What are some of the key FCPA enforcement actions involving M&A? These enforcement actions, FCPA Resource Guide and the Evaluation of Corporate Compliance Program (and Update) have
For the month of March, we will be considering how to create a more effective compliance program involving business ventures. This will include the role
To conclude this month’s series on Internal Controls, I am joined by Vin DiCianni, Founder and CEO of AMI. We discuss how corporate culture is
One of the specific requirements in the 2020 Update is around internal controls and, more specifically, control testing. It stated: Control Testing – Has the
The fifth and final Objective is Monitoring Activities. As with all other components of the COSO Cube, Monitoring Activities are part of an interrelated whole
As with the other components of the COSO Cube, the objective of Information and Communication is not to be taken in a vacuum. Indeed, one
In its Framework Volume, COSO Control Activities “are the actions established through policies and procedures that help ensure that management’s directives to mitigate risks to
Objective II is designed to provide a company with a “dynamic and iterative process for identifying and assessing risks.” For the compliance practitioner, none of
COSO was adopted in 1992 as a framework for a basis to design and test internal controls’ effectiveness. In 2010, updating this more than 20-year-old
