Och-Ziff: Accountability and Internal Controls (Part IV)

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1 Response

  1. Frank Numann says:

    Thank you for your good article on Och Ziff. We saw earlier with BHP that the SEC may fine a company for not operating its controls as designed. In the BHP case it concerned controls to prevent a breach of FCPA provisions. ALthough a breach was not established (and the DoJ dropped the investigation), the SEC went ahead and fined BHP $25 million for their omissions.