Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the Ericsson FCPA enforcement action from the internal controls perspective.
Some of the highlights include:
- What does this enforcement action tell up about internal controls?
- How were the business units able to evade internal controls for so long?
- Was there control override?
- What is the role of ERP systems such as Oracle and SAP in compliance?
- If a company refuses to use standard ERP systems, is that a control failure under the FCPA?
- What are the lessons learned for a corporate compliance program?
- What does all this mean for compliance professionals going forward?
Tom’s blog posts, both the FCPA Compliance and Ethics Blog.
Part 2-The Bribery Schemes