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Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose
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Conducting Corporate Internal Investigations
New York Medical College (NYMC) officials thought the HHS Office of Inspector General’s (OIG) audit was wrapping up in December 2021, based on what “the original senior auditor” told them. But the auditor retired and work...more
Learning Objectives: 1. Understand the data elements required for 501r, ESG, and health equity 2. Understand how those data elements cross over 3. Understand best practices with data governance and process...more
In this article, accounting firm Deloitte observes that boards and managements often experience “denial” when the topic of fraud risk arises—no one wants to feel that the trust they place in their own employees is actually...more
ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more
HCCA's Healthcare Research Compliance Academy is a three-and-a-half-day intensive training program designed to help attendees increase their ability to manage effective research compliance programs. Our faculty of experts...more
SCCE’s Compliance & Ethics Institute is the primary educational and networking event for compliance and ethics professionals worldwide. Leading industry professionals cover real‑world compliance issues, emerging trends, and...more
REGULATORY UPDATES - SEC Proposes Conditional Exemption for Finders Assisting Small Businesses with Capital Raising - On October 7, 2020, the Securities Exchange Commission (the “SEC”) proposed a conditional exemption...more
While much of the corporate legal world has been focused on the effects of the COVID-19 pandemic, a little-noticed case working its way through the federal courts in Washington, D.C. threatens to whittle down the scope of...more
The FDIC and OCC have issued new guidance for banks on heightened cybersecurity risks facing the financial services industry because of increased geopolitical tensions and threats of aggression. The guidance published on...more
As independent auditors to public companies and business development companies begin to make required disclosure of Critical Audit Matters (CAMs) to the audit committee, such reports are beginning to include discussion of...more
Internal auditors are worried that boards are not paying enough attention to—wait for it—internal auditors. Probably most often, we consider the internal audit function in the context of financial reporting, but its brief can...more
The Financial Reporting Council (FRC), the regulatory body for accountants, auditors and actuaries in the UK, was allowed access to privileged material of a client of an auditor under investigation....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 2009, the Securities and Exchange Commission sued Danny Pang and his two companies for allegedly defrauding investors of hundreds of millions of dollars by misrepresenting investments in the life insurance policies of...more
Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more
Returning to an enforcement priority repeatedly articulated over the years, the SEC recently imposed sanctions on a registered investment advisory firm and two principals arising out of an alleged scheme to inflate the...more
In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more