effective internal controls Archives - Corruption, Crime & Compliance

6 Mar, 2017

Review, Revise and Re-Organize Your Company’s Internal Controls (Part II of II)

Assuming you made it through Part I of this two-part posting about internal controls, we need to consider a new approach to the design and implementation of internal controls. The first hurdle to overcome, as always, is acknowledgement that a new approach is needed. The CFO and the financial team will inevitable resist because this has long been an area where they are the experts,...

A New Approach to Internal Controls (Part I of II)

General

5 Mar, 2017

A New Approach to Internal Controls (Part I of II)

The Justice Department and the Securities and Exchange Commission have dedicated more time and energy to understanding a company’s internal controls and enforcing basic requirements that companies maintain effective internal controls. For prosecutors, companies often fall short when it comes to following their internal controls. If you follow my blog, you know that I have often predicted that DOJ will eventually prosecute criminally an individual...