Compliance into the Weeds - SOX Compliance, PCAOB Inspections and Audits
Compliance into the Weeds-Episode 57-SOX Reform or Not?
Compliance into the Weeds-Episode 51, the PCAOB and Compliance
Compliance into the Weeds-Espiode 47
Everything Compliance-Episode 12
Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol
Compliance into the Weeds-Episode 30-SOX 404(b)
FCPA Compliance and Ethics Report-Episode 145-SEC Enforcement of the FCPA, Part II
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
Compliance understanding of business processes is a critical part of understanding internal controls and a company’s risk profile. Compliance officers are adept in identifying and assessing risks. In doing so, a compliance...more
Ed. Note-We welcome back Troy McAlister with another guest post. Troy brings 20 years of experience at both public and private companies, in public accounting and in a variety of industries. Troy has experience in...more
The first step is to convert your company’s compliance risks into internal control objectives. The internal control objectives are then given to each business unit with instructions to develop controls, which meet the...more
We are on the final countdown, moving closer to Number 500. On Monday, August 31, I will be celebrating my 500th Anniversary episode, where I will talk about some of the key changes I have seen in compliance over the past 10...more
The initial FCPA Guidance included valuable compliance program guidance keyed to the heading, “Hallmarks of an Effective Compliance Program.” Issued in 2012, the outline of an effective compliance program was an important...more
What are some best practices regarding an internal reporting system? The 2012 FCPA Guidance stated, “An effective compliance program should include a mechanism for an organization’s employees and others to report suspected or...more
I have long articulated that companies that have robust compliance programs are more efficient, better run and more profitable organizations. ...more
Chief financial officers are powerful players in the corporate governance landscape. CFOs play a critical role in the management and oversight of the company’s internal accounting controls. Sarbanes-Oxley lifted the...more
When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more
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
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
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
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
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
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
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
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
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
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
I recently had the chance to visit with Joe Howell, the Executive Vice President (EVP) of Workiva LLC. Howell has been the Chief Financial Officer (CFO) of a number of public companies, mostly in the technology space, and...more
William Shakespeare’s Hamlet included this often used phrase – hoist with his own petard (a small bomb). Shakespeare never knew that his eloquence would apply to today’s SEC enforcement of internal controls. The FCPA...more
This Glossary is designed to provide law students taking Securities Regulation with a tool that will assist them in learning the basic language of securities law and achieve a working knowledge of the fundamental principles...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
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