• Day 14 of One Month to More Effective Internal Controls-What is the COSO Framework?
    This week we turn our attention to COSO, with an introduction to the organization and its framework for internal controls. I will go through the internal controls and how they relate to compliance. Finally, I will end with a discussion of evaluation of internal controls through the COSO Framework. Once… ... read more
    Source: Blog FeedPublished on 2017-07-23
  • Day 14 of One Month to More Effective Internal Controls-What is the COSO Framework?
    This week we turn our attention to COSO, with an introduction to the organization and its framework for internal controls. I will go through the internal controls and how they relate to compliance. Finally, I will end with a discussion of evaluation of internal controls through the COSO Framework. Once… ... read more
    Source: Podcast FeedPublished on 2017-07-23
  • This Week in FCPA-Episode 62, the Kids are Back Edition
    This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including: Will Canada approve DPAs for use in anti-corruption prosecutions? TI-Canada recommends they come into use. See article in Corporate Compliance by clicking here. Also see interview with RCMP… ... read more
    Source: Blog FeedPublished on 2017-07-21
  • This Week in FCPA-Episode 62, the Kids are Back Edition
    This week, Jay and I return for a wide-ranging discussion on some of the week’s top compliance and ethics related stories, including: Will Canada approve DPAs for use in anti-corruption prosecutions? TI-Canada recommends they come into use. See article in Corporate Compliance by clicking here. Also see interview with RCMP… ... read more
    Source: Podcast FeedPublished on 2017-07-21
  • Day 13 of One Month to More Effective Internal Controls-Code of Conduct as an Internal Control
    Last year, one of the most interesting non-Foreign Corrupt Practices Act (FCPA) enforcement actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit paid out by United Airlines to David Samson, the former Chairman of the Board of Directors of the Port… ... read more
    Source: Blog FeedPublished on 2017-07-21
  • Day 13 of One Month to More Effective Internal Controls-Code of Conduct as an Internal Control
    Last year, one of the most interesting non-Foreign Corrupt Practices Act (FCPA) enforcement actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit paid out by United Airlines to David Samson, the former Chairman of the Board of Directors of the Port… ... read more
    Source: Podcast FeedPublished on 2017-07-21
  • Clarence Darrow, the Scopes Monkey Trial and Leadership
    Today we honor one of the ‘Trials of the Century’ from the 20th century, as on this day in 1925, the Scopes Monkey Trial ended with defense attorney Clarence Darrow giving one of his greatest closing arguments, asking for his client to be convicted so the case could be appealed.… ... read more
    Source: Blog FeedPublished on 2017-07-21
  • Day 12 of One Month to More Effective Internal Controls-Board Oversight as an Internal Control
    Is a Board of Directors a compliance internal control? I think the clear answer is yes. In the FCPA Guidance, in the Ten Hallmarks of an Effective Compliance Program, there are two specific references to the obligations of a Board in a best practices compliance program. The first in Hallmark… ... read more
    Source: Blog FeedPublished on 2017-07-20
  • Day 12 of One Month to More Effective Internal Controls-Board Oversight as an Internal Control
    Is a Board of Directors a compliance internal control? I think the clear answer is yes. In the FCPA Guidance, in the Ten Hallmarks of an Effective Compliance Program, there are two specific references to the obligations of a Board in a best practices compliance program. The first in Hallmark… ... read more
    Source: Podcast FeedPublished on 2017-07-20
  • Everything Compliance-Episode 14
    Show Notes for Everything Compliance-Episode 14 Topics from Matt: Trump Administration & FCPA enforcement— we have two declinations now; maybe a compare-and-contrast, and speculation on what a tough Trump Admin enforcement WOULD look like; EU’s GDPR— Do EU regulators really know what they want to do with enforcement of this… ... read more
    Source: Blog FeedPublished on 2017-07-20
  • Everything Compliance-Episode 14
    Show Notes for Everything Compliance-Episode 14 Topics from Matt: Trump Administration & FCPA enforcement— we have two declinations now; maybe a compare-and-contrast, and speculation on what a tough Trump Admin enforcement WOULD look like; EU’s GDPR— Do EU regulators really know what they want to do with enforcement of this… ... read more
    Source: Podcast FeedPublished on 2017-07-20
  • Tribute to Martin Landau and Strength in the Middle
    In addition to the passing of George Romero over the weekend, there were several other notable deaths. Today, I want to pay tribute to Martin Landau. When most people think of Landau, they remember his Oscar winning performance as Bela Lugosi in the movie Ed Wood which came out in… ... read more
    Source: Blog FeedPublished on 2017-07-20
  • Day 11 of One Month to More Effective Internal Controls-Internal Controls for Gifts, Travel and Entertainment
    Joe Howell, EVP of Workiva, Inc. as noted that it is reasonable to expect that internal controls over gifts, travel and entertainment (GTE) be designed to ensure that all satisfy the criteria as defined in company policies. Generally speaking, these are fairly narrow, including a definition of the dollar limit,… ... read more
    Source: Blog FeedPublished on 2017-07-19
  • Day 11 of One Month to More Effective Internal Controls-Internal Controls for Gifts, Travel and Entertainment
    Joe Howell, EVP of Workiva, Inc. as noted that it is reasonable to expect that internal controls over gifts, travel and entertainment (GTE) be designed to ensure that all satisfy the criteria as defined in company policies. Generally speaking, these are fairly narrow, including a definition of the dollar limit,… ... read more
    Source: Podcast FeedPublished on 2017-07-19
  • Compliance into the Weeds-Episode 46-The Potted Plant Edition
    In this episode, Matt Kelly and I discuss the recent Second Circuit Court of Appeals decision in HSBC v. Moore. In this case a federal district court had ordered the release of redacted monitor’s report in the HSBC money-laundering Deferred Prosecution Agreement (DPA), based upon the request of an interested… ... read more
    Source: Blog FeedPublished on 2017-07-19

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