1. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
How corrupt is your
international
business?
FCPA compliance
2. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
The spotlight is on
2010: 50 individuals had been charged
and nearly $2 billion collected from FCPA
2005: 5 individuals and roughly $16.5
million collected 0
1
2
2009 2010
FCPA
$ Billions
• Huge press exposure, both
USA FCPA & UK Bribery Act
• Criminal liability for company
executives
• SEC ‘whistle-blower
incentives
3. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
The real cost of FCPA violations
ITT
$12B total revenues; 40,000 employees
$5B in government contracts; F500
FCPA – China
payments case
DCAA audit $0.5M
Fine $1.7M
Legal Fees $4.0M
Post-case monitoring $1.5M
TOTAL COSTS $7.7M
Estimated Costs
Press reports show a fine of $1.7M but the real cost
to ITT could easily be in excess of $10M
(not including business opportunity cost)
ITT was fined $1.7M for allegedly paying
Chinese officials for the sale of water
pumps. They were accused of paying $200k
in bribes for business worth $4M and after-
tax profits of $1M
4. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
The ProblemHow responsive are you?
Are your investigations
something like this?
Slow, disruptive
& ineffective
Any Investigation ...
• Involves many organizations, languages
• Collection alerts organization (leads to
cover-up)
• Who is key? Who have we missed?
• Time is money – the longer this drags
on, the more it costs
5. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
The ProblemA new paradigm
Faster, smarter, more effective investigations
• Insight into entire company (not just who you think might be involved)
• Non-disruptive (investigate before collection and interviews)
• Provide Case Intelligence within days not weeks
• Prioritize most important investigations
Don’t wait until it’s too late…
• Get ahead
• Periodically review your foreign
business relationships
• Compliance peace of mind
6. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
360 degree Assessments
Multiple Deployments
360 degree Assessments
• Get insight into ‘trouble’ regions
• Non-disruptive (investigate before collection and interviews)
• Assess key business relationships
• Gain compliance ‘peace of mind’
What relationships
do we have in
Country X ?
7. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
How often do we need
these 360 assessments?
Typically 1 or 2 times a year… or as
the business dictates … such as…
• Unbelievable sales growth in Brazil?
• New R&D trials in China?
• New oil exploration contracts
in Nigeria?
• etc
8. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
What is involved?
Fast, comprehensive, effective and non-disruptive
• These are not detailed audits of Financials
• They are not in-country, covert investigations
• They are not reviews of your partnership programs
They are a …
comprehensive review of
how your company
conducts its international
business operations
9. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
Live DemoDemo
10. Copyright © 2011 Catelas Inc. All rights reservedFCPA 360 degree
Thank You
Robert Levey
978 996 2758
robert.levey@catelas.com
www.catelas.com
Editor's Notes KEY POINTSThe first 10 days are critical – define the case strategy with clarity and convictionBy knowing what the case is about and who to collect and investigate EARLY.Case strategy is KEY – dismiss, settle, contest – allocate budget and resources KEY POINTSThe first 10 days are critical – define the case strategy with clarity and convictionBy knowing what the case is about and who to collect and investigate EARLY.Case strategy is KEY – dismiss, settle, contest – allocate budget and resources
