The 2020 Update re-emphasized the need to perform a root cause analysis and, equally importantly, use it to remediate your compliance program. It stated, “a
One of the most significant changes in the 2020 FCPA Resource Guide, 2nd edition, was the addition of a new Hallmark entitled “Investigation, Analysis, and
Your company has just made its largest acquisition, and your CEO says they want you to have a compliance post-acquisition integration plan on their desk
One of the areas articulated in the 2020 Update was around payments and payroll. The compliance professional and the corporate payroll function have a significant
The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When it
The role of the CCO has steadily grown in stature and prestige over the years. The 2020 FCPA Resource Guide, under the Hallmarks of an
One of the critical elements found in the 2020 Update is the need to use the information you obtain, whether through risk assessment, root cause
What happens when controls are continually overridden? Does that necessarily mean that companies are engaging in activities that violate the FCPA or some other law,