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
Will US companies create their own business risk abroad by not adopting compliance policies for risks that they deem controversial or may not fully believe in at home? On the surface this may seem like a rhetorical question –...more
We are surrounded by bias in a variety of contexts – news, politics, books and Internet information. Given the overwhelming amount of information, some find comfort in information supplied by sources with a bias. We have...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
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
Ethics and compliance officers talk constantly about the importance of corporate culture, ethical values, and a strong tone at the top; and we should. You can’t have an effective corporate compliance program without them....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
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
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
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
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
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
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
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
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
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
Today we acknowledge (I cannot say celebrate) one of the seminal events which led to the explosion of Foreign Corrupt Practices Act (FCPA) enforcement actions from 2004 forward. On this day in 2001 the Houston based company...more
Today, I wrap up my series on why I think compliance is at the Tipping Point. However as it is a Friday in October, I continue my tribute to the Man in the Shadows, producer Val Lewton, whose films for RKO had some of the...more
I conclude my tribute to my favorite Bob Dylan album, Highway 61 Revisited with a look at the most surreal song on the disc, Tombstone Blues. I want to use it to contrast the most excellent article that appears today as 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
On this day in 1876 one of the greatest failures in risk management took place when Lieutenant Colonel George Armstrong Custer and his entire 7th Cavalry were wiped out at the Battle of the Little Big Horn. Custer had split...more