Internal Controls

News & Analysis as of

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

Focus on China Compliance - Fall 2014

In This Issue: - Between a Rock and a Hard Place: Navigating Disclosures to U.S. Regulators Within the Framework of China’s State Secrets Law - Internal Investigations in China: Collecting and Reviewing Digital...more

What’s Next for COSO’s New Framework?

By now, most companies have begun to transition from The Committee of Sponsoring Organizations of the Treadway Commission (COSO) 1992 Internal Control—Integrated Framework to the updated COSO 2013 framework. In fact, many...more

Wyndham Decision Provides Guidance to Corporate Directors and Officers in Responding to a Data Breach

U.S. District Judge Stanley R. Chesler of the District of New Jersey recently provided much needed guidance to directors and officers on their duties and responsibilities with regard to cybersecurity. In Palkon v. Holmes, et...more

SEC Obtains Over $4 Billion for Securities Violations in 2014

Following the end of its fiscal year on September 30, the Securities and Exchange Commission (SEC) reported that FY 2014 was notable not only for the record number of enforcement actions filed, but for the wide range of...more

25 Ways Manufacturers Can Drive Profitability

Cohen & Company recently hosted “25 Way to Drive Profitability,” a workshop in Youngstown geared specifically toward manufacturers. Beginning with an overview by Rick Schiraldi of the Valley’s manufacturing roots and history,...more

This Week In Securities Litigation

The Commission brought a series of administrative proceedings this week and one civil injunctive action. The civil injunctive action was an insider trading case. The administrative proceedings centered on FCPA violations, the...more

Self-reporting, Extensive Cooperation Yields Reduced Fine In SEC FCPA Action

Layne Christensen, a global water management, construction and drilling company resolved FCPA bribery and books and records and internal controls charges with the SEC. In the Matter of Layne Christensen Company, Adm. Proc....more

Internal Controls Outside the US – Part IV

This post will conclude a short series I have presented on the issue of internal controls outside the US. I want to conclude by raising some ways in which a compliance professional can work to implement internal controls in a...more

The Mummy and Internal Controls in Locations Outside the US – Part III

Today we celebrate Hammer Film’s version of The Mummy. This was the first film that the Hammer studios made under a license agreement with Universal Pictures, the holder of the copyright of its classic monsters from the 1930s...more

The Horror of Dracula and Internal Controls in International Locations, Part I

This Friday we celebrate the second in the Hammer Films horror series, which was actually its first offering, based on Count Dracula, entitled “Horror of Dracula”. It starred the famous Hammer Films horror movie two-some of...more

Assessing the Increased Regulatory Focus on Public Company Internal Control and Reporting

Over the past few months, the Securities and Exchange Commission (‘‘SEC’’) has publicly stated its increasing focus on public company internal controls and related reporting obligations. In February of this year at the...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

The Origins of the FCPA: Lessons For Effective Compliance and Enforcement - Part Five

The Congressional debates - The revelations from the Watergate hearings and the Commission’s investigations and enforcement actions sparked two years of Congressional hearings. Those revelations also spawned a...more

Financial Services Weekly News Roundup - October 2014

Editor’s Note: Spotlight on the Federal Reserve and CSBS 2014 Community Banking Report. On September 24 the Federal Reserve and the Conference of State Bank Supervisors (CSBS) announced the release of their report,...more

This Week In Securities Litigation

The Commission announced its largest whistleblower action this week – an award to a person overseas of over $30 million. The agency also filed a series of actions this week....more

FCPA Compliance and Ethics Report-Episode 94-Internal Controls for Gifts, Travel and Entertainment in a FCPA Compliance Program,... [Video]

In this episode of the FCPA Compliance and Ethics Report I continue my visit with Henry Mixon on internal controls for gifts, travel and entertainment in a best practices FCPA compliance program. ...more

17 Red Flags for Potential International-Sanctions Violations

Recent events in Ukraine and the Middle East have expanded sanctions placed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) against certain foreign financial institutions and individuals. This...more

The Global Anti-Corruption Perspective - Q3 2014

TOP 10 TIPS FOR COUNTERING SMALL BRIBES - The issue of so-called facilitation payment’ and other small bribes is a thorn in the side of many international businesses. Not only is it difficult to do business in many...more

Lessons from GSK in China – Internal Controls, Auditing and Monitoring

One of the questions that GSK will have to face during the next few years of bribery and corruption investigations is how an allegedly massive bribery and corruption scheme occurred in its Chinese operations? The numbers went...more

Barclays Is Sanctioned By The FCA and The SEC

Barclays took a double hit from regulators yesterday. First the Financial Conduct Authority in the UK fined Barclays Bank Plc, about £38 million for putting £16.5 billion of client assets at risk. Then the SEC imposed a $15...more

The Home Depot Data Breach: There’s No Time Like the Present for Cybersecurity

As Home Depot’s recent cybersecurity breach emphasizes, there is no time like the present to institute controls designed to prevent an attack. In the latest data security breach, Home Depot’s servers were broken into,...more

Internal Controls, COSO and FCPA Compliance: Interview with Henry Mixon

Ed. Note-today I continue my interviews of thought leaders in the compliance space. Today I visit with Henry Mixon, a noted internal controls expert. Where did you grow up? I grew up in Birmingham...more

A Reminder of the Importance of Internal Controls Under SOX

On July 30, 2014, the SEC announced charges against the CEO and the former CFO of a computer equipment company based in Florida for misrepresenting the state of the Company’s internal controls over financial reporting and...more

FCPA Compliance and Ethics Report-Episode 91, Internal Controls for Third Parties Under the FCPA, Part II [Video]

In this episode, I continue my exploration of internal controls around third parties in a FCPA compliance program, with Henry Mixon. ...more

81 Results
|
View per page
Page: of 4