News & Analysis as of

Books & Records Compliance Chief Compliance Officers

The Volkov Law Group

The Growing Tension Between Compliance and Financial Controls

The Volkov Law Group on

Compliance professionals are used to internal struggles for influence and resources.  Chief compliance officers have devoted years and years to justifying the need to elevate and empower the compliance function.  For years,...more

Thomas Fox - Compliance Evangelist

Operationalizing Compliance: Part V – Controller’s Office

This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more

The Volkov Law Group

The Revolution in Compliance Training – It is Not Just About Your ABCs

The Volkov Law Group on

A CCO never feels like he or she has caught up on compliance program requirements. As soon as one new best practice is identified, a CCO blinks for a moment and then there is a new best practice for them to consider....more

The Volkov Law Group

Bridging the Gap: Uniting Compliance and Financial Controls (Part II of IV)

The Volkov Law Group on

A Chief Compliance Officer has a number of important relationships to attend to in the corporate governance landscape. A critical relationship needed to “operationalize” a compliance program is a partnership between a CCO and...more

Thomas Fox - Compliance Evangelist

A ‘Most Daring Act’ and the SQM FCPA Enforcement Action – Part I

A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more

Thomas Fox - Compliance Evangelist

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

A&O Shearman

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest - July 2016

A&O Shearman on

Shearman & Sterling’s bi-annual Trends & Patterns report provides insightful analysis of recent enforcement trends and patterns in the US, the UK, and elsewhere as well as helpful guidance on emerging best practices in FCPA...more

Carlton Fields

FCPA: Anti-Bribery Provisions

Carlton Fields on

The Foreign Corrupt Practices Act (FCPA) addresses the problem of international corruption in two ways: (1) the anti-bribery provisions prohibit individuals and businesses from bribing foreign government officials in order to...more

Thomas Fox - Compliance Evangelist

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

The Volkov Law Group

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

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 145-SEC Enforcement of the FCPA, Part II

In this episode which is Part II of my look at SEC enforcement of the FCPA, I consider whether profit disgorgement is available to the SEC in a strict liability enforcement action of violation of internal controls. ...more

The Volkov Law Group

Internal Controls Enforcement (Part I of IV)

The Volkov Law Group on

I was recently inspired by Tom Fox’s excellent writings on the COSO 2013 framework, and his examination of internal controls issues – see here, here, and here. Today, I begin my own series on internal controls but from a...more

Thomas Fox - Compliance Evangelist

Minnie Minoso Broke Barriers; Goodyear Pushes Compliance Forward

Yesterday we celebrated the hard-nosed playing style of Anthony Mason, who recently passed away. Today we honor a true pioneer in professional baseball, Minnie Minoso, or Mr. White Sox. Minoso was the first black Cuban to...more

Dorsey & Whitney LLP

The Origins of the FCPA - Lessons for Effective Compliance and Enforcement - Conclusion

Dorsey & Whitney LLP on

This is the final part of an occasional series. The entire paper will be published by Securities Regulation Law Journal early next year. Conclusion: The FCPA Today - The FCPA was unique in the world at passage....more

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