Page 5 - Effective Compliance Program News Today

The United States Department of Justice (DOJ) is the federal agency tasked with enforcing a wide range of federal laws and regulations. When the DOJ suspects that an individual or...

Halloween is almost upon us and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As...

What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of any effective anti-corruption...

To embed, copy and paste the code into your website or blog: Over the past few blog posts, I have been discussing the Statement issued last week by President Biden equating the international scourge of corruption as a national security threat to the United States and President Biden’s directive that countering corruption is “a core United States national security interest.” President Biden followed this up with his Memorandum on Establishing the Fight Against Corruption as a Core United S...

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To embed, copy and paste the code into your website or blog: One of the specific requirements laid out in the 2020 Update, is around internal controls and more specifically control testing. Fortunately, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) 2013 Internal Controls Framework considers assessing compliance internal controls. In “Internal Controls – Integrated Framework, Illustrative Tools for Assessing Effectiveness of a System of Internal Controls”, CO...

To embed, copy and paste the code into your website or blog: The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin the process which will determine, in many instances, how the company will respond going forward. Internal reporting. The 2020 FCPA Resource Guide has as clear and concise a statement about hotlines as any other requ...

To embed, copy and paste the code into your website or blog: 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. You must have a process for the full life cycle of third-party risk management. There are five steps in the life cycle of third-party risk management, which will fulfill the DOJ requirements as laid out in the 2020 FCPA Resource Guide and in the Hallmarks of an ...

To embed, copy and paste the code into your website or blog: What are internal controls? The best definition I have come across is from Jonathan Marks who defined internal controls as: An internal control is an action or process of interlocking activities designed to support the policies and procedures detailing the specific preventative, detective, corrective, directive and corroborative actions required to achieve the desired process outcomes or the objectives(s). This, along with continuous ...

To embed, copy and paste the code into your website or blog: Even with this most turbulent year nearly at an end, we continue to lose many true greats. One of the greatest in baseball in the ‘60s and ‘70s was Richie (Dick) Allen. According to Tyler Kepner, writing in his On Baseball column in the New York Times (NYT), between 1964 through 1974, Henry Aaron, Willie McCovey, Frank Robinson, Willie Stargell, Roberto Clemente, Willie Mays, Harmon Killebrew, Carl Yastrzemski, Billy Williams, Re...