FCPAméricas Blog
Archive for Audits category:
“Empresas Fantasmas”: Detecting Phantom Vendors
9.07.2012
Speak to an Argentine about public corruption and he or she will probably invoke the term “empresa fantasma” at some point. Phantom vendors are a common form of facilitating bribery in Argentina, as noted in reports there. In fact, they are common in many parts of the world. Companies focused on FCPA compliance should be […]
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SEC: Local Language Essential to “Effective” FCPA Compliance
7.11.2012
What is the big lesson from yesterday’s $7.4 million SEC settlement with Lewisville, TX-based Orthofix, the latest FCPA action involving Latin America? The “FCPA Commentariat” will surely highlight how corruption risks are common in public procurement in countries like Mexico. FCPAméricas has written about that subject (The Anatomy of Corruption in Public Procurement) based on […]
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Three Concrete Ways in which FCPA Compliance Officers can Better Engage Operations
6.27.2012
One of the most difficult things about establishing an effective anti-corruption compliance program is getting the operations units of a company to take interest. Paper programs alone are insufficient. The Wal-Mart case and others tell us this. Instead, employees throughout a company must fully embrace compliance functions. And the business units are essential to putting […]
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Answers from Internal Audit on FCPA Compliance
6.06.2012
FCPAméricas recently asked the question: how does Internal Audit do it all at a time when FCPA practitioners keep asking it for more? Top executives at Compliance Week’s 2012 Annual Conference offered some helpful answers. Communication. In the audit world, relationships are key. Internal Audit teams that prioritize communication with other parts of the business […]
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An FCPA Question for Internal Audit: How do you do it all?
5.31.2012
Next week, I have the privilege of moderating a panel about “Running the Modern Audit Function” at Compliance Week’s 2012 Annual Conference. The panelists are an impressive group – senior executives from Starbucks Coffee, Intel, and Hasbro. What would one ask when given such an opportunity? As an FCPA attorney, I would ask this – […]