Culture and Troubling Friends, Family, & Relationships…

Troubling Friends, Family, & Relationships With the recent frauds and bad acts in the news I can't help wondering who was recruited or jumped on the wagon to help perpetuate the misbehavior. Here are some thoughts for the board, audit committee, general counsel, compliance, and internal audit to consider. Fraudsters seek out those who share … Continue reading Culture and Troubling Friends, Family, & Relationships…

Audit Committee Primer on 3rd Party Risk Management

Every U.S. company conducting or seeking business abroad is subject to the Foreign Corrupt Practices Act (FCPA) and it's no secret that 3rd party issues still present the highest risk under the FCPA.  In fact, some say that 90%+ of reported FCPA cases involve third-party intermediaries! Yet many Boards and Audit Committees seem unsure as … Continue reading Audit Committee Primer on 3rd Party Risk Management

Chief Compliance Officer v. General Counsel – Should They Be Separate?

Copyright 2018  - Jonathan T. Marks Lack of separation of the CHIEF COMPLIANCE OFFICER (CCO) and the GENERAL COUNSEL (GC) has been cited as a cause of numerous corporate mishaps or failures.  In fact, separation is now the norm in Health Care organizations.  In spite of numerous recommendations to separate the two functions, there is … Continue reading Chief Compliance Officer v. General Counsel – Should They Be Separate?

Audit Committees, Internal Audit, and Fraud Risk

Audit committees (AC) are charged with overseeing financial reporting and audit processes in U.S. public companies.  Scandals in the pre-Sarbanes-Oxley Act of 2002 (SOX) era (e.g., Enron, Global Crossing, Tyco International, and WorldCom) demonstrated that corporate governance could be compromised, resulting in fraudulent financial reporting (FFR). Among the provisions of SOX, Section 407 required companies to … Continue reading Audit Committees, Internal Audit, and Fraud Risk

Board of Directors Guide to FCPA Compliance

Several years ago, Tom Fox was kind enough to post the “FCPA Compliance Overview and Action Plan” that I cobbled together based on my experiences. Since that time I have received many calls and e-mails for more information, so I decided to post it for others to consider using in practice. My goal is to continuously … Continue reading Board of Directors Guide to FCPA Compliance

March 9th, 2018, Fraud Symposium – Presented by the IIA Philadelphia Chapter & Moderated by Jonathan T. Marks

Time Speaker and Proposed Topic* 7:45 – 8:15 Registration and Continental Breakfast 8:15 – 9:30 Mark J. Nigrini will present on, “Digital Footprints”.  He is a faculty member at the College of Business and Economics at West Virginia University in Morgantown in the US state of West Virginia. Nigrini is best known for his work … Continue reading March 9th, 2018, Fraud Symposium – Presented by the IIA Philadelphia Chapter & Moderated by Jonathan T. Marks

Root Cause Analysis

Tom Fox podcast visits with Jonathan T Marks, CPA, CFE, on how to perform a root cause analysis and its uses in the remediation phase of a best practices compliance program. One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program … Continue reading Root Cause Analysis

Doing Compliance Master Training Miami, February 12 and 13, 2018

Tom Fox is partnering with Marcum LLP to put on a two-day Doing Compliance Master Class, which will be unlike any other class currently being offered. It will be held in Miami, FL on February 12 & 13, 2018. This Doing Compliance Master Class is not theory or analytical underpinnings of the FCPA. The focus … Continue reading Doing Compliance Master Training Miami, February 12 and 13, 2018

Skepticism – a Weapon to Fight Fraud

What is wanted is not the will to believe, but the will to find out, which is the exact opposite.” – Bertrand Russell, “Skeptical Essays,” 1928 Questions about professional skepticism – how to define it, how much is enough, what policies support it, and what practices diminish it – are perennial topics of concern among … Continue reading Skepticism – a Weapon to Fight Fraud

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