This article will focus on the use of continuous controls monitoring of a FCPA compliance program. While most companies have a Code of Conduct, with attendant implementation policies and procedures in place, training thereon and a hotline; many companies have yet to implement any type of self-audit program to measure FCPA compliance program performance. One of the concepts to emerge out of Sarbanes-Oxley (SOX) is that of continuous controls monitoring for SOX compliance. This author believes that the experiences beginning to come out of continuous controls monitoring programs could portend a powerful tool to assist companies in their ongoing FCPA compliance program.
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