The compliance component of your M&A regime should begin with a preliminary pre-acquisition assessment of risk. Such an early assessment will inform the transaction research
The DOJ and SEC have both made it clear that they expect companies to be more robust in their use of data analytics in compliance
One of the key components for any successful business leader; yet one rarely discussed, is judgment. I was therefore intrigued by a Harvard Business Review
In today’s edition of Daily Compliance News: First VW senior manager trial in Germany. (NYT) Sayonara Hertz. (WSJ) JPMorgan to pay $920MM to settle spoofing
A gap analysis is a method of assessing the differences in performance between a business’ internal controls to determine whether business requirements are being met
Next, consider what COSO says about assessing compliance internal controls. In its Illustrative Guide, COSO laid out its views on “how to assess the effectiveness
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
The first of the five objectives is control environment and it sets the tone for the implementation and operation of all other components of internal control. It
In 2016, one of the most interesting non-international focused FCPA enforcement actions was announced by the SEC. It involved a clear quid pro quo benefit
It is reasonable to expect that internal controls over gifts, travel and entertainment be designed to ensure that they satisfy the criteria as defined in
