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
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
In addition to establishing an ethical environment, board members and management must also take the lead in implementing and maintaining a formal fraud risk management program. One key element of such a program is a fraud risk assessment.
The risks provided are not based on theory, but rather what I am seeing in practice. I also focused on those risks that might not be so obvious?