internal controls

keyboard

The 10 Most Important FCPA Internal Controls (Part One: Accounting Controls)

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, ...

strong risk management

Tone at the Top: Strong Links for Effective Risk Management

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 […]

fraud triangle opportunity

Incorporating the Fraud Triangle into Compliance Risk Assessments: The “Opportunity” Factor

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 ...