internal controls - Volkov Law

Podcasts

Episode 332 -- Deep Dive into SEC's Internal Controls and Cybersecurity Settlement with R&R Donnelly

In a significant expansion of internal controls enforcement, the SEC announced a $2.1 million settlement with R.R. Donnelley & Sons Co. ("RRD") for its handling of a 2021 ransomware attack and resulting disclosure failures. The settlement represents the SEC's first application of its internal

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Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants

Flutter Entertainment, the previous owner of PokerStars, agreed to pay the Securities and Exchange Commission $4 million for improper payments to Russian-based consultants, stemming from conduct committed by The Stars Group, PokerStars previous owner. Flutter purchased PokerStars in 2020. Flutter is an Ireland-based global gaming and sports betting

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The Importance of Accounting and Internal Controls (Part I of II)

Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records and internal controls. When it comes to bribery, wrongdoers have to find ways to “steal” or gain

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Oracle Joins Ranks of FCPA Recidivists: Settles SEC Case for $23 Million (Part I of II)

Oracle Corporation settled its second FCPA case in ten years. Oracle agreed to pay $23 million to resolve allegations that its subsidiaries in Turkey, India and the United Arab Emirates maintained slush funds to bribe foreign officials. Ten years ago in 2012, Oracle paid the SEC $2 million creating millions

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Compliance Program Monitoring, Testing, Audits, Assessments and Continuous Improvement (Part I of IV)

Chief compliance officers have a lot of issues to balance on their plate. Experienced CCOs know that it is not possible to complete every objective, balance every changing risk, and continuously improve their respective compliance programs on a real-time basis. If you review the Department of Justice's

Podcasts

Episode 226 -- A Deep Dive into KT Corp's SEC Settlement for FCPA Violations

The SEC announced the first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay $3.5 million in civil penalties and $2.8 million in disgorgement. KT Corp.

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KT Corp. Settles SEC FCPA Case for $6.3 Million (Part I of III)

The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay $3.5 million in civil penalties and $2.8 million in disgorgement. KT Corp.

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Building an ESG Structure and Program (Part II of III)

Investor demand for companies to provide robust and transparent ESG information is growing quickly. Investors understand that companies have to develop effective strategies to address ESG risks. The impact on shareholder price is evident – stakeholders are demanding that companies devote time and attention to ESG issues. Companies have to respond

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WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate acquisition targets into existing compliance programs. At bottom, WPP and its subsidiaries lacked any culture of compliance.

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Spring Cleaning: Time to Review Your Internal Controls

There are a lot of so-called "dirty secrets" in the corporate governance world. Not the tawdry kind that appear to follow controversial politicians – I mean in the world of internal controls. I would wager that most companies cannot even identify all of the policies, procedures and controls