Risk Assessments
January 18, 2024
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One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on
One cannot really say enough about risk assessments in the context of anti-corruption programs. This is because every corporate compliance program should be based on
This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the
If there is one truism from the practice of law that translates to the practice of compliance, it is that you are only limited by
We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement involving the German software company, SAP. The company agreed to pay the Department
One of the key goals of any compliance program is to train employees in awareness and understanding of the FCPA; your specific company compliance program;
The year in Foreign Corrupt Practices Act (FCPA) enforcement started off with a bang on January 10 with the announcement of a resolution of the
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
What are internal controls? The best definition I have come across is from Jonathan Marks, partner at BDO, who defined internal controls as: An internal
There are numerous reasons to put some serious work into your compliance policies and procedures. They are certainly a first line of defense when the
What is the value of having a Code of Conduct? In its early days, a Code of Conduct tended to be lawyer-written and lawyer-driven to
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