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More Sarbanes-Oxley Anniversary Thoughts

The day my OpEd in the Financial Times was published, July 30, there were many other stories in other publications marking the occasion of Sarbanes-Oxley's tenth anniversary. Most of them focused on the lack of prosecutions of CEOs and CFOs for false financial statement certification crimes....

Board of Directors and FCPA Oversight – An Internal Control Under SOX, Part I

Today we begin by honoring the political process and a politician extraordinaire. In September of 1836, Sam Houston was elected as the first President of the Republic of Texas. One of the most interesting characters from the early-to-mid-19 th century, Houston was born in Virginia in 1793, moved with...

SOX, the Destruction of Evidence And Dr. Seuss: Is a Fish A Tangible Object?

Section 1519 was passed as part of the Sarbanes-Oxley Act in the wake of Enron’s massive accounting fraud. The section was designed to fill a gap in the law by preventing corporate document-shredding to conceal evidence of financial wrong doing. Prior law under Section 1512(b) prevented intimidating...