News & Analysis as of

Corruption Internal Audit Functions

Society of Corporate Compliance and Ethics...

[Webinar] ’GOAT’ Compliance Programs - April 12th, 12:00 pm - 1:30 pm CT

Learning Objectives - How to risk rate third parties - How to conduct a third-party audit - Corruption indicators to identify during an audit...more

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

NAVEX

The Compliance Program’s Role in Anti-Fraud Efforts

NAVEX on

Corporate compliance professionals can learn a lot from the audit world. Our latest lesson comes in a statement from the Securities and Exchange Commission, warning auditors to do better at identifying the risk of fraud among...more

The Volkov Law Group

The Herbalife FCPA Settlement: Board Oversight and Internal Audit Failures

The Volkov Law Group on

In the enforcement and compliance arena, there are instances of misconduct that underscore important governance principles. But this just sounds like a bunch of mumbo jumbo (the technical term, I know)....more

The Volkov Law Group

Digging into High-Risk Distributors (Part II of II)

The Volkov Law Group on

Compliance professionals are implementing their own monitoring and auditing strategies.  Internal audit does not have the resources nor the time to assume responsibility for this function.  If possible, internal audit may...more

Wilson Sonsini Goodrich & Rosati

Telefônica Brasil Case Reinforces Risks of Gifts and Hospitality Involving Foreign Officials

On May 9, 2019, Telefônica Brasil agreed to pay a US$4.13 million civil fine to settle U.S. Securities and Exchange Commission charges for violations of the internal accounting controls and recordkeeping provisions of the...more

The Volkov Law Group

Five Signs Your Company Lacks Integrity

The Volkov Law Group on

It is always easy to second-guess or look back with 20-20 hindsight on a compliance breakdown and point out all the problems that were ignored or created by corporate actors. There are common factual scenarios that recur in...more

Thomas Fox - Compliance Evangelist

Stryker FCPA Enforcement Action: Compliance Lessons For Distributors and Dealers – Part II

Over this two-part blog post series, I have been considering the Stryker Corporation 2018 Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

Stryker FCPA Enforcement Action: Compliance Lessons For Distributors and Dealers – Part I

Last month, Stryker Corporation joined a rather ignominious list of recidivists under Foreign Corrupt Practices Act (FCPA) enforcement annuls....more

The Volkov Law Group

What Happens When a CFO Fails to Listen to the CCO?

The Volkov Law Group on

Chief financial officers are powerful players in the corporate governance landscape. CFOs play a critical role in the management and oversight of the company’s internal accounting controls. Sarbanes-Oxley lifted the...more

The Volkov Law Group

Stryker Suffers “Strike Two” and Settles SEC FCPA Case

The Volkov Law Group on

Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.” In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now...more

The Volkov Law Group

The Vital Role of Internal Audit to Compliance

The Volkov Law Group on

A chief compliance officer can only succeed with the support of other important compliance partners. Another way to put it – in the words of Blanche Dubois from A Streetcar Named Desire, “I have always depended on the...more

BCLP

Anti-Corruption Enforcement: Analyzing the Enforcement Approaches of the US, the UK and France

BCLP on

Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

The Volkov Law Group

CCOs and CFOs: Bringing Everyone Together

The Volkov Law Group on

Chief compliance officers are politicians and have to possess great interpersonal skills. They have to “get along” and persuade key constituencies — most especially their business partners – to commit and devote time and...more

Thomas Fox - Compliance Evangelist

Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more

The Volkov Law Group

Bridging the Gap: Uniting Compliance and Financial Controls (Part II of IV)

The Volkov Law Group on

A Chief Compliance Officer has a number of important relationships to attend to in the corporate governance landscape. A critical relationship needed to “operationalize” a compliance program is a partnership between a CCO and...more

The Volkov Law Group

Building a Due Diligence Infrastructure (Part IV of IV)

The Volkov Law Group on

A due diligence infrastructure is designed to demonstrate a company’s good faith commitment to compliance with anti-corruption laws by: identifying corruption risks; and mitigating such risks to ensure that the company does...more

The Volkov Law Group

Cleaning Up a Compliance Program Mess

The Volkov Law Group on

You have just been hired as the new Chief Compliance Officer of a global company operating in over 80 countries, including numerous high-risk corruption countries. You have no staff and have been given a budget to hire 5...more

NAVEX

Ethics & Compliance Training Best Practice FAQs: Top Five Questions from the Training Benchmark Webinar Answered

NAVEX on

During our recent webinar (now available on-demand), we provided an in-depth tour through the findings of our 2015 Ethics & Compliance Training Benchmark Report. Webinar attendees asked a number of valuable questions on...more

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