspaper defense counsel.
Because, as noted above, defense counsel may have been retained long before a claim arises and is tendered to the insurance carrier, there may be issues for insurers and insureds to negotiate with respect to writing an introduction in an argumentative, the choice of defense counsel, the rates charged, and possible coverage of pre-notice or pre-tender defense expenses. Fines and penalties. Samuel Wrote Periodical Essays In Only One Newspaper? The amounts payable for violations of the FCPA are fines and penalties, which typically are not covered by professional liability insurance. However, there may be policies or endorsements available that provide limited coverage for questions hamlet, certain FCPA fines or penalties. In addition, some policies may provide limited coverage for FCPA-related defense costs, even in the absence of coverage for the fines and penalties themselves. Follow-on litigation. As in other governmental investigations, an FCPA enforcement action often will trigger follow-on actions, such as class actions by shareholders alleging securities fraud, derivative actions alleging breach of fiduciary duty and samuel wrote periodical essays, based on the same conduct alleged in the FCPA investigation, or congressional investigations. These types of lawsuits typically are covered by directors’ and officers’ liability policies. Even if these actions ultimately are unsuccessful, they add to example essay introduction and thesis statement, the overall costs of defending an FCPA investigation. Exclusion for intentional acts and imputation. Samuel Periodical? Exclusions barring coverage for intentional, willful, or fraudulent acts may apply to FCPA matters.
Many times, these exclusions require a final adjudication of intentional or fraudulent conduct. However, if such a final adjudication occurs, the insured may be required to reimburse the insurer for an introduction in an, any defense costs advanced on its behalf. However, with respect to the application of exclusions, such as the samuel periodical, exclusions for intentional acts, insurance policies may contain non-imputation clauses providing that the knowledge or conduct of of scientific one insured cannot be imputed to other insureds for purposes of determining whether the exclusion applies. Samuel Johnson? A policy also may provide that only certain persons’ knowledge can be imputed to an insured entity. For example, some policies provide that only the thesis, chief executive officer’s or chief financial officer’s knowledge may be imputed to the company. FCPA investigations and periodical essays in only, enforcement actions are on the rise and, along with parallel shareholder litigation, may lead to increased exposure for both insureds and insurers. Counsel for insureds and insurers should be aware of the related insurance coverage issues as they apply in the context of FCPA enforcement actions and related litigation. Keywords: litigation, insurance, coverage, Foreign Corrupt Practices Act, FCPA, anti-bribery, fines and penalties, exclusions.  Stacey L. Ap Essay? McGraw is a partner in essays the Washington, D.C., office and Stacey E. Rufe is an associate in the Richmond, Virginia, office of Troutman Sanders, LLP, where they both represent insurers in complex coverage disputes and litigation. The views stated in this article are the views of the authors and do not necessarily represent the views of Troutman Sanders, LLP, or its clients.
 The 2012 Resource Guide to the U.S. Foreign Corrupt Practices Act published by the Criminal Division of the U.S. DOJ and the Enforcement Division of the nursing thesis rguhs, SEC is the best source for additional information about the FCPA. See also Mike Koehler, “The Story of the FCPA,” 73(5) Ohio St. L.J. 93238 (2012) (providing history of the drafting and passage of the FCPA).  Serena Ng Anna Prior, “SEC Warning Sinks Avon,” Wall St. J. , Nov. Wrote Periodical Essays In Only One Newspaper? 1, 2013.  “Alcoa to Pay $384 Million to Settle Bribery Charges,” N.Y. Times , Jan.
9, 2014.  See United States v. Kay , 513 F.3d 432, 44748 (5th Cir. 2007) (discussing common-law definitions of “willfully” and level of knowledge required to establish willful violation of the FCPA).  See Kay , 513 F.3d at 448 (holding that defendant need not know the terms of statute and know that he was violating statute in order to have “willfully” violated the an introduction in an argumentative essay, FCPA).  See, e.g. , United States v. Liebo , 923 F.2d 1308, 131112 (8th Cir. 1991) (sufficient evidence existed for jury to conclude that gifts given to official’s cousin were given “corruptly” to “obtain or retain business” in violation of FCPA).  See, e.g. , United States v. Aguilar , 783 F. Supp.
2d 1108 (C.D. Johnson Periodical In Only One Newspaper? Cal. European Journal Submission? 2011) (motion to dismiss denied because electric utility wholly owned by Mexican government may be considered an “instrumentality” of a foreign government within the meaning of samuel johnson periodical essays FCPA). Copyright 2017, American Bar Association. All rights reserved. Congress? This information or any portion thereof may not be copied or disseminated in any form or by any means or downloaded or stored in an electronic database or retrieval system without the express written consent of the American Bar Association. The views expressed in this article are those of the author(s) and do not necessarily reflect the positions or policies of the American Bar Association, the Section of wrote Litigation, this committee, or the employer(s) of the author(s).
A multi-part series in which a group of insurer and policyholder attorneys provide 5 almost-Twitter friendly practical pointers on insurance. Circuit Conflicts in Antitrust Litigation. This practical guide surveys current conflicts among the Circuit Courts of Appeal in antitrust litigation. A Century of congress Legal Ethics: Trial Lawyers and the ABA Canons of Professional Ethics. The ABA Canons of Ethics was adopted in 1908 and samuel essays, created ethical standards for lawyers.