News & Analysis as of

Internal Controls

CEO Leadership – Honesty, Integrity, Listening and Empathy

by Michael Volkov on

At the outset, let me concede that I am not a psychiatrist (although we all feel like one at times with family members and colleagues). My observations on CEO leadership come from my own life experiences, and professional...more

No More Excuses: CCOs Have to Embrace Technology

by Michael Volkov on

It is time for an honesty check – many CCOs do not like change. CCOs, however, need to embrace change as a powerful force. Compliance is an evolutionary process – it is constantly changing. A compliance program has to move...more

Farewell to a Repo Man and Using Laconic Persuasion as a CCO

by Thomas Fox on

The life of a Repo Man is always intense… That was one of the greatest lines from one of the greatest movies from one of the greatest laconic actors of all time. Of course it was Harry Dean Stanton who died over the...more

4 Signs of a Poor Relationship Between a CCO and the Board

by Michael Volkov on

Chief compliance officers have to devote more time to establish and maintain a positive relationship with the corporate board or audit/compliance committee. CCOs have a lot of responsibilities and feel a lot of pressure to...more

Book Review: The Chickenshit Club

by Thomas Fox on

To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more

The COSO ERM Framework

by Thomas Fox on

The COSO Enterprise Risk Management (ERM) Framework was released last week. It provides an excellent structure for compliance practitioners and businesses to think through the entire lifecycle of risk management....more

Dorsey Anti-Corruption Digest - September 2017

by Dorsey & Whitney LLP on

Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

Tales from the Corporate Scandal Crypt: GM, VimpelCom, VW and Wells Fargo

by Michael Volkov on

We are fascinated by corporate scandals. Since the 1980s, the US public has enjoyed unraveling corporate scandals, and vilifying corporate leaders caught in the web of deceit and misconduct. I am sure there are historical...more

Ethics and Compliance Training, What Gets Results?

The following interview is with Dr. Patricia Harned, Chief Executive Officer of the Ethics & Compliance Initiative (ECI). RB: Pat, it’s a pleasure to have you join us today, and thank you for sharing your report “Ethics...more

FDIC Provides Some Statistics on Violations Found During BSA/AML Exams: One Percent of Exams Lead to Formal Enforcement Actions

by Ballard Spahr LLP on

In its Summer 2017 issue of Supervisory Insights, published last week, the Federal Deposit Insurance Corporation (“FDIC”) provides some insight into its examination process and outcomes for Bank Secrecy Act (“BSA”)/Anti-Money...more

Financial Controls and Contract Management Systems

by Michael Volkov on

Compliance officers understand that a company’s greatest risks surround access to and use of money. A CCO has to understand a company’s financial controls, and in a perfect world, should have a seat at the table in the...more

SEC Charges Adviser With Deficient Controls

by Dorsey & Whitney LLP on

The SEC has in the past brought actions against political intelligence firms. One involved compliance procedures and required admissions as part of the settlement....more

Compliance into the Weeds-Episode 51, the PCAOB and Compliance

by Thomas Fox on

In this episode, Matt Kelly and I take a deep dive into the Public Accounting Oversight Board (PCAOB). We consider the role of the PCAOB in both audit standards and internal controls for compliance. What is goodwill, goodwill...more

The Good and the Bad from OCIE’s Cyber Examinations and What Firms Should Do Next

by Dechert LLP on

The Office of Compliance Inspections and Examinations (OCIE) of the U.S. Securities and Exchange Commission (SEC) released a National Examination Program Risk Alert (Risk Alert) on August 7, 2017 regarding observations from...more

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

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