Compliance Audits

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
News & Analysis as of

Top Six Frequently Asked Questions About the AODA for Franchisors and Franchisees

In Ontario, the Accessibility Directorate of Ontario has been increasingly active in pursuing enforcement actions against organizations that have not complied with their requirements under the Accessibility for Ontarians with...more

Upcoming Ontario Ministry Of Labour Blitzes

Ontario’s Ministry of Labour has announced several upcoming blitzes during which it will ensure that employers in specified industries are compliant with particular areas of concern under the Employment Standards Act, 2000...more

Employers Must Be Prepared for I-9 and E-Verify Inspections - Immigration and Customs Enforcement (ICE) Inspection of Forms I-9...

Has ICE Been Busy in 2013? What to Expect if You Get a Notice of Inspection - On November 6, 1986, the Immigration Reform and Control Act required employers to verify the identity and employment eligibility of their...more

CMS Identifies Key Priorities for 2014 Compliance Reviews of Qualified Health Plans in the Federally Facilitated Marketplace

At a Centers for Medicare & Medicaid Services ("CMS") teleconference titled "Compliance Reviews in the Federally-Facilitated Marketplace" ("FFM"), which was held on April 10, 2014, CMS representatives discussed the agency's...more

Life Cycle Management Of Third Parties – Step 5 – Management Of The Relationship

Today ends my review of what I believe to be the five steps in the management of a third party under an anti-bribery regime such as the Foreign Corrupt Practices Act (FCPA) or UK Bribery Act. On Monday, I reviewed Step 1 –...more

DHHS Gearing Up to Begin HIPAA Audits of Business Associates

The office of US Department of Health and Human Services Secretary Kathleen Sebelius recentlyannounced plans to perform "pre-audit" HIPAA compliance surveys of 800 Covered Entities and 400 Business Associates. Under the...more

Compliance Audit Information May Not Be Attorney Client Privileged

Attorneys routinely advise clients conducting audits and investigations that the audit or investigation should be conducted by outside counsel in order to establish attorney client privilege. ...more

The Audit's Done, And We Need To Reclassify – Now What?

Let's assume you've done an internal audit, or one required by the Department of Labor, and found – as so many companies do – that certain titles/positions require reclassification from exempt to non-exempt under the Fair...more

HIPAA Audits Set to Begin in 2014: Another Enforcement Mechanism for HIPAA Compliance

The Department of Health and Human Services (HHS) is expected to launch its long-awaited HIPAA audit program sometime in 2014. The audit program will be run by HHS’ Office of Civil Rights (OCR), which is likely eager to get...more

IRS Releases Its “Roadmap” Of The Transfer Pricing Audit Process

The US Internal Revenue Service has released its Transfer Pricing Audit Roadmap, a 26-page outline of the two-year transfer pricing audit process, emphasizing up-front planning and a fact-based approach for examiners. ...more

Mistakes a Plan Sponsor Should Correct Before an IRS/DOL Audit

I have been in the retirement plan business for over 15 years and I have met too many plan sponsors who don’t care that their plan isn’t being run correctly. What makes them eventually care is when they are audited by the...more

The Federalist Papers And A Federated Approach To GRC

Today we celebrate one of America’s greatest political commentaries, The Federalist Papers. They were penned by James Madison, Alexander Hamilton and John Jay. They presented their three views on why the Federal Constitution...more

OCC Releases Guidelines on 'Heightened Expectations' for Large National Banks and Savings Associations

The Office of the Comptroller of the Currency (OCC) recently released proposed amendments to its Part 30 regulations, which reflect the agency's "heightened expectations" for large banks. That release, styled as an "Interim...more

Financial Reporting & Accounting Enforcement Annual Review - 2013

In This Issue: Introduction; Redesigning the SEC’s Division of Enforcement, Again; Focus Areas: What’s Next; Overview of 2013 Cases; Public Company, Officer, and Director Trends; Audit Firm and Auditor Trends; Rule...more

Be Prepared – HIPAA Audits are Coming in 2014

Later this year, the Department of Health and Human Services (“DHHS”) is expected to launch its permanent HIPAA Audit Program. The HIPAA Audit Program is authorized under Section 13411 of the HITECH Act, and is designed to...more

SEC, KPMG and Auditor Independence

The Commission, as part of its retooled enforcement program, is, in part, focusing on gatekeepers such as attorneys and accounts in an effort to achieve omnipresence. This has resulted in a number of proceedings against...more

U.S. Administrative Law Judge Suspends Chinese Affiliates of “Big Four” Accounting Firms

In a surprising turn in the long-running and widely reported dispute between the Securities and Exchange Commission (“SEC”) and the Chinese affiliates of the “Big Four” accounting firms, on January 22, 2014, a U.S....more

New York’s Non-Profit Revitalization Act

The New York Non-Profit Revitalization Act of 2013 (the “Act”) was signed into law December 18, 2013, and the bulk of its provisions will take effect July 1, 2014. As we reported in our previous alert on the subject, the...more

Audit Workplace Policies And Practices To Ensure A Legally Compliant 2014

Auditing internal employment policies and practices helps to identify and resolve areas of legal risk. The types of workplace policies that should be regularly reviewed include: EEO/Harassment; Complaint Reporting Procedures;...more

DOL Seeks Remand Of District Court Case Regarding OFCCP’s Data Gathering Authority

Earlier this week the Department of Labor moved to remand Frito-Lay’s lawsuit seeking to block the production of employment data in connection with an OFCCP investigation into discrimination at its Dallas facility. Frito-Lay,...more

FFIEC Issues Final Guidance on Social Media Usage by Financial Institutions

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) issued final guidance for financial institutions relating to their use of social media (the “Guidance”). With its release, the FFIEC adopts...more

IRS “Wealth Squad” – Something to Keep in Mind During Tax Season

The IRS Global High Wealth Industry (“GHWI”) (part of the IRS Large Business & International Division) is auditing individuals with tens of millions of assets or income who utilize complicated financial and estate plan...more

OMB Publishes Final Uniform Guidance on Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

On December 26, 2013, the Office of Management and Budget (“OMB”) published final guidance in the Federal Register entitled “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”...more

Key Trends, Issues and Best Practices in Compliance 2013

NAVEX Global services the largest ethics and compliance community in the world. This survey is one example of our commitment to identify and communicate key trends and issues critical to business success. This independently...more

Guarantor and Affiliate Financial Statements: Finding a Silver Lining

This week in our playbook, we are talking about guarantor and affiliate financial statements. First, the bad news: As a general rule, all guarantors must present the same audited and unaudited financial statements as...more

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