Audits Compliance

News & Analysis as of

Real Guidance (Finally) On the Compliance Oversight Role of Boards

New guidance for boards of directors on what it means to have “reasonable oversight” for the implementation and effectiveness of corporate compliance programs could signal the beginning of a global trend towards more—and more...more

Pink Flamingos and the Compliance Audit

The creator of one of the most ubiquitous symbols of mid-century Americana died earlier this week. Don Featherstone, the creator of the pink plastic lawn flamingo, the ultimate symbol of American lawn kitsch, has died. He was...more

EPA Updates Its Audit Policy with "eDisclosure"

On June 10, 2015, the U.S. Environmental Protection Agency hosted a webinar describing a plan to modernize the implementation of its April 11, 2000 Audit Policy. The plan – called eDisclosure – attempts to provide a...more

Subcontracting Plans: How Implementing Best Practices Now Can Save You Headaches Down the Road

As a federal contractor, there are already many areas where you must track your compliance with the rules and regulations carefully. One area increasingly receiving greater scrutiny from the government is prime contractors’...more

OIG Updates 2015 Work Plan: New medicare initiatives for hospitals, DMEPOS suppliers, clinical labs, GPOs

The OIG issued on May 28, 2015 an update to its 2015 Work Plan which includes several new Medicare initiatives for the OIG’s audit and inspection during the current fiscal year and forecasts broader areas of focus for future...more

Levi Strauss and Auditing of Third Parties

Today we celebrate innovation. On this day in 1873, a patent to create work pants reinforced with metal rivets was granted. This marked the birth of one of the world’s most famous garments: the blue jeans. Jacob Davis, a...more

Minimizing Risk Under the Clean Water Act

The Federal Water Pollution Control Act — more commonly known as the Clean Water Act — establishes a stringent regulatory and permitting regime governing the discharge of pollutants into rivers, streams, wetlands, and other...more

Implementing an Effective Third Party “Audit” Program

Explore new approaches to third party audits for a more effective, risk-aligned third party risk management program.    Compliance officers have been insisting on (and should continue to insist on) including third party...more

Evolving Audit Committee Standards for Texas Insurers

Effective January 1, 2010, the National Association of Insurance Commissioners (NAIC) adopted the Annual Financial Reporting Model Regulations (Model Audit Rule), which among other requirements, substantially expanded the...more

The Time is Now for Every Company to Conduct Culture Audits

Companies and CCOs are starting to get the message – the best and most effective control against code and legal violations is a culture of ethics and compliance. Those are high-minded ideals for high-level executives....more

Third Party Audits: Biting the Bullet

The next compliance frontier in anti-corruption enforcement is third-party audits. We have spent the last few years fashioning third-party audit contractual provisions to define when and how such audits can be conducted. ...more

COSO and Internal Controls – Part V

This post concludes my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more

Five Tips for Advancing with Audit Analytics-Part III

Ed. Note-Joe Oringel, Principal at Visual Risk IQ recently wrote a series of blog posts on advancing your business through the use of data analytics and audit. I asked Joe if I could repost his articles, which he graciously...more

Five Tips for Advancing with Audit Analytics, Part I

Ed. Note-Joe Oringel, Principal at Visual Risk IQ recently wrote a series of blog posts on advancing your business through the use of data analytics and audit. I asked Joe if I could repost his articles, which he graciously...more

OIG Defends Its Hospital Compliance Reviews in Response to AHA Criticism

The Office of the Inspector General for the Department of Health and Human Services(“OIG”) responded to concerns expressed by the American Hospital Association (“AHA”) regarding the OIG’s hospital compliance reviews,...more

The OIG Work Plan: Does OIG Always Know Best?

Provider Compliance Departments routinely set audit priorities based, in part, on OIG’s Work Plan, but what should a provider do if it disagrees with a position that the OIG takes? Providers should be prepared to defend their...more

2014 FERC Enforcement Report Emphasizes Internal Compliance Procedures, Self-Reporting, and Importance of Cooperation

The Federal Energy Regulatory Commission’s (FERC) Office of Enforcement (Enforcement) 2014 Report on Enforcement (Report), issued on November 20, 2014, provides an overview of and statistics regarding FERC’s enforcement...more

Changing Regulatory Regime Necessitates New Solutions To An Old Problem: 5 Elements Critical To An Anti-Fraud Compliance Program

US government regulators have become more aggressive in their detection and enforcement of fraud against the government. One of the key tools they are using to combat such fraud is the False Claims Act. Most FCA cases are...more

Trial Lawyering and FCPA Compliance

As most readers of this blog know, I am a recovering trial lawyer. To this day, some of my best friends are still out there, still teeing it up as trial lawyers. They have an important place in our country’s legal system,...more

SEC Sanctions Auditor, Should Make Small Issuers Think Twice

The SEC brought a settled administrative action against an auditor on October 24th. Often I’ll take a case like this and write something about it to warn other auditors (or investment advisers or broker-dealers, or whomever)...more

OIG identifies five major CFPB management challenges

The joint Federal Reserve/CFPB Office of the Inspector General (OIG) recently issued its first listing of “major management challenges” facing the CFPB. These challenges represent what the OIG believes to be “the areas that,...more

SAS 125 Alert: Guidance Regarding Auditor’s Written Communication

In 2011 the AICPA’s Auditing Standards Board published Statement on Auditing Standards (SAS) No. 122, Statements on Auditing Standards: Clarification and Recodification—fondly known as the Super SAS as it was a newly codified...more

The SEC's MCDC Initiative: Where To Go From Here

Issuers, underwriters and advisors in the municipal bond marketplace are facing unprecedented challenges from federal regulators in connection with both the issuance of bonds and ongoing post-issuance compliance. These...more

Governance & Securities Law Focus: Latin America Edition - October 2014

In this issue: - US DEVELOPMENTS - SEC Developments - Noteworthy US Securities Law Litigation - Recent SEC/DOJ Enforcement Matters - EU DEVELOPMENTS - European Commission...more

The Origins of the FCPA - Lessons for Effective Compliance and Enforcement - Conclusion

This is the final part of an occasional series. The entire paper will be published by Securities Regulation Law Journal early next year. Conclusion: The FCPA Today - The FCPA was unique in the world at passage....more

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