Compliance Tip of the Day: COSO Governance Framework: Part 4, Culture
Compliance Tip of the Day: COSO Governance Framework: Part 2, Oversight
Compliance Tip of the Day: COSO Governance Framework: Part 1, Introduction
Compliance Tip of the Day: Design - Centric Internal Controls
Compliance Tip of the Day: Lessons from Internal Control Failures
Compliance Tip of the Day: Internal Control Deficiencies
Compliance Tip of the Day: Assessing Internal Controls
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 4 - Control Information and Communication
Compliance Tip of the Day: COSO Objective 3 – Control Activities
Compliance Tip of the Day – COSO Objective 1 – Control Environment
Compliance Tip of the Day: Code of Conduct as an Internal Control
Compliance Tip of the Day: COSO Framework
Compliance Tip of the Day: Internal Controls for GTE
Compliance Tip of the Day: Board Oversight on Internal Controls
Compliance Tip of the Day: Internal Controls for Third Parties
Compliance Tip of the Day: Implementing Internal Controls
Compliance Tip of the Day: Risk Assessments and Internal Controls
Compliance Tip of the Day: Issues for Internal Controls in International Operations
Compliance Tip of the Day: Top 4 Compliance Internal Controls
Risk and compliance leaders face increasing demands to elevate board conversations beyond compliance checkboxes. Boards expect clear insight into how risks affect strategic execution, financial performance, and enterprise...more
On Friday, SEC Chief Accountant Paul Munter released a public statement in which he expressed concerns about the risk assessment process of both auditors and management. As a possible harbinger of things to come, the...more
We all know the importance of teamwork and collaboration. Whatever the context, sports, business, military, and many other situations, teamwork and cooperation is essential to success. ...more
Sometimes compliance issues are simple. Most times they are nuanced. This is a simple issue but it carries with it a significant message. So here goes – where is the CCO’s office?...more
The Evaluation of Corporate Compliance Programs, 2019 Guidance, makes clear that operationalization of compliance into an organization should be done at multiple levels. The 2019 Guidance also called out culture as a key...more
How Are Compliance Budgeting and Compliance Officer Autonomy Tied Together When Assessing Compliance Effectiveness? The Department of Justice (“DOJ”)’s compliance program evaluation identifies the need to allocate...more
In this episode, the second of three building on Akin Gump’s annual Top 10 Topics for Directors report, partner Lauren Leyden discusses the #MeToo movement and its impact on the corporate world. Among the topics covered: •...more
Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a...more
We live in a bizarre time — an information age where lines are blurred between truth and lies — a strange era in which our daily doses of information are dominated by scandals, corruption, and repeated claims of “fake news.” ...more
The drug and medical device industries have been taking it on the FCPA chin for years. The risk factors in the international marketplace are significant – healthcare professionals are normally government employees; government...more
Maureen O’Hara died this week. To anyone who has ever watched The Quiet Man on St. Patrick’s Day, she will always be known as Mary Kate Danaher, who was pursued and eventually wed by John Wayne. Testament to the fiery...more
On September 15, 2015, the Security and Exchange Commission’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert to provide additional information on the areas of focus for its second round of...more
On September 8, the SEC charged a sports supplements and nutrition company, its former audit committee chairman and three of its current and former executive officers with committing accounting, disclosure and other...more
If you find yourself as the CEO of a public company, you’ll probably find pluses and minuses. You’ll have to work really hard, but it can be lucrative, too. You can get paid a lot of money. And your company can pay you...more
Signaling that it is closely scrutinizing the expenses of senior executives and the internal controls of public companies, the Securities and Exchange Commission charged former Polycom CEO Andrew M. Miller this week with...more
The former President and CEO of a public company repeatedly charged personal expenses to the firm largely by falsifying documents and records. Although the executive admitted certain misdeeds to internal investigators...more
On December 22, 2014, French power and transportation company Alstom S.A. (“Alstom”) pleaded guilty to violating the Foreign Corrupt Practices Act (“FCPA”) and agreed to pay $772.29 million, the largest criminal fine ever...more
In this episode I begin a two-part review of the 2014 FCPA year. In this episode I review some of the significant corporate enforcement actions. ...more
Tone-at-the-top says it all. Without the support of the CEO, a Chief Compliance Officer is limited in what he or she can accomplish. If there is no commitment from the CEO, a CCO can propose and possibly build great...more