Under the FCPA, companies can be punished not only for the wrongful things they do, like paying bribes, but also for certain things they don’t do. In particular, the FCPA’s accounting provisions require companies to have internal controls in place. When companies do not have certain protections, such as appropriate accounting systems and anti-corruption policies, procedures and processes, they risk violating the law.
Specifically, the FCPA’s accounting provisions require issuers (both U.S. and non-U.S. companies that are publicly traded in the United States) to esta Read More
Five Things the Audit Committee Won’t Tell Internal Audit -
Most audit executives work hard to develop open relationships with their audit committee members. The effort generally pays off. Regardless of how hard we work at fostering openness and honesty, however, some audit committee members may not be comforta...