Cody Worthington | Contributing Editor
J. Cody Worthington is a Senior Manager in the Forensic Investigations group at Johnson Controls International plc, based in Glendale, Wisconsin.
When choosing transactions to test as part of anti-bribery assessments, the usual suspects include expense accounts like consulting, marketing, promotions, commissions, or miscellaneous. Other expense accounts are selected based on the nature of the company’s business, risk factors or descriptions of the account.
I finished my first FCPA investigation in 2007 and sought to learn more about this uniquely American law and its requirements.