The 2020 Update mandated a Board of Directors ensure “the sufficiency of the personnel and resources within the compliance function, in particular, whether those responsible
The basic framework for internal controls is derived from the COSO Model developed by the Committee of Sponsoring Organizations of the Treadway Commission in 1992
Where does “tone at the top” start? With any public and most private U.S. companies, it is at the Board of Directors. But what is
Welcome to this month’s offer of 31 Days to a More Effective Compliance Program. This month I will focus on the Board of Directors and
In this final episode for the month of July on 31 Days to a More Effective Compliance Program, I review the past month’s offerings and
In today’s edition of 31 Days to a More Effective Compliance Program, I am joined by Vin DiCianni, founder of Affiliated Monitors. Vin provides insights
One of the areas many companies do not focus on enough is possible corruption in their supply chain for goods and services provided on a
The FCPA world is littered with cases involving freight forwarders, brokers and agents in the shipping and express delivery arena. Both the DOJ and SEC
One of the issues in any compliance program is the compensation paid to a third-party as FCPA exposure arises when companies pay money, either directly
At some point, you will be required to terminate a third-party and there will be multiple legal, compliance and business issues to navigate through. If
