The Treasury Department’s Office of Foreign Assets Control fined a California-based cosmetics company nearly $1 million for importing fake eyelash kits that contained materials from North Korea.… Continue Reading
The name sounds objective and exact — even scientific. The internal controls provisions. But in real life, how do internal controls measure up? Do they work?
To review — the FCPA requires issuers to devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that all transactions are properly executed and recorded and all assets are accounted for.… Continue Reading