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explain how the deficient internal accounting system contribute to orthofix fcpa violation acts?also need using following information 15. The internal accounting controls were deficient with

explain how the deficient internal accounting system contribute to orthofix fcpa violation acts?also need using following information

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15. The internal accounting controls were deficient with respect to the setting, approval, and payment of commissions and discounts. Orthofix had no policies or processes in place to standardize or centrally approve and monitor the commissions and discounts that Orthofix Brazil was providing to third parties, which allowed Orthofix Brazil to push through high commissions and discounts that ultimately were used to facilitate improper payments. The decentralized nature of Orthofix's business in Brazil allowed Orthofix Brazil to easily evade the policies and controls that Orthofix did have in place when the conduct occurred. An indirect reporting structure created gaps in supervision that provided the opportunity to orchestrate and execute the bribery schemes without detection. 16. Furthermore, a lack of centralized global accounting and payment controls allowed Orthofix Brazil to record the improper payments as legitimate business expenses. Given the prior corruption and internal controls issues at its Mexican subsidiary, Orthofix was aware of deficiencies in its controls and the FCPA risks at its subsidiaries' operations. Despite these red flags, Orthofix failed to establish better controls and supervision over its subsidiaries in high risk countries.

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