Compliance Tip of the Day: Assessing Internal Controls
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 4 - Control Information and Communication
Compliance Tip of the Day: COSO Objective 3 – Control Activities
Compliance Tip of the Day – COSO Objective 1 – Control Environment
Compliance Tip of the Day: Code of Conduct as an Internal Control
Compliance Tip of the Day: COSO Framework
Compliance Tip of the Day: Internal Controls for GTE
Compliance Tip of the Day: Board Oversight on Internal Controls
Compliance Tip of the Day: Internal Controls for Third Parties
Compliance Tip of the Day: Implementing Internal Controls
Compliance Tip of the Day: Risk Assessments and Internal Controls
Compliance Tip of the Day: Issues for Internal Controls in International Operations
Compliance Tip of the Day: Top 4 Compliance Internal Controls
Compliance Tip of the Day: Discipline and Rigor in GTE Internal Controls
Compliance Tip of the Day: What are Internal Controls?
Testing Your Compliance Program
Regulatory vs. Business Compliance
Grupo Empresarial y Control … ¿a qué te cojo ratón?
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
In remarks to an industry group, Matthew R. Galeotti, head of the Department of Justice (DOJ) Criminal Division, emphasized that companies may avoid criminal resolutions if they voluntarily self-disclose misconduct, fully...more
Our White Collar, Government & Internal Investigations Team examines the impact of President Trump’s Executive Order pausing enforcement of the Foreign Corrupt Practices Act and identifies some key considerations and...more
How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges? In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more
This week, leading up to Halloween, I will examine lessons for compliance professionals through the lens of the great Universal Movie Monsters: Frankenstein, Wolfman, Dracula, and The Mummy. Today, we consider what compliance...more
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
Compliance and risk management are crucial aspects of any organization, and the third sector is no exception. In this week’s episode of Great Women in Compliance, hosted by Hemma Lomax, she visited with Sabrina Segal on the...more
One of the great things about having a podcast network is that I get to not only explore topics that I love but I get to tie them into compliance. Perhaps the best example is my award-winning series, Trekking Through...more
One of the benefits of old(er) age is perspective and experience. (As we age, we have to find the positive reasons to tout). If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more
We all agree on the importance of corporate culture. Everyone gets it – corporate leaders mouth the words but rarely understand the nuances, and the need to attend to a company’s culture. Compliance professionals want to...more
Welcome to a special five-part blog series on building a stronger culture of compliance, sponsored by Diligent. In this series I will visit with Yvette Hollingsworth-Clark, Viktor Cuijak, Jessica Czeczuga; Michael Parker; and...more
The Ethics and Compliance Initiative (“ECI”) is a terrific organization that provides important ethics and compliance insights and leadership. Starting in 1994, ECI has conducted a longitudinal, cross-section study of...more
The Justice Department’s recent revisions to its Corporate Enforcement Program and its Evaluation of Corporate Compliance Programs stressed the importance of compensations systems and consequence management. The theoretical...more
L’Agence française anticorruption (AFA) et le Parquet national financier (PNF) ont publié conjointement en mars 2023 un guide pratique visant à apporter aux entreprises un éclairage sur l’objet et la conduite d’une enquête...more
Let’s move beyond the headline – trade compliance is the new FCPA. We get it. The next step is to do something about it. The Justice Department has repeated this refrain – it is one of its greatest hits. In addition, DOJ,...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
A partir de la expedición de la Ley 2196 de 2022, las entidades sin ánimo de lucro (ESAL) en Colombia por parte de las entidades obligadas a contar con un Programa de Transparencia y Ética Empresarial (PTEE o el Programa)...more
Chief compliance officers rely on several important sources for feedback — internal data and communications (reviews with board, senior managers, employees); and benchmarking against comparable organizations. An internal...more
Chief compliance officers have a lot of issues to balance on their plate. Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective...more
There are lots of sources for compliance guidance — prosecutors, regulators, compliance organizations, and many others have set forth important and valuable guidance for the design and implementation of an effective ethics...more
The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay...more
This is the second post in this year’s series examining important trends and new development in white collar law and investigations. Our previous post discussed health care enforcement. Up next: trends in tax enforcement. ...more
Operation Lava Jato (Carwash) had a profound effect on business in Brazil, with countless companies caught up in one way or another in the corruption scandal. State oil company Petrobras was no exception, but, as is the case...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
Chief compliance officers play a key role in managing a company’s ethical culture. Most companies fail to pay proper attention to its culture because it is difficult to define, measure and monitor. Such an approach is...more
When I was a federal prosecutor and investigating corporations for misconduct, I imagined a well-oiled machine with vast resources, capable of overwhelming government prosecutors and law enforcement agents with lawyers,...more