The speaker was a national partner in a big accounting firm. What he said was simple and profound: "When it comes to internal controls, ask yourself how long it would take to detect an improper payment. Would it take a year, a quarter, or a month? That's how you test your company."
In September, when the Serious Fraud Office was still planning for roll out of the Bribery Act around now, Vivian Robinson QC, General Counsel for the SFO, recorded a webcast discussing the new law and how to comply with it.
Keeping tabs on international operations within global businesses has become extremely challenging. Our evolving economy is exciting and enticing, but varying languages, cultures and, most importantly, business practices add complexity to managing FCPA compliance.
On March 24, Ball Corporation, an Indiana corporation based in Broomfield Colorado, paid a $300,000 penalty to settle civil FCPA books and records and internal control charges brought by the the SEC.
As reported today by Ellen Podgor on the White Collar Crime Prof Blog, the case against GlaxoSmithKline's former VP and associate general counsel has been dismissed without prejudice.
The Mexican woman held in a California jail since her arrest on FCPA charges in August has alleged that prosecutors tried to bury information about intercepted phone and email logs from her lawyers and violated her attorney-client and spousal privileges.
Next week the World Compliance FCPA Tour, which we're pleased to be a part of, will be in Colombia -- Bogota, Barranquilla, and Medellin -- hosted there by AmCham.
A correspondent in LA sends the following dispatch from the courtroom about yesterday's action in the Lindsey case. . . .
Two recent cases have focused attention on the hard choices faced by company counsel involved in criminal investigations and prosecutions.