Compliance Perspectives: A New Tool for Applying the COSO ERM Framework to Compliance
Days to a More Effective Compliance Program-Day 22 | Assessing compliance internal controls
Day 19 of One Month to More Effective Internal Controls-COSO Objective V- Monitoring Activities
Day 18 of One Month to More Effective Internal Controls-COSO Objective IV: Information and Communication
Day 17 of One Month to More Effective Internal Controls-COSO Objective III: Control Activities
Day 16 of One Month to More Effective Internal Controls-COSO’s Objectives and Principles-Risk Assessments
Day 14 of One Month to More Effective Internal Controls-What is COSO?
Compliance into the Weeds-Episode 40, COSO ERM Framework Update
FCPA Compliance and Ethics Report-Episode 115-Tom Fox and Matt Kelly on COSO, Bruker Corp, Dallas Airmotive and Alstom
Welcome to Vinson & Elkins’ Securities and ESG Updates. Our aim is to provide insights into notable developments in securities reporting and the environmental, social and governance space over the quarter and, where...more
On March 30, 2023, the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”), an organization comprising five private-sector organizations with the goal of helping companies improve their performance by...more
Under the pressure of institutional investors, environmental groups, employees, consumers and other stakeholders, many companies have sought to demonstrate their bona fides when it comes to ESG through disclosure about their...more
COSO was adopted in 1992 as a framework for basis to design and then test the effectiveness of internal controls. In 2010, it was deemed necessary to update this framework, to provide a more supportable approach when...more
In the age of Coronavirus, it could well be time to assess your internal controls beyond a gap analysis. Consider what COSO says about assessing compliance internal controls. In its Illustrative Guide, COSO laid out its views...more
"NEW GAAP" REVENUE RECOGNITION - In 2014, the U.S. Financial Accounting Standards Board ("FASB") issued new revenue standards under Accounting Standards Codification ("ASC") 606, Revenue from Contracts with Customers...more
This week we turn our attention to COSO, with an introduction to the organization and its framework for internal controls. I will go through the internal controls and how they relate to compliance. Finally, I will end with a...more
The city of Houston has seen a multi-year economic downturn from the drop in the price of oil. Every company in the energy space has been required to dramatically cut its work force, including unfortunately, it compliance...more
As Houston, TX, is the epicenter of Foreign Corrupt Practices Act (FCPA) enforcement, most energy companies in my hometown have mature compliance programs or at least more mature than in other industries, which have not gone...more
One of the most difficult stories of the Bible for me was always that of God and Abraham. But somehow this song explained it for me as it deals with some unusual problems that can be solved out on Highway 61, which is a...more
Ed. Note-today we have a guest post from Jean-Michel Ferat ,CPA, CFF is a Managing Director in the Washington D.C office of the Claro Group around his views on the BHP Billiton enforcement action. Much has been made in...more
This week I will present a series on steps that you can take in your compliance program if you find yourself, your company or your industry in an economic downturn. All of the recommendations I will make are ideas that have...more
I think that a strict liability standard is coming to Foreign Corrupt Practices Act (FCPA) enforcement. A number of factors have caused me to come to this conclusion. While there may well be wide disagreement as to whether...more
In This Issue - White House Releases Proposed Privacy Legislation - Lessons from the Anthem Data Breach - SEC and FINRA Release Results of Industrywide Cybersecurity Examination Sweeps - COSO Releases Report on...more
I have intentionally avoided a Top Five or Top Ten prediction list for Foreign Corrupt Practices Act (FCPA) enforcement going forward from 2014 into 2015. However there is one area of FCPA enforcement, which I think underwent...more
In this episode Compliance Week editor Matt Kelly and I discuss the COSO 2013 Framework implementation and its changes from the prior Framework. We also discuss the recent Bruker Corp & Dallas Airmotive FCPA enforcement...more
By now, most companies have begun to transition from The Committee of Sponsoring Organizations of the Treadway Commission (COSO) 1992 Internal Control—Integrated Framework to the updated COSO 2013 framework. In fact, many...more
Last week, I posted a piece regarding the “squishy” deadline (to borrow the term of art coined by the COSO Chair) for implementation of the new 2013 COSO internal control framework. As you may recall, the original 1992 COSO...more
With the original 1992 COSO internal control framework deemed by COSO to be “superseded” as of December 15, 2014, companies are fast approaching the deadline for adoption of the updated 2013 COSO framework, But is it really a...more
A recent SEC-settled administrative action is another reminder of the SEC’s focus on internal control over financial reporting (ICFR). Although prior SEC ICFR charges have been accompanied with allegations of false financial...more
The Committee of Sponsoring Organizations of the Treadway Commission (COSO) 1992 Internal Control—Integrated Framework has long been recognized as the starting point for designing, implementing and conducting internal...more
When evaluating internal control over financial reporting, Exchange Act Rule 13a-15(c) requires the evaluation to be based on a framework that is “a suitable, recognized control framework that is established by a body or...more
As many of our readers are well aware, SEC reporting companies are required to maintain internal control over financial reporting to ensure accurate financial statements, and to evaluate the effectiveness of the internal...more