The Justice Department Thursday charged two former Herbalife executives with bribing Chinese officials for ten years and covering it up by lying to the SEC and destroying evidence.… 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
Nearly every corporate anti-bribery violation reveals problems with internal controls.
Again and again SEC enforcement actions describe devious employees who were able to subvert the controls and thereby create slush funds and pay bribes, or controls that were weak to begin with and incapable of detecting or stopping the corrupt actors.… Continue Reading