Keeping the cards close to the vest is not the best strategy for casinos trying to avoid being used as money laundering outlets. Rather, transparency trumps secrecy. This is particularly true for casinos operating in the Asia Pacific region.
8 Questions Directors and Senior Management Should Ask About Their Company’s Anticorruption Compliance Efforts
July 24, 2012 with Elizabeth Robertson and Amy L. Sommers
In the wake of continuing press reports about the role of bribery in international commerce, many corporate directors and senior executives are asking for a fresh look at their company’s exposure to the risks of violating the U.S. FCPA, the U.K. Bribery Act, and similar laws around the world. A team of K&L Gates attorneys have identified eight key questions that should guide the thinking of corporate directors and senior managers in evaluating their company’s anticorruption compliance measures.
Tone at the Top: Strong Links for Effective Risk Management
July 6, 2012
As the saying goes, a chain is only as strong as its weakest link. This adage rings true in many situations. In regard to risk, for example, there are countless points at which various individuals might contribute to the overall strength of an organization’s management of risk. The antithesis of the “it’s-not-my-job” mentality, this mindset is all about a corporate consciousness [...]
Raising the Bar: Integrating Internal Controls in a Tough Defense Environment
May 8, 2012
As part of the Compliance Done Right series that spotlights those corporations and compliance teams and professionals that are doing something right, here is a case study on how BAE Systems integrated internal controls.
Morgan Stanley Gets Thumbs Up From DOJ & SEC For Best Practices Compliance Program
May 3, 2012
Thomas Fox reviews the FCPA violation allegations against Morgan Stanley’s former managing director Garth Peterson and why the DOJ and SEC chose not to prosecute the company.
Incorporating the Fraud Triangle into Compliance Risk Assessments: The “Perception” Factor
May 1, 2012
John Hanson wraps up his series on the Fraud Triangle, today focusing on the perception factor, which though not part of the Fraud Triangle, may be an overriding factor in a person’s decision whether to violate a compliance policy, act unethically or commit a fraud, even when risk levels are high within the three Fraud Triangle factors.
The Biomet SEC Complaint: Lessons for Management on the Prevention of Corruption
April 19, 2012
In today’s post we revisit the Biomet deferred prosecution agreement. As you may recall, one of the major failings of the company, which led to the violations of the Foreign Corrupt Practices Act were those of the company’s internal audit department. I asked my colleague Henry Mixon, CPA and FCPA internal controls specialist, for his [...]
Incorporating the Fraud Triangle into Compliance Risk Assessments: The “Opportunity” Factor
April 6, 2012
In Part 1 of this series, John Hanson provided an overview of the Fraud Triangle and how incorporating it into compliance risk assessments can improve a compliance program’s assessment and prioritization of compliance risks. Now he focuses on the “opportunity” factor of the Fraud Triangle and provides some practical ways to incorporate this factor into a larger compliance risk assessment.
Behind the Standards: Clarifying SAS 70’s Confusing Departure
March 16, 2012
The demise of SAS 70 audits raises questions, confusion and a dose of drama. To gain clarity on the auditing standard’s replacement and its alternatives, it helps for service providers and their customers to understand what went on behind the scenes that caused in this change
Compliance Rocks: Adele is Phat (And Teaches Compliance Lessons)
February 13, 2012
I was watching the Grammy Awards show last night and found my love for Adele Adkins thoroughly validated. She is phat. Not “f-a-t” of course but “p-h-a-t” – i.e., urban slang for very attractive or appealing. I know, I know. It’s a really bad play-on-words in light of the unfair controversy over her appearance. I [...]
