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 it is incumbent to consider not only the most obvious risk areas for your internal controls but also the universe of potential transactions within a company’s operations. There is a clear need for rigor in your internal controls protocols. Adherence to that rigor can increase operationalization around the internal controls a company should consider, including gifts, travel, and entertainment expenses. Brooks said, “Building and maintaining order … requires toughness of mind and rigid discipline to serve your own work properly.” By having the rigor to institute and enforce the types of internal controls identified, you can go a long way toward detecting and, more importantly, preventing an FCPA violation from occurring.

Some of the key areas of Internal Control focus should be:

·       The Delegation of Authority (DOA)

Petty cash disbursements

·       Travel

·       P-Cards

·       Employee Expense Reports

·       Corporate checks and wire transfers, such as check requests, purchase orders, or vendor invoices.

·       Gifts and business entertainment

Three key takeaways:

1. You must maintain rigor around your internal controls.

2. Controls against fraud can also help to prevent corruption.

3. Building and maintaining good internal controls requires rigor.