31 Days to More Effective Compliance Program - Mapping Internal Controls

Thomas Fox
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As they made clear with several FCPA enforcement actions in 2020, the SEC has continued to emphasize the accounting provisions of the FCPA, specifically the internal controls provisions. Charles Cain, the Chief, FCPA Unit; Division of Enforcement of the SEC, reiterated that the SEC is committed to protecting investors in U.S. public companies and those which list other securities in the U.S., through enforcement of the accounting provisions, including internal controls provisions of the FCPA. The reason is straightforward; a company See more +
As they made clear with several FCPA enforcement actions in 2020, the SEC has continued to emphasize the accounting provisions of the FCPA, specifically the internal controls provisions. Charles Cain, the Chief, FCPA Unit; Division of Enforcement of the SEC, reiterated that the SEC is committed to protecting investors in U.S. public companies and those which list other securities in the U.S., through enforcement of the accounting provisions, including internal controls provisions of the FCPA. The reason is straightforward; a company with rigorous internal compliance controls is better able to prevent, detect and remedy any FCPA violations that may occur.

Three key takeaways:

1. Learn the internal controls your company currently has in place.

2. Map your compliance internal controls to the COSO 2013 Internal Controls Framework.

3. Use your gap analysis as a basis for remediation. See less -

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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