Tagged: internal controls

Crossing a New Bridge: Compliance Officers and Financial Controls

Compliance officers face plenty of challenges. The list of close allies always includes the General Counsel, Internal Audit, Human Resources and Procurement officials. In two recent surveys (here and here), CCOs reported that they do not have a strong working relationship with the CFO and typically do not get involved in the design and implementation of financial controls. That is a real significant problem. Lets start...

Encouraging Employees to Break the “Rules” to Do the Right Thing

Lauren Connell of The Volkov Law Group joins us again for a posting about corruption and gifts and hospitality.  Her profile is here and she can be reached at lconnell@volkovlaw.com. Laws and regulations draw black lines in often-gray areas. That is their purpose; they exist to make it easier to tell what is “wrong” and what is “right” (as defined by whoever made the law)....

Gifts, Meals and Prosecution: BHP Billiton’s Settlement

The SEC is on a mission – companies that engage in egregious payment schemes for gifts, hospitality and travel are going to get prosecuted for civil FCPA violations. Recent SEC enforcement actions against companies continue, and BHP Billiton’s settlement last week is another example of the SEC’s prosecution strategy. BHP Billiton agreed to pay a $25 million penalty to settle SEC charges for internal controls...