Questions related to fraud contracts outside US 2143

  • Hi all,
    I am a new member from Hong Kong. I work at a US Company’s HK branch (with office in China) and I suspect (actually with evidences, but not go into details here) there are some fraud contracts being signed in China and were submitted to local Finance Department for booking. Since our corporate policy requires customers in China to settle payment before internally recognizing the sales booking, therefore even we found the contracts are not real and reported to Finance Controller in US Headquarter, they did not do a thing. They said since there are signed contracts in place and payment received, they will accept them.
    My question: if there are suspicious sales transactions from overseas branch, but mother company in US does not take any action to investigate the case, is it a violation of the Sarbanes Oxley Act? I think it is the management’s responsibility to control internal booking process and it is a matter of ‘code of ethics’ by individual employee (in this case the Sales Reprentative). Am I correct?
    Please kindly advise and suggest how I should address this to US HQ related to this.
    Many thanks.

  • I think this would actually be a violation of the Foreign Corrupt Practices Act.
    link on the web at

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