Search results for: management override
Management Override and Navy SEALs
Keeping pace with all the ethics and compliance lessons one can learn from the Trump Administration is no easy task. Nevertheless, we have yet another one: the perils of management override, as demonstrated by President Trump’s determination to keep a disgraced Navy SEAL in military service. The story evolved quickly over the weekend. It begins…
Read MoreAdvice on Third-Party Risk Management
Last week I had the good fortune to moderate a webinar on third-party risk management. We had outstanding guests who raised excellent points, and as usual, I ended up taking plenty of notes so that I could pass them along here. Let’s begin with an appreciation of just how tricky a problem third-party risk management…
Read MoreFresh Lessons on Management Fraudsters
One of the largest PR firms in the world is going through its own minor PR crisis this week, with its former CFO pleading guilty to embezzling $16 million from the firm over the course of nearly a decade. Frank Okunak, who ran financial operations at PR firm Weber Shandwick from 2009 to 2019, pleaded…
Read MoreConn’s Lesson on Management Estimates
Oh, look. Another accounting enforcement action from the SEC, where poorly designed internal controls led to management’s abuse of estimates. Everyone put on your shocked face. The SEC settled a case on Monday with Conn’s, a rent-to-own retailer based in Texas with $1.55 billion in annual sales. Conn’s agreed to pay $1.1 million in a…
Read MoreBetting/Bitcoin Biz Settles FCPA Charges
Federal prosecutors have sanctioned a one-time Chinese online lottery business turned bitcoin mining operation for violations of the Foreign Corrupt Practices Act, where senior executives bribed Japanese lawmakers in the late 2010s to win permissions to open a casino there — and good lord, writing that sentence feels like hitting some sort of corruption risk…
Read MoreA Tale of Two Monitor Decisions
One dreaded outcome from a regulatory investigation is the appointment of an independent compliance monitor. Now two recent corporate misconduct settlements demonstrate how puzzling regulators’ decisions about compliance monitors can be — because for the life of me, I can’t figure out why one company received a monitor while the other didn’t. The cases involve…
Read MoreSAP, Part II: Remediation Work
Today, let’s return to the FCPA enforcement action announced last week against German software giant SAP, which resulted in $220 million in penalties and disgorgement, plus a long list of compliance remediation measures. Those measures are worth going through in detail. For those who missed last week’s news, the recap is as follows. SAP agreed…
Read MorePCAOB Lists 2023 Inspection Priorities
The Public Company Accounting Oversight Board has released its list of priorities for audit firm inspections in 2023, in case any internal audit and financial compliance teams want to understand where your auditor is feeling the pressure and how that pressure might fall through onto you. The PCAOB releases such a list every spring after…
Read MoreSEC to Auditors: Do Better on Fraud Risk
The Securities and Exchange Commission is urging auditors to do better at assessing fraud risk among their clients — a rather notable statement peppered with keywords such as “gatekeepers” and “protection of investors,” clearly intended to warn audit firms that the agency wants to see improvement here. The statement came on Tuesday from Paul Munter,…
Read MoreFoster Wheeler’s FCPA Lessons
We have our first FCPA enforcement action of the Biden Administration: a $177 million punch against engineering firm Amec Foster Wheeler, for bribery involving overseas agents to win a contract with Brazilian state-owned oil giant Petrobras. The settlement was announced Friday by U.S. regulators and the parent company of Foster Wheeler, John Wood Group. Wood…
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