News & Analysis as of

Sarbanes-Oxley Compliance

The Root Compliance Problem: “Shadow Process”

by NAVEX Global on

Sometimes I revisit my compliance roots in the world of Sarbanes-Oxley – a place much more concerned with financial reporting than corporate ethics and culture, I know. Yet lessons from one group that can help the other still...more

Compliance into the Weeds-Episode 51, the PCAOB and Compliance

by Thomas Fox on

In this episode, Matt Kelly and I take a deep dive into the Public Accounting Oversight Board (PCAOB). We consider the role of the PCAOB in both audit standards and internal controls for compliance. What is goodwill, goodwill...more

How to Weigh Costs & Benefits of Compliance

by NAVEX Global on

Jay Clayton, new chairman of the Securities and Exchange Commission (SEC), gave a speech on July 12 about what his priorities as leader of the SEC will be. He outlined eight principles. Chief compliance officers should make...more

Anti-Corruption Compliance: The Need to Look Under the Cloak of Materiality

by Michael Volkov on

Sarbanes-Oxley revolutionized the auditing profession. Section 404 imposed stringent requirements for disclosure of the state of a company’s internal controls and financial reporting. The company’s independent auditor is...more

Compliance into the Weeds-Espiode 47

by Thomas Fox on

In this episode, Matt Kelly and I discuss SOX and Dodd-Frank reform efforts involving compliance. ...more

New Revenue Recognition Standard – Part VI: What Does Mean?

by Thomas Fox on

Over several blog posts, I have explored in detail the new Financial Accounting Standards Board (FASB) Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606), which set forth a new Revenue...more

New Revenue Recognition Standard – Part I: Introduction

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

CCOs and Resources: Put Your Money Where Your Mouth Is!

by Michael Volkov on

The compliance profession is enjoying its moment of triumph. Chief compliance officers are earning substantial salaries and rewarded with high-level positions in the C-Suite and significant influence. CCOs are the hot...more

Investigation Challenges

by Thomas Fox on

Today I conclude my three-part series on internal investigations with Jonathan Marks, a partner at Marcum LLP and a well-known internal investigation expert, by considering some of the challenges you may well face during an...more

Everything Compliance-Episode 12

by Thomas Fox on

Show Notes for Episode 12, the Summer Haze Edition The dog days of summer are on the horizon and the Houston Astros lead the major leagues in winning percentage. Coincidence that the US pulls out of the Paris Climate Accords...more

Whistleblower Hotlines: Still a Vital Tool

by NAVEX Global on

Recently the chief compliance officer of a global company asked me: does a company need a telephone-based whistleblower hotline anymore? In our all-technology, all-the-time world, could a company phase out telephone hotlines...more

Compliance into the Weeds-Episode 30-SOX 404(b)

by Thomas Fox on

In this episode Matt Kelly and myself take a deep dive into SOX 404(b), what it requires and how companies comply with the reporting requirements set out in this statute. We consider the recent announcements from Congressman...more

Whistleblower Conference Agenda Sizzles with Hot Topics

by Thomas Fox on

2016 was more than simply the most robust year in Foreign Corrupt Practices Act (FCPA) enforcement. It was also a record year in Securities and Exchange Commission (SEC) whistleblower awards and additionally the year the SEC...more

The “New” Face of Corporate Misconduct

by Michael Volkov on

As we look across the corporate governance landscape and focus on the spikes of corporate scandals, I started to wonder if there was any pattern or trend to the nature of corporate scandals....more

Compliance isn’t Going Away (and Neither Should You) – Part III

by Thomas Fox on

I continue what has now become a week-long explanation of why the compliance function in a corporation and the compliance profession in general is not going anywhere, even with the election of Trump as President and a full...more

Compliance Isn’t Going Away (and neither should you) – Part I

by Thomas Fox on

Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...more

Volkov on the Evolving Standards for Compliance Programs

by Thomas Fox on

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

When Leslie Caldwell Talks FCPA, You Should Listen

by Thomas Fox on

November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more

Houston Professional Football Stays the Same; Compliance Evolves

by Thomas Fox on

The history of professional football in Houston is certainly star-crossed. After winning the first two American Football League (AFL) championships in 1960 and 1961, the Oilers never made it back to the big game. After the...more

Johnson Controls Pays $14 Million for China FCPA Violations: DOJ Declines Prosecution

by Michael Volkov on

At first glance, the SEC’s recent enforcement action against Johnson Controls for $14 million for FCPA violations in China, along with a Justice Department declination under its new Pilot Program, appears to be a “routine”...more

Enforcement Week II: The Johnson Controls FCPA Enforcement Action – Part I

by Thomas Fox on

I continue my exploration of recent enforcement matters and issues by turning to the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action, which was announced last week. Mike Volkov has called...more

Convergence of Audit and Compliance Functions

by Michael Volkov on

Returning to the serious subject of compliance, there are some who argue that compliance is a lot simpler than professionals and commentators tend to describe. I am an advocate for simplicity as a way to ensure adoption of...more

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

by Thomas Fox on

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more

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

by Thomas Fox on

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

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

by Thomas Fox on

Today, I continue my exploration with Joe Howell about the Public Accounting Oversight Board (PCAOB), its scrutiny of public company auditors and how its work impacts the corporate compliance function. Yesterday, I ended with...more

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