News & Analysis as of

Internal Controls

Day 10 of One Month to More Effective Continuous Improvement-Controls Testing

by Thomas Fox on

Continuous improvement requires that you not only audit and monitor but also that you test your controls. In addition to the language set out in the 2012 FCPA Guidance, two of the seven compliance elements in the US...more

How Do You Define a Compliance Program Failure?

by Michael Volkov on

In our perpetual quest for simplicity, sometimes we fail to understand the complexity of an issue. In the corporate world, if you ask board members and CEOs how they would define a compliance program ”failure,” I am sure...more

COMPLIANCE INTO THE WEEDS-EPISODE 48-THE HALLIBURTON FCPA ENFORCEMENT ACTION

by Thomas Fox on

In this episode, Matt Kelly and I explore last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton...more

Day 22 of One -Lessons in Failures of Internal Controls

by Thomas Fox on

I conclude this one month series by considering the recently concluded Securities and Exchange Commission (SEC) resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company. I...more

Lessons in Failures of Internal Controls

by Thomas Fox on

Last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide...more

Using a Human Rights Lens to Strengthen Your Anti-Corruption Compliance Program

Companies are increasingly expected to manage the human rights impacts of their activities. This expectation is embedded in new legislative requirements, in the requirements of business partners and investors, and in the...more

Goodbye to Rocket J. Squirrel – Halliburton Resolves FCPA Enforcement Action

by Thomas Fox on

June Foray died this week. You may not think you have heard of her but let me assure you; you have heard her. Foray was the voice of Rocket J. Squirrel in perhaps the greatest cartoon show ever, Rocky and Bullwinkle....more

Follow the Money and Beware the Extra “L”: First Department Sustains Claims against Fund Administrator After Hackers Grab Millions

A legal feud is underway between the world’s biggest hedge fund administrator and a former client over an email scam that resulted in hackers stealing millions in client funds. And not surprisingly, the time-honored...more

Anti-Corruption Compliance: The Need to Look Under the Cloak of Materiality

by Michael Volkov on

Sarbanes-Oxley revolutionized the auditing profession. Section 404 imposed stringent requirements for disclosure of the state of a company’s internal controls and financial reporting. The company’s independent auditor is...more

Cybersecurity: When Social Engineering Fraud is Not Covered Under Your Insurance Policy

by Bennett Jones LLP on

We live in an age of escalating cybersecurity threats. Many intrusion threats are social engineering attacks, which seek to gain entry to an organization's computer systems via its personnel and not a hack to the computer...more

Day 15 of One Month to More Effective Internal Controls-COSO’s Objectives and Principles: Control Environment

by Thomas Fox on

The updated Framework retained the core definition of internal controls; those being control environment, risk assessment, control activities, information and communication, and monitoring activities. However, it built up...more

Day 14 of One Month to More Effective Internal Controls-What is COSO?

by Thomas Fox on

This week we turn our attention to COSO, with an introduction to the organization and its framework for internal controls. I will go through the internal controls and how they relate to compliance. Finally, I will end with a...more

Day 13 of One Month to More Effective Internal Controls-Code of Conduct as an Internal Control

by Thomas Fox on

Last year, one of the most interesting non-Foreign Corrupt Practices Act (FCPA) enforcement actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit paid out by United...more

Day 12 of One Month to More Effective Internal Controls-Board Oversight as an Internal Control

by Thomas Fox on

Is a Board of Directors a compliance internal control? I think the clear answer is yes. In the FCPA Guidance, in the Ten Hallmarks of an Effective Compliance Program, there are two specific references to the obligations of a...more

What To Look For In Strong Computer Fraud & Social Engineering Insurance

by GB&A Insurance on

Cyber security has been the talk of the town for quite a while now. Organizations today flooded with statistics and mentions of the importance of proper security measures and cyber liability programs. Some companies...more

New Revenue Recognition Standard – Part VI: What Does Mean?

by Thomas Fox on

Over several blog posts, I have explored in detail the new Financial Accounting Standards Board (FASB) Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), which set forth a new Revenue...more

Day 11 of One Month to More Effective Internal Controls-Internal Controls for Gifts, Travel and Entertainment

by Thomas Fox on

It is reasonable to expect that internal controls over gifts, travel and entertainment (GTE) be designed to ensure that all satisfy the criteria as defined in company policies. Generally speaking, these are fairly narrow,...more

New Revenue Recognition Standard – Part V: Allocation and Revenue Recognition

by Thomas Fox on

I continue to explore the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

Day 9 of One Month to More Effective Internal Controls-Mapping Your Compliance Internal Controls

by Thomas Fox on

As they made clear with several FCPA enforcement actions in 2016, the SEC has placed a renewed interest in the accounting provisions of the FCPA, specifically the internal controls provisions. The BHP enforcement continued...more

Day 8 of One Month to More Effective Internal Controls-What is a Gap Analysis?

by Thomas Fox on

A gap analysis is a method of assessing the differences in performance between a business' internal controls to determine whether business requirements are being met and, if not, what steps should be taken to ensure they are...more

New Revenue Recognition Standard – Part IV: Determining the Transaction Price

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

New Revenue Recognition Standard – Part III: Performance Obligations

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

Day 7 of One Month to More Effective Internal Controls-Implementing Internal Controls

by Thomas Fox on

Today, I consider some ways in which a compliance professional can work to implement internal controls in a multi-national organization. The first step is to convert your company’s compliance risks into internal control...more

New Revenue Recognition Standard – Part II: Contracts

by Thomas Fox on

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

Day 6 of One Month to More Effective Internal Controls-Risk Assessments and Internal Controls

by Thomas Fox on

Next, I will review how to use the risk assessment you have performed as a tool to provide a structured approach to establishing effective internal controls. After preparation of the risk assessment, the next step is to...more

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