General
Companies have to embrace a holistic management approach to their internal controls. In the corporate governance world, a new approach is needed to develop a more rational and consistent method for managing your company’s internal controls. This is not a radical proposal but a rational response to the enforcement
General
Laws control the lesser man --- right conduct controls the greater one – Mark Twain A company’s internal controls define the backbone of its operations, encompassing financial, operational and compliance functions. The FCPA defines requirements for publicly-traded companies to implement internal controls, including compliance controls. Under the internal controls requirements,
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The FCPA includes a specific requirement that a public company maintain an adequate set of internal controls. A company's compliance program is one component of a company's internal controls. Sarbanes-Oxley expended and reinforced this important requirement. The Department of Justice and the SEC have aggressively