The Herbalife FCPA Settlement: Board Oversight and Internal Audit Failures
In the enforcement and compliance arena, there are instances of misconduct that underscore important governance principles. But this just sounds like a bunch of mumbo jumbo (the technical term, I know). In the face of inexplicable behavior and failures to act, I often come back to the simple, but powerful phrase, “You Should Have Known Better.” The use of this phrase carries with it a...