Audit Archives - Corruption, Crime & Compliance

3 May, 2017

Compliance and Financial Audits – Distinctions With Substance

Chief compliance officers and internal auditors are natural friends and allies. In the corporate governance world, they share many common interests. The natural partnership between compliance and audit reflects their substantive overlap of responsibilities. Internal auditors are guardians of a company’s internal controls, and ever since Sarbanes-Oxley, they have even greater responsibility for the accuracy of a company’s financial reporting system. A compliance program is...

General

1 Mar, 2017

DOJ Compliance Expectations Concerning Training, Internal Investigations and Audits (Part IV of IV)

DOJ’s Compliance Evaluation questions provide important indications of “new” trends and approaches to compliance functions and issues. Training In the area of training, DOJ’s Compliance Evaluation reiterates DOJ’s concern that companies tailor their training programs to their specific risk profile. In the FCPA Guidance issued in 2012, DOJ explained that training programs should be tailored to specific audiences. DOJ has refined this requirement to focus...

General

20 Sep, 2016

Sampling as a Compliance Strategy

In the technology age in which we live, CCOs often come face to face with a new phenomenon – too much information or data. TMI is not something to laugh at nor ignore. CCOs often face situations where they need to understand what is occurring through a monitoring or audit function. In those cases, CCOs have to decide whether it is worth the cost in...

General

19 Jul, 2015

Refining a CCO’s Reporting Relationship to a Corporate Board

You can observe a lot by just watching – Yogi Berra There is way too much time being spent on esoteric arguments about corporate board reporting responsibilities for Chief Compliance Officers. Let’s agree and move on to more important and difficult issues. I hate to be dogmatic but when it comes to this issue, there really is one obvious solution. Varying alternatives are less than...

General

14 May, 2015

Risk Assessment: A Natural Partnership for Internal Auditors and CCOs

We all know our favorite things and people who fit together well – milk and cookies, peanut butter and jelly, chips and salsa, Tracy and Hepburn, Martin and Lewis, Abbott and Costello, and many other great combinations. In the corporate compliance world, chief compliance officers and internal auditors are natural allies. They often report to the same board committee, share a common perspective on corporate...