The internal controls provision in the FCPA statute has broad application to a variety of situations beyond foreign bribery. The Securities and Exchange Commission knows full well the power of the internal controls provision and has readily applied it in a variety of circumstances. One recent example is the SEC’s settlement with Andeavor LLC for failure to publicly disclose the status of its negotiations to...
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- COSO ERM and Cloud Computing August 19, 2021
- 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