The IBM Case: FCPA Compliance Programs And Internal Controls

There was Congressional testimony last fall to consider possible modifications to the Foreign Corrupt Practices Act. In part the testimony focused on the issue of FCPA compliance procedures as a defense for a business organization. Under current practice those procedures are not a defense but mitigation...

Internal Controls under the UK Bribery Act and FCPA

Although much is still unclear about the implementation date, or the manner in which the UK Bribery Act will be enforced, it is clear that one of the important compliance functions which a company should implement is appropriate internal controls. The previously released Consultative Guidance had...