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Best Practices Foreign Corrupt Practices Act (FCPA) Internal Controls

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 12th - 13th, Polanco, CDMX, Mexico

Connect with the leading Anti-Corruption experts and discuss the latest compliance strategies at ACI’s Mexico Summit on Anti-Corruption & Compliance Programs. As Mexico’s longest running, premier anti-corruption and...more

Thomas Fox - Compliance Evangelist

Monitoring and Improvement of Internal Controls

What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities that violate the FCPA or some other law such as Sarbanes-Oxley (SOX). Cristina Revelo said she would...more

Thomas Fox - Compliance Evangelist

Internal Controls

What are internal controls? The best definition I have come across is from Jonathan Marks, partner at BDO, who defined internal controls as: An internal control is an action or process of interlocking activities designed to...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

American Conference Institute (ACI)

[Event] 11th Summit on Anti-Corruption Brazil - May 25th - 26th, São Paulo - State of São Paulo, Brazil

Brazil’s Anti-Corruption and Compliance Community Will Gather for Large, 1:1 and Smaller-Group Discussion! As the longest-standing anti-corruption and compliance gathering in Brazil, Summit on Anti-Corruption Brazil is...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Global Compliance Updates - November 2nd - 3rd, 5:55 pm - 8:15 pm GST

Compliance teams looking to stay ahead of the changing landscape need to be up to date on the latest developments. Join us for Global Compliance Updates in collaboration with the DIFC Academy, on 2–3 November 2021. This...more

Thomas Fox - Compliance Evangelist

Prudent discharge of compliance obligations by a Board

What are the obligations of a Board member regarding the Foreign Corrupt Practices Act (FCPA)? Are the obligations of the Compliance Committee under the FCPA at odds with a director’s “prudent discharge of duties to...more

Society of Corporate Compliance and Ethics...

[Event] April Basic Compliance & Ethics Academy - April 27th - 30th, Chicago, IL

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

Thomas Fox - Compliance Evangelist

Taming Complexity in Compliance

One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. ...more

Thomas Fox - Compliance Evangelist

The Competitive (Compliance) Advantage of Data

The Department Of Justice (DOJ) and Securities and Exchange Commission (SEC) have both made it clear that they expect companies to be more robust in their use of data analytics in compliance programs....more

Society of Corporate Compliance and Ethics...

[Event] March Basic Compliance & Ethics Academy - March 2nd - 5th, San Diego, CA

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

Hanzo

[Webinar] Compliance Investigations: Best Practices and Effectiveness Essentials - May 17th, 2:00pm ET

Hanzo on

Compliance teams conduct investigations on a regular basis, which is why having a robust investigation protocol is a must for any best practice program. How do you think through the protocols for this important and frequent...more

Bass, Berry & Sims PLC

OFAC Actions Provide Guidance on Sanctions Compliance Best Practices

• Russian corporations de-listed through significant specific steps agreed to with OFAC • Exporter settles for $7.7 million and agrees to comprehensive compliance measures • OFAC outlines sanctions compliance best...more

Thomas Fox - Compliance Evangelist

Performing Risk Assessments

One cannot really say enough about risk assessments in the context of an anti-corruption program. Since at least 1999, in the Metcalf & Eddy enforcement action, the Department of Justice (DOJ) has said that a risk assessment,...more

Thomas Fox - Compliance Evangelist

New Revenue Recognition Standard – Part IV: Determining the Transaction Price

This week I am exploring the Financial Accounting Standards Board (FASB) issued Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), for public business entities, certain not-for-profit...more

Thomas Fox - Compliance Evangelist

Day 21 of One Month to Better Compliance Through HR-the HR Gap Analysis for Compliance

How can you determine if Human Resources (HR) can meet the needs of a best practices compliance program? One place to start is with a gap analysis to determine what HR has in place that can facilitate your company’s...more

Thomas Fox - Compliance Evangelist

Deep Dive Due Diligence: Part V – Level III Due Diligence as a Board Tool

Today, I conclude my exploration of Level III, deep dive due diligence, by discussing how a this should be considered as a best practices tool by a Board of Directors in a broader sense. I am joined in this exploration by...more

Thomas Fox - Compliance Evangelist

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...more

Thomas Fox - Compliance Evangelist

Volkov on the Evolving Standards for Compliance Programs

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

Thomas Fox - Compliance Evangelist

The Unsinkable Molly Brown – Compliance, Stakeholder Engagement and CSR

Tammy Grimes died earlier this week. For those of you not familiar with that name, you may well know the name of the Broadway musical which catapulted her to fame, The Unsinkable Molly Brown. Grimes garnered a Toni in 1960...more

Thomas Fox - Compliance Evangelist

Embraer FCPA Enforcement Action – Part III

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

Thomas Fox - Compliance Evangelist

Compliance Training, Part I

In a recent Slate article, entitled “Ethics Trainings Are Even Dumber Than You Think”, author L.V. Anderson railed against what she termed box-checking training where companies put on training not to actually train employees...more

Thomas Fox - Compliance Evangelist

Joe Howell on the PCAOB, Audits and Compliance – Part IV

This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more

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