Internal Controls

News & Analysis as of

Settlement with Large Firm Audit Partner Reaffirms SEC’s Emphasis on Related Party Disclosures

The SEC’s Division of Enforcement has made a concerted effort in recent months to warn auditors and other corporate “gatekeepers” that it intends to scrutinize the adequacy of related party disclosures in financial filings. ...more

King Arthur Week – The Green Knight and the Protection of Whistleblowers – Part IV

We continue our King Arthur themed week with an exploration of one of the most interesting characters in the Arthur canon, The Green Knight, so called because his skin and clothes are green. The meaning of his greenness has...more

Navex Global's 2015 Ethics and Compliance Hotline Benchmark Report

Experienced ethics officers will tell you that one of the most effective ethics and compliance program measurement tools they have is the data from their internal reporting systems. But how do you put that information into...more

Who Wants to be a Millionaire? Compliance Officer Whistles His Way to a Million Dollar Pay Day

Last week the SEC announced an award of between $1.4 to $1.6 million to a whistleblower who provided information that assisted the SEC in an enforcement action. The enforcement action against the whistleblower’s company...more

SEC Awards Million-Dollar Whistleblower Bounty To Compliance Professional

Last week, the U.S. Securities and Exchange Commission ("Commission" or "SEC") issued an order awarding as much as $1.6 million to a "compliance officer" for information that helped the Commission resolve an enforcement...more

The SEC Doesn’t Love Secret Perks for Executives

If you find yourself as the CEO of a public company, you’ll probably find pluses and minuses. You’ll have to work really hard, but it can be lucrative, too. You can get paid a lot of money. And your company can pay you...more

Cultivating a Culture of Compliance eBook

A strong ethical culture is the foundation of a successful compliance program. It is also among the most difficult program elements to define, establish, and maintain over time. Produced by Compliance Week in cooperation...more

5 Takeaways from the HHS OIG’s Guidance for Health Care Governing Boards

Tuesday, the HHS OIG, in collaboration with the Association of Healthcare Internal Auditors, the American Health Lawyers Association (AHLA), and the Health Care Compliance Association, released a guidance document entitled...more

New Guidance for Health Care Boards

On Monday, April 20th the U.S. Department of Health and Human Services Office of Inspector (HHS OIG) announced new compliance guidance that impacts health care providers across the country....more

New Board Compliance Guidance Prompts General Counsel Focus

Health care general counsel should review, and brief their internal clients on, the new Practical Guidance for Health Care Governing Boards on Compliance Oversight (Guidance), released on April 20, 2015. A joint effort by...more

SEC Looks to Increase Focus on Enforcement of FCPA Accounting Provisions

Government enforcement of the Foreign Corrupt Practices Act (FCPA) typically involves both criminal charges pursued by the Department of Justice (DOJ), and civil charges from the Securities and Exchange Commission (SEC). Last...more

"Facilitation": A New Tool for Extraterritorial Sanctions Enforcement?

Recent OFAC and DOJ actions have focused on certain entities – overseas financial institutions – and particular conduct – US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated...more

FLIR FCPA Action Highlights: Continued Focus on Penalizing Improper Expenditures for Government Officials

FLIR Systems, Inc. (“FLIR”), a publicly traded company based in Oregon, agreed to pay approximately $9.5 million to settle allegations of violations of the Foreign Corrupt Practices Act (“FCPA”) on April 8, 2015. The U.S....more

In re Polycom and the SEC's Continued Focus on Internal Controls

Over the past year, the SEC and other regulatory agencies have initiated an increasing number of investigations into companies based on allegations of inadequate internal controls and/or a system for reporting those controls....more

FCPA Compliance and Ethics Report-Episode 148-Mike Volkov on Criminal Enforcement of the Internal Controls Provisions of the FCPA [Video]

In this episode I visit with Mike Volkov on his recent series on internal controls under the FCPA and his belief that the DOJ may be moving towards criminal enforcement of the internal controls provisions....more

Four Strategies for Helping Employees Deal with Pressure and Stress at Work

How managers can help employees avoid unreasonable workplace pressure, which can lead to unethical behavior. A few of my recent focus groups with employees reminded me of a national survey that examined the sources and...more

SEC Uses Books and Records and Internal Control Regulations to Extend Reach of Actions Beyond Fraud

Last year, we predicted that the SEC would increase its use of administrative proceedings to enforce strict liability violations such as books and records and internal controls. See Mary P. Hansen & William L. Carr, The...more

The Importance of Conflicts of Interest Compliance

A company’s character includes avoiding the appearance of, or actual, conflicts of interest. Compliance professionals need to pay more attention to conflicts of interest. In some instances, companies have not even adopted...more

Rolling Stone’s Rape Story Retraction: Lessons for the Compliance Practitioner

There are only a very few magazine articles that have radically affected me when I read them. Nick Hornby’s account of a group of soccer hooligans, where he chronicled when they traveled to and briefly took over the Italian...more

A Cautionary Tale (or Two) – The Need for Robust Internal Oversight in Financings

In this era of rushed financings and hectic corporate restructurings, internal controls and procedures are more important than ever. Adding litigious shareholders and debtholders to the mix means it’s never been more...more

This Week In Securities Litigation

The Second Circuit rejected a petition for rehearing by the U.S. Attorney’s Office in the Newman case. There the Court reversed and dismissed the insider trading actions against two traders based on the failure of the court...more

SEC Charges Ex-CEO with Concealing Personal Use of Corporate Funds from Investors, Settles with Corporation

Signaling that it is closely scrutinizing the expenses of senior executives and the internal controls of public companies, the Securities and Exchange Commission charged former Polycom CEO Andrew M. Miller this week with...more

Inadequate Internal Controls Cost Tech Firm $750,000

Without admitting or denying the U.S. Securities and Exchange Commission’s findings, Polycom Inc. settled with the agency on Tuesday, March 31, 2015, over alleged insufficient internal controls and disclosure violations for...more

FCPA Books and Records and Internal Controls Enforcement – A Retrospective (Part III of IV)

Plan for the future because that’s where you are going to spend the rest of your life. – Mark Twain. The SEC enforces its books and records and internal controls provisions, most of which involve non-FCPA violations....more

SEC Charges Former CEO, Firm Based On Concealed Perks

The former President and CEO of a public company repeatedly charged personal expenses to the firm largely by falsifying documents and records. Although the executive admitted certain misdeeds to internal investigators...more

165 Results
|
View per page
Page: of 7

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.
×