Internal Controls

News & Analysis as of

The 5 Key Ingredients to a Culture of Ethics

Every company wants to create a culture of ethics. If the senior leadership ignores or downplays a culture of ethics, they have narrowed business opportunities for the company, its shareholders, and other stakeholders. A...more

SEC, Bristol-Myers Settle FCPA Charges

FCPA procedures, internal controls and travel, entertainment and gifts were at the center of the SEC’s latest FCPA action. The action names as a Respondent Bristol-Myers Squibb Company and focuses on its efforts to sell...more

Bristol-Myers Squibb FCPA Enforcement Action

Yesterday, the Securities and Exchange Commission (SEC) announced a Foreign Corrupt Practices Act (FCPA) enforcement action against Bristol-Myers Squibb Company (BMS) for the actions of the company’s joint venture (JV) in...more

SEC Settles FCPA Action With Hitachi

The SEC filed a settled FCPA books and records and internal controls action centered on a firm which used a subsidiary partially owned by a foreign political party to influence the award of government contracts. Specifically,...more

FinCEN Proposes AML Regulations for Investment Advisers

In August 2015, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed regulations that would require investment advisers subject to SEC registration to establish anti-money laundering (AML)...more

SEC Files Settled Financial Fraud Action

Financial fraud actions have traditionally been a staple of SEC Enforcement. During the market crisis, however, the number of those cases waned. Following the formation of a task force focused on financial statement fraud,...more

Cleaning Up a Compliance Program Mess

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

Mintz Levin Health Care Qui Tam Update: Recent Developments & Unsealed Cases - September 2015

Trends & Analysis - Since our last Qui Tam Update, we have identified 39 health-related False Claims Act (“FCA”) qui tam cases that have been unsealed. Of those cases...more

California Attorney General’s Open Data Initiative – The Latest in State and Federal Government Efforts to Harness the Power of...

Early this month, California Attorney General Kamala D. Harris announced a unique data initiative to expand the public’s access to key criminal justice information that has been, to date, largely blocked from public...more

FinCEN Seeks to Add Investment Advisers to BSA/AML Regulation

Why it matters - More than 12 years after initially proposing to extend the Bank Secrecy Act's anti-money laundering compliance programs and recordkeeping and reporting requirements to investment advisers, the Financial...more

SEC Provides Additional Information On Cybersecurity Examinations

On September 15, 2015, the Security and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide additional information on the areas of focus for its second round of...more

SEC to Conduct Second Round of Cybersecurity Examinations

On September 15, 2015, the Office of Compliance Inspections and Examinations (OCIE) of the Securities and Exchange Commission (SEC) issued a Risk Alert announcing its second round of examinations of registered investment...more

The latest challenges in health and safety in the mining industry

We recently attended the Health, Safety, Environment and Community Conference convened by the NSW Minerals Council. The Conference drew together participants from across the mining industry in NSW to look at what miners are...more

Corruption Risks in Brazil: Ensuring Compliance with the FCPA & BCCA

Brazil is one of the hardest places in the world to do business – the World Bank Doing Business Report 2014 ranked Brazil 116 out of 183 for overall “ease of doing business.” In this on-demand webinar, Matteson Ellis of...more

SEC and DOJ Hacking Prosecutions Highlight SEC’s Increased Interest in Cybersecurity Risks

Companies are reminded of the need for strong internal controls. The US Securities and Exchange Commission (SEC) and the Department of Justice (DOJ) recently filed civil and criminal actions in the largest hacking and...more

SEC Charges Four Individuals and Nutrition Company for Failure To Disclose Executive Perks

On September 8, the SEC charged a sports supplements and nutrition company, its former audit committee chairman and three of its current and former executive officers with committing accounting, disclosure and other...more

Leading Casino Settles with FinCEN for $8 Million for BSA Violations

On September 8, FinCEN announced the assessment of an $8 million civil money penalty against a leading U.S.-based casino for its willful violations of the BSA’s requirements to develop and implement a reasonably designed AML...more

FinCEN Announces Caesars Penalty After Multiyear Investigation

This week the Financial Crimes Enforcement Network (FinCEN) announced a Consent Agreement that imposed an $8 million civil penalty against Desert Palace, Inc. d/b/a Caesars Palace. Caesars first disclosed the investigation in...more

OIG audit finds RAD risk assessment inadequate

The HUD Office of Inspector General (the “OIG”) recently released an audit of the front-end assessment (“FERA”) undertaken for the Rental Assistance Demonstration’s (the “Demonstration”) first, or public housing, component. A...more

DOJ Revises the FCPA Resource Guide

In June 2015, the Department of Justice and the Securities and Exchange Commission (SEC) published revisions to their jointly issued A Resource Guide to the U.S. Foreign Corrupt Practices Act. The Resource Guide, initially...more

FinCEN Proposed AML Rule For Investment Advisers

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more

Corporate Investigations & White Collar Defense - September 2015

No Dog Days of August for the SEC—A Recap of a Busy Month - Why it matters: Who says there is a government slowdown in August? Not for the SEC. August 2015 turned out to be very busy indeed for the agency, which...more

FCPA 2015: Enforcement Trends & Predictions

In this webinar, Thomas Fox spoke with Julie Moriarty of The Network about FCPA enforcement trends and made his own predictions for 2015. Topics covered include big-name companies and their respective corporate fines, state...more

Executive Assistant Embezzles $1 Million from Hewlett Packard; as yet, SEC Doesn’t Care

Surely you remember the SEC’s case against Polycom from this spring. In it, the SEC alleged that Polycom CEO Andrew Miller had “created hundreds of false expense reports with bogus business descriptions for his personal use...more

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

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