Tagged: sarbanes oxley

Ominous Signs for the Future of the Compliance Profession

As we celebrate Ethics and Compliance Week in 2017, I wanted to offer my own assessment of where the compliance profession stands and the challenges facing the profession for the future. I am an eternal optimist – I will never fall to the dark side of cynicism and pessimism. Over the last ten years, the compliance profession has made great strides as a profession and...

Internal Controls Enforcement: Hoisting Yourself on Your Own Petard

William Shakespeare’s Hamlet included this often used  phrase – hoist with his own petard (a small bomb). Shakespeare never knew that his eloquence would apply to today’s SEC enforcement of internal controls. The FCPA requires companies to make and keep accurate books and records and to devise and maintain an adequate system of internal accounting controls. The FCPA also prohibits individuals and businesses from knowingly...