News & Analysis as of

Internal Controls

SEC Charges Firm, CEO and CFO In Corporate Perks Action

by Dorsey & Whitney LLP on

The Commission charged a firm and its former CEO and CFO in actions centered on the improper payment of expenses facilitated by inadequate internal corporate controls. In the Matter of Provectus Biopharmaceuticals, Inc., Adm....more

New Revenue Recognition Standard – The Podcast Series

by Thomas Fox on

In May 2014, 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 entities, and...more

Incorporating AML Compliance Into a Compliance Program (Part III of III)

by Michael Volkov on

Global companies should implement an AML program and KYC practices that follow the general outline for best practices, though it does not need to be as rigorous as a financial institution. For most companies, AML risks can...more

China's State Secret Laws: What To Do When Trade Secrets Collide with State Secrets

by Kobre & Kim on

Multinational companies doing business in China should treat the sensitive information received from their Chinese partners with special care, particularly if the information originates from a state-owned enterprise (SOE)....more

Putting Ethics Back Into Compliance (Part IV of IV)

by Michael Volkov on

My final posting on this week’s ethics series is a call to action for all compliance professionals. Every compliance officer should insist on and embrace a title – “Chief Ethics and Compliance Officer.” Some larger...more

Skilled Nursing Facilities Targeted in Government Enforcement Actions and Qui Tam Lawsuits

by Pepper Hamilton LLP on

Skilled nursing facilities (SNFs) have been the subject of multiple high-profile False Claims Act settlements in recent years, and new pronouncements and pending enforcement actions suggest that SNFs will continue to face...more

GE, Corporate Jets and Compliance

by Thomas Fox on

When do a corporate jets become a compliance issue? That is perhaps one question that is being asked at General Electric (GE) since the revelation came to light that during the tenure of the former Chief Executive Officer...more

COSO Framework: Fraud, Corruption and Compliance (Part I of II)

by Michael Volkov on

Global companies need to actively work to prevent fraud and corruption. Fraud and corruption go hand-in-hand. To commit bribery, bad actors have to gain access to money for unauthorized (illegal) purposes. A failure to...more

CCOs and CFOs: Bringing Everyone Together

by Michael Volkov on

Chief compliance officers are politicians and have to possess great interpersonal skills. They have to “get along” and persuade key constituencies — most especially their business partners – to commit and devote time and...more

Breaking Down Telia: One of the Largest FCPA Settlements and the First of the Trump Administration

The recent settlement by Telia Company AB (“Telia”), the first of the U.S. Department of Justice (“DOJ”) under the Trump administration and one of the largest FCPA enforcement actions to date, has been touted by some as a...more

HR and Compliance: Working Together to Hire Ethical Employees

by Michael Volkov on

Human resources and compliance professionals share many common objectives and interests. They need to coordinate and operationalize their joint interests in a variety of ways....more

It Takes a Village . . . To Commit Bribery

by Michael Volkov on

A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other...more

SFC Highlights Deficiencies in Asset Management Industry

• The SFC has identified nine common areas of non-compliance in managing funds and discretionary accounts. • The SFC urged licensed corporations to review their existing internal control procedures and operational...more

Day 17 of One Month to More Effective Compliance for Business Ventures- Corporate Controller and Business Ventures

by Thomas Fox on

One area not often considered by the CCO as a key part of any compliance regime is the corporate Controller. The Controller generally has the responsibility to accurately record and report the financial transactions of the...more

Strict Liability and Human Rights Due Diligence – too little too early?

by Hogan Lovells on

It was a pleasure to speak in Geneva earlier this month at a consultation hosted by the United Nations Office of the High Commissioner for Human Rights (“OHCHR“) on the scope for making businesses strictly liable for human...more

ISO 37001: The Good, The Bad and the Ugly (Part II of V)

by Michael Volkov on

In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more

After the Storm: Forensic Accounting = Record Reconstruction

by Foodman CPAs & Advisors on

IRS is authorized to grant certain relief that may help Taxpayers and Businesses recover financially from the impact of a disaster when the federal government declares their location to be a major disaster area. IRS could...more

In Defense of Compliance Checklists

by Michael Volkov on

Compliance officers have to avoid complicating a compliance program. As in many areas in life, there is a value in simplicity. Take for example a compliance training presentation. If a compliance officer overwhelms his/her...more

Implementing a Policy Review to Ensure You Are Protected Under The Computer Fraud and Abuse Act, Part 1: Why You Should Conduct a...

by Hinshaw & Culbertson LLP on

One size rarely fits all, especially where technology is concerned. So too is employer coverage under the Computer Fraud and Abuse Act (“CFAA”). Cookie-cutter molds for aspects of your business simply do not work. ...more

Day 6 of One Month to More Effective Internal Controls-Pre-Acquisition Due Diligence

by Thomas Fox on

The compliance component of your mergers and acquisition regime should begin with a preliminary pre-acquisition assessment of risk. Such an early assessment will inform the transaction research and evaluation phases. This...more

The Mummy, Equifax and Dust in the end

by Thomas Fox on

It is the dust in end that Equifax created from its statements over the past week and actions which led to the massive data breach in the first place. The former head of the company, Richard Smith, testified before Congress...more

Comply With the U.S. Treasury’s OFAC Regulations and Avoid Possible Enforcement Action

by Butler Snow LLP on

For a variety of reasons, the United States government prohibits foreign and domestic individuals, groups, companies and other entities from enjoying the benefits of participating in the U.S. economy. ...more

Whatever Happened to the FCPA’s Foreign Conduct Requirement - How the FCPA is Being Used to Police Domestic Conduct and Internal...

As its name implies, the U.S. Foreign Corrupt Practices Act (“FCPA”) was designed to prevent U.S. companies from engaging in foreign bribery. The Department of Justice (“DOJ”) and the Securities Exchange Commission (“SEC”),...more

DOJ And SEC Bring Major FCPA Enforcement Actions Against Swedish Telecom Firm, Imposing One Of Largest FCPA Penalties In History

by Shearman & Sterling LLP on

On September 21, 2017, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced significant enforcement actions against Telia Company AB, a Swedish telecommunications firm, for alleged...more

Ethics and Compliance Controls – Different Means to the Same Objective

by Michael Volkov on

People are getting confused. A company’s ethical culture is not a touchy-feely concept that makes everyone warm and cozy all over. At the same time, compliance controls are not hard and fast rules that are mechanically...more

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