January 11, 2011 Note: The draft guidance is not prescriptive and does not detail specific anti-bribery measures, but instead adopts
Several years ago, Tom Fox was kind enough to post the “FCPA Compliance Overview and Action Plan” that I cobbled together
Tom Fox is partnering with Marcum LLP to put on a two-day Doing Compliance Master Class, which will be unlike
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?