There is a portion of the DOJ’s Evaluation of Corporate Compliance Programs that has received surprisingly little play in FCPA compliance circles. Under the heading “Risk-Based Training,” the DOJ poses a series of questions companies will need to answer.… Continue Reading
As much as compliance officers dream of unlimited staff and funding, the reality is that compliance departments often face the challenge of managing complex global risks with inadequate resources.
Last week I came across a gem of a post over on ACL’s in-house blog, about the future of internal audit. One of the senior executives there, Dan Zitting, was talking about the premium that recruiters now place on audit executives who understand data analytics — to the extreme that one recruiter told Zitting, “Frankly no one in management truly needs the services of the traditional auditor any more; what they need is the promise of Big Data to materialize.”… Continue Reading
I spoke with Aaron Murphy, author of the book, Foreign Corrupt Practices Act: A Practical Resource for Managers and Executives and, as of 2014, a partner in the litigation practice of Akin Gump Strauss Hauer & Feld LLP’s office in San Francisco.… Continue Reading