How arrived at culpability score

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COMPUSTARTUP, a public company, has been found guilty of defrauding shareholders. The base fine has been computed at a Level 30 offense (See HERE to determine amount). Aggravating factors include information that suggests the Senior Vice President of Accounting knew about the corruption and turned a blind eye. Despite this, it was the CEO -- who had no knowledge of the fraud -- who alerted the SEC and the company, aside from the perpetrators' initial untrue statements to the grand jury, has willingly cooperated. The net worth of the company is approximately $28 million.

Problem 1: Establish the total fine that you recommend using the three-step process under the FSGO.

Problem 2: Show your computations for the fine that you recommend and explain how you arrived at your culpability score.

Problem 3: What if the CEO had been involved, and he or she has already been convicted on SEC fraud before? How would that change your culpability score?

Problem 4: How can companies take proactive steps to minimize culpability scores?

Reference no: EM132678133

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