LexisNexis® Legal Newsroom
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...

FCPA Lessons Learned-Failures in Internal Controls

We often write and speak on some of the lesson learned from enforcement actions brought by the Department of Justice (DOJ) under the Foreign Corrupt Practices Act (FCPA). We believe that companies can not only learn from the mistakes of others in implementing or enhancing their compliance program...

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

In Part I of this two-part post regarding a Board of Director’s Role in Foreign Corrupt Practices Act (FCPA) oversight from the internal controls perspective, I reviewed how a Board might have independent liability for its failure to act as an appropriate internal control as required by Sarbanes...