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Internal Controls Audits Foreign Corrupt Practices Act (FCPA)

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part II)

Foley & Lardner LLP on

In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: October 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

Thomas Fox - Compliance Evangelist

Talent Mix: Maximizing Your Program’s Reach with Diverse Skillsets

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

Thomas Fox - Compliance Evangelist

Assessing compliance internal controls under the COSO 2013 Internal Controls Framework

In the age of Coronavirus, it could well be time to assess your internal controls beyond a gap analysis. Consider what COSO says about assessing compliance internal controls. In its Illustrative Guide, COSO laid out its views...more

Thomas Fox - Compliance Evangelist

Countdown to 500 – Jonathan Marks on Professionalism in Compliance

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

Society of Corporate Compliance and Ethics...

[Event] April Basic Compliance & Ethics Academy - April 27th - 30th, Chicago, IL

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

Society of Corporate Compliance and Ethics...

[Event] March Basic Compliance & Ethics Academy - March 2nd - 5th, San Diego, CA

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

Foley & Lardner LLP

Navigating the Aggressive Enforcement of International Regulations: Eight Compliance Tips for Auto Companies

Foley & Lardner LLP on

We are now two years into the current presidential administration and regulators have imposed three of the ten largest Foreign Corrupt Practices Act penalties in history and the largest export controls penalty of all time....more

Bass, Berry & Sims PLC

OFAC Actions Provide Guidance on Sanctions Compliance Best Practices

• Russian corporations de-listed through significant specific steps agreed to with OFAC • Exporter settles for $7.7 million and agrees to comprehensive compliance measures • OFAC outlines sanctions compliance best...more

Thomas Fox - Compliance Evangelist

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

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

Thomas Fox - Compliance Evangelist

Creation of Roundabout and Operationalization of Compliance

Readers of this blog know of my love for progressive rock music and that my favorite prog rock group is Yes. You might understand how thrilled I was when the Wall Street Journal (WSJ), of all places, ran an interview with...more

Thomas Fox - Compliance Evangelist

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

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

Thomas Fox - Compliance Evangelist

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

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

Thomas Fox - Compliance Evangelist

COSO and Internal Controls – Part V

This post concludes my exploration of internal controls and how companies can demonstrate compliance with the internal controls requirement under the Foreign Corrupt Practices Act (FCPA) by adhering to the Committee of...more

Dorsey & Whitney LLP

The Origins of the FCPA - Lessons for Effective Compliance and Enforcement - Conclusion

Dorsey & Whitney LLP on

This is the final part of an occasional series. The entire paper will be published by Securities Regulation Law Journal early next year. Conclusion: The FCPA Today - The FCPA was unique in the world at passage....more

Dorsey & Whitney LLP

The Origins of the FCPA: Lessons For Effective Compliance and Enforcement - Part Five

Dorsey & Whitney LLP on

The Congressional debates - The revelations from the Watergate hearings and the Commission’s investigations and enforcement actions sparked two years of Congressional hearings. Those revelations also spawned a...more

Thomas Fox - Compliance Evangelist

Lessons from GSK in China – Internal Controls, Auditing and Monitoring

One of the questions that GSK will have to face during the next few years of bribery and corruption investigations is how an allegedly massive bribery and corruption scheme occurred in its Chinese operations? The numbers went...more

Cadwalader, Wickersham & Taft LLP

Will Independent Directors Be on the Hook for Failure of Internal Controls in FCPA Cases?

The Foreign Corrupt Practices Act ("FCPA" or "the Act") prohibits bribery of foreign public officials in order to obtain or retain business. In addition to its anti-bribery provisions, the FCPA contains accounting provisions...more

Manatt, Phelps & Phillips, LLP

A Roadmap for Audit Committees in Meeting the Challenges Posed by Enhanced Regulatory Scrutiny Under the Dodd-Frank Act

Audit committees must aid management in navigating an increasingly complex regulatory framework. Two recent developments arising from the passage and implementation of the Dodd-Frank Act have led to further challenges for...more

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