FCPA Settlement - Petrobras Board Involved

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Third Party Red Flags

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FCPA - “A Better Life, a Better World” Well Maybe Not Yet for Panasonic Avionics

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Internal Control Defined and Some Guidance

Compliance officers talk about controls constantly. Effective controls are the lifeblood of what makes a compliance program work. Most of us can rattle off examples of controls, or recognize a control when we see one.
So my fellow speaker asked the audience: What is a control?
Nobody dared answer. We all, me included, were suddenly uncertain that we could define a control correctly.
The speaker who posed this question is Jonathan T. Marks, partner at Baker Tilly and a prolific thinker on all things forensics, audit, and internal control. Lately Marks has been asking audit and compliance audiences to define a control — and to his dismay, most people can’t.Read Marks’ definition of internal control.

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How GDPR Could Impact Whistleblowers and the Ethics Hotline

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It's a Hit! Third Party Due Diligence

Why do due diligence? The “knowing” standard of the US Foreign Corrupt Practices Act (FCPA) makes a company equally liable whether an improper payment is made to a “Foreign Official”¹ directly or through a third-party, such as an agent, distributor, reseller, or sub-contractor. To minimize their exposure to potential sanction under anti-bribery and corruption regulations such as the FCPA, companies need to apply appropriate due diligence, taking a proportionate and risk-based approach.
Potential due diligence efforts include direct requests for details on the background, expertise, and business experience, of relevant individuals. It is also important to know whether you are dealing with a Politically Exposed Person (PEP) or a State Owned Enterprise (SOE).

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13 Step FCPA Compliance Action Plan

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Audit Committees, Internal Audit, and Fraud Risk

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