Tagged: contract to invoice to payment

Contract to Invoice to Payment (“Tinkers to Evers to Chance”) (Part II of II)

The SEC knows that it has powerful enforcement tools. The FCPA imposes two important requirements on issuers – keep accurate books and records and maintain internal controls to ensure that management’s accounting controls operate effectively to ensure proper use of corporate assets. The SEC knows these are broad requirements.  One critical area of focus has been the SEC’s focus on contract-invoice-payment process.  For compliance professionals,...