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

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