One of the questions GSK faced during the bribery and corruption investigation of its Chinese operations was how an allegedly massive bribery and corruption scheme occurred? Where
As they made clear with several FCPA enforcement actions in 2020, the SEC has continued to emphasize the accounting provisions of the FCPA, specifically the
How should you assess your internal controls regime for international operations? It is incumbent that you need to review as much information as you can
Next, I want to consider some of the issues around internal controls outside the U.S. and why your company’s internal controls might require changes for
There are four significant controls that I would suggest the compliance practitioner implement initially. They are: 1) DOA; 2) maintenance of the vendor master
New York Times columnist David Brooks’ thoughts on building and maintaining order inform the discussion on rigor in your internal controls. In internal controls, I believe
What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of
In an area of inquiry entitled Oversight, the 2020 Update asks three basic questions which we have explored throughout this chapter: What compliance expertise has been
A white paper by Deloitte & Touche LLP, entitled “Risk Intelligence Governance – A Practical Guide for Boards”, laid out six general principles to help
How can a Board work to incorporate the compliance function into a long-term business strategy of the organization? A Board can do so by engaging
