Blog Posts Tagged with "FCPA"
Guidance on Internal Controls, Ethics, and Compliance
April 10, 2011 Added by:Thomas Fox
A benchmark of the elements of an effective compliance program is the OECD's Good Practice Guidance on Internal Controls, Ethics, and Compliance. This article lists 12 specific instructions for companies to utilize as a basis to construct an effective compliance program upon...
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Effective FCPA Risk Assessments
April 01, 2011 Added by:Thomas Fox
Insufficient strategies include: an FCPA compliance policy that is disseminated broadly but has shallow preventative measures; monitoring efforts which review samples from artificially inflated universes; expanding the FCPA audience, yet diluting the compliance solution...
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Compliance and Ethics: Tone from the Middle
March 25, 2011 Added by:Thomas Fox
In the communication of company values, a company must speak with one voice. This core concept needs to be communicated throughout the organization. It is not meant as challenge to employee’s personal views or their lifestyle, but as a company, it is important to speak as one...
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Foreign Business Representatives: Some Red Flags
March 18, 2011 Added by:Thomas Fox
Businesses look to the value obtained in the use of a foreign business representative. This simple economic analysis is not sufficient in the FCPA context. There should be a separate analysis on whether the foreign business representative has the substantive skills to perform the services requested...
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Documentation and the TRACE Due Diligence Guidebook
March 12, 2011 Added by:Thomas Fox
Many companies focus on the specifics of a best practices FCPA compliance program, we believe they should also make documentation an over-arching principal in their compliance programs. Everything done or performed within the context of your FCPA compliance program should be documented...
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FCPA Risk Assessments and Current Best Practices
February 26, 2011 Added by:Thomas Fox
The key point is that a Risk Assessment is absolutely mandatory and must be used as a basis for the design of an effective compliance policy. If a Risk Assessment is not used, it might be well nigh impossible to argue that your compliance program meets even the basic standards...
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Internal Controls Under the FCPA
February 11, 2011 Added by:Thomas Fox
Generally speaking, Internal Controls are policies, procedures and training which are installed to safeguard that a business’ assets are utilized in an appropriate manner; with proper oversight and approval and that all company transactions are properly recorded in its books and records...
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Evaluation of FCPA Compliance Training
February 04, 2011 Added by:Thomas Fox
Review the documentation of training attendance and confirm. Make your department, or group leaders, accountable for the attendance of their direct reporters and so on down the chain. Evidence of training is important to create an audit trail for any internal or external assessment...
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Being a Great Compliance Leader
January 28, 2011 Added by:Thomas Fox
If a leader stops growing and improving they run the risk of becoming a terrible boss. Most managers stop working on themselves at some point in their career. Many managers are afraid of failure and this leads to a fear of change. Others do not receive proper training or support from their companies...
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Is Your FCPA Compliance Program a Good Business Model?
January 21, 2011 Added by:Thomas Fox
Companies need to be aware of developments and enhance their compliance program to meet these evolving standards. Authors Casadesus-Masanell and Ricart have provided a valuable guide for the FCPA compliance practitioner about how to set up a compliance business model for a company...
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Franchising and the FCPA
January 15, 2011 Added by:Thomas Fox
Even if it is not the US franchisor’s own employees which engage in the FCPA violations, the US franchisor will still face the risk of an enforcement action if the franchisee’s employees engage in such conduct...
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Top Ten FCPA Investigations of 2010
January 07, 2011 Added by:Thomas Fox
While enforcement actions can provide the DOJ/SEC's current thinking on FCPA compliance best practices, the public information made available during investigations can provide compliance professional many opportunities for teaching points and lessons learned by others...
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The FCPA: Mergers and Acquisitions
January 01, 2011 Added by:Thomas Fox
The clear trend in FCPA enforcement is an increased and aggressive level of enforcement activity under the both the DOJ and Securities and Exchange Commission. Businesses must be particularly heedful in the engaging in the mergers and acquisitions process, whether acquiring other companies or being acquired...
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Volkov’s Proposal for an FCPA Self-Compliance Program
December 17, 2010 Added by:Thomas Fox
At the FCPA hearings on November 30 before the US Senate Judiciary Committee, Subcommittee on Crime and Drugs, Michael Volkov (an Infosec Island contributor) presented an interesting idea which he believes will maximize incentives for companies to comply with the FCPA...
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FCPA Compliance Due Diligence
December 11, 2010 Added by:Thomas Fox
Most companies are not created out of new cloth but are ongoing enterprises. They need to bring resources to bear to comply with the FCPA while continuing to do business. This can be particularly true in the area of performing due diligence on foreign business partners or vendors...
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How To Risk-Base Supply Chain Vendors Under FCPA
November 25, 2010 Added by:Thomas Fox
The Supply Chain probably does not command your Compliance Department attention as do other types of third party business partners. This may be coming to an end as most Compliance Professionals recognize that third parties which supply goods or services to a company should be scrutinized...
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- Over-Sharing Riskier than Government Snooping
- 20 Critical Security Controls: Control 13 – Boundary Defense
- Redefining Social Networking
- Creating Your Own Privacy & ROI
- Security Intelligence for the Enterprise - Part 1
- Why are Cybercrimes NOT Always White-collar Crimes?
- From the SMB to Security Guru: Five Ways IT Pros Can Manage Security on a Budget
- Balancing Act Between Privacy and Security
- The NSA’s Word Games Explained: How the Government Deceived Congress in the Debate over Surveillance Powers
- NSA Surveillance Is Legal And Not Targeting Average Americans, Says Texas A&M Professor