While many compliance practitioners believe that employee expense reports are a sufficient internal control of gifts because there are other ways in which a gift can be presented, other controls must be considered. Once your company policy on gifts has been finalized, the internal controls over expense reports fall into three primary areas:
- The expense report format, including what information it requires.
- Controls over the submitting employee and the preparation of the expense report.
- Controls to ensure the approvers do their review process properly.
Internal controls around gifts can be used in various ways in your best practices compliance program. They can certainly be used to detect an issue and perhaps even prevent an issue from becoming a full-blown FCPA violation; however, by using some of the techniques that Howell has suggested, you can move your compliance program to a proscriptive phase where you not only stop an issue from becoming a violation but through identification, you can move towards remediation as a part of your ongoing compliance efforts. The bottom line is that good internal controls make for good business processes; if you can move your compliance program’s internal controls forward, you can help make them a part of your financial controls and, thereby, have a better-run company.
Three Key Takeaways:
- GTE compliance internal controls are low-hanging fruit. Pick them.
- Compliance with internal controls can be both detected and prevented controls.
- Good compliance with internal controls is good for business.
For more information on how to build out a best practices compliance program, including internal controls, check out The Compliance Handbook, 3rd edition.
