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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Bill Steinman
Contributing Editor

Do internal controls have a fatal flaw?

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

And the big compliance story for 2019 is . . . .

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