The FCPA includes a specific requirement that a public company maintain an adequate set of internal controls. A company’s compliance program is one component of a company’s internal controls. Sarbanes-Oxley expended and reinforced this important requirement. The Department of Justice and the SEC have aggressively enforced the internal controls requirement. The SEC, in particular, has expansively enforced the internal controls requirement even where a failure...
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- Governance, Fraud, and Corporate Culture: Sorting Through a Complicated Relationship April 15, 2021
- Environmental, Social, and Governance or ESG April 14, 2021
- Internal Controls – A Process to Help Ensure Internal Controls are Designed Consistently and Appropriately April 8, 2021
- Ethics and Compliance: Active Board Involvement Is a Must April 5, 2021
- Governance: Board of Directors Effectiveness April 5, 2021