Page 3 - Effective Compliance Program News Today

One of the specific requirements in the 2020 Update is around internal controls and, more specifically, control testing. It stated: Control Testing – Has the company...

Is a Board of Directors a compliance internal control? The clear answer is yes. In the 2020 FCPA Resource Guide, Hallmarks of an Effective Compliance Program, there are two specific...

The SEC has continued to emphasize the accounting provisions of the FCPA, specifically the internal controls provisions. The reason is straightforward; a company with rigorous internal...

On the heels of the release of the final regulations on December 28, today, the Office of the Medicaid Inspector General just released guidance on Compliance Programs; Self-Disclosure;...

The role of the compliance professional and the compliance function in a corporation has steadily grown in stature and prestige over the years. When it came to the corporate compliance...

The role of the CCO has steadily grown in stature and prestige over the years. The 2020 FCPA Resource Guide, under the Hallmarks of an Effective Compliance Program, focused on whether...

On January 17, 2023, Assistant Attorney General (“AAG”) Kevin Polite announced revisions to the Department of Justice’s (“DOJ”) Corporate Enforcement Policy (“CEP”), which will apply to...

The US Department of Justice (DOJ) continues to try to dispel lingering skepticism over the benefits of corporate disclosure and cooperation. In remarks delivered on January 17,...

As every compliance practitioner is well aware, third parties still present the highest risk under the FCPA. The 2020 Update devotes an entire prong to third-party management. It begins...

What are internal controls? The best definition I have come across is from Jonathan Marks, who defined internal controls as: Internal control is an action or process of...