Joanna A van der Vant: How to Reduce Risk
Joanna a. van der Vant reports that Study of Foreign Corrupt Practices Act violations found common weaknesses.
CHICAGO, Illinois – October 30, 2012 – Joanna A. van der Vant, accountant at Sol Property Management, LLC, steers CPAs toward safe practices. A 2011 white paper by a consulting firm did extensive research, analyzing hundreds of cases that fell under the Foreign Corrupt Practices Act (FCPA) in order to determine what got those companies into trouble. Joanna A. van der Vant breaks down those weaknesses in order to help companies stay within the provisions of the act.
The below information, Joanna A. van der Vant explains, was extrapolated from a report that examined 286 FCPA cases. The report was titled “Staying Out of the Headlines: Strategies to Combat Corruption Risk.” After reviewing the report, Joanna A. van der Vant recommends the following actions to help minimize risk.
- Revise your company’s policies. The study found that in more than a third of the cases, the company simply did not have controls in place to adequately measure contract pricing. This measurement is necessary to show that a company is not illegally inflating prices or disguising earnings. A clear policy can help prevent this type of questioning, states Joanna A. van der Vant. Also, as Joanna A. van der Vant advises, a competitive bidding process can help eliminate questions. Businesses should also provide detailed invoicing to show the intention of each payment.
- Maintain written verification of all foreign business transactions. Nothing can set off red flags like foreign business partnerships. Joanna A. van der Vant recommends documenting everything and saving that documentation well into the future.
- Set up a payment approval and disbursement process. All financial transactions should be well documented and tracked. According to Joanna A. van der Vant, this can best be accomplished by setting up an approval process for a business’ transactions that can be extracted and shown if questions should arise. Pay special attention to any commissions or fees, because these can also create audit flags, says Joanna A. van der Vant.
- Attach and maintain documentation for all payments. In some cases, Joanna A. van der Vant has found, businesses shift money around by recording false transactions. Joanna A. van der Vant stresses the importance of attaching documentation for each transaction.
- Set up a clearinghouse for commissions. If your business is allowing commissions to be paid without authorization, Joanna A. van der Vant cautions this could lead to problems. To play it safe, make sure commissions are cleared through an objective party. That third party should be trained in FCPA regulations and educated about the dangers of corruption from within.
According to Joanna A. van der Vant, FCPA will likely not be a concern for most companies. But it is critical to put measures in place to protect in the event of future close scrutiny, notes Joanna A. van der Vant, and ensure that your company stays safe within Foreign Corrupt Practices Act regulations.