Search results for: "accounting controls"
Internal Accounting Controls and Cyber Risk
Today I want to return to that recent enforcement action against RR Donnelley, where the Securities and Exchange Commission cited faulty internal accounting controls at Donnelley as grounds to impose a $2.1 million sanction over the company’s poor handling of a cybersecurity incident. What are internal control professionals supposed to make of an enforcement action…
Read MoreAccounting Controls: A Hollywood Tale
Sometimes the importance of internal accounting controls can be a little hard for compliance professionals to grasp, but fear not! A crazy tale from Hollywood this week gives us a great example of why internal controls matter and what can go wrong when they’re not working properly. The tale comes from Tom Hollander, the fairly…
Read MoreAnother Lesson on Accounting Controls
Royal Bank of Canada has settled charges with the Securities and Exchange Commission over poor accounting controls for software development, which might sound super nerdy — because it is, really — but the case also lets us ponder yet again the importance of a strong control environment. The SEC announced the case late last week.…
Read MoreA New Corporate Enforcement Policy
Another day, another corporate enforcement pronouncement from the U.S. Justice Department. This time the memo comes from the Criminal Division, which again repeats the mantra, “If you companies should self-disclose, cooperate, and remediate, we won’t prosecute you!” but there are a few nuances that compliance officers will want to consider. The Justice Department announced the…
Read MoreADM Settles Fraud Case for $40M
Food giant Archer Daniels Midland has settled accounting fraud charges with the Securities and Exchange Commission, agreeing to pay $40 million in penalties for sketchy financial reporting moves in the early 2020s that artificially inflated the earnings of a supposed high-growth operating division. Internal control and anti-fraud folks, we have lots to review here. The…
Read MoreFresh Help on Bribery Risk Indicators
Good news for anti-corruption enthusiasts! Five law enforcement agencies around the world have published fresh guidance on indicators of foreign bribery, to help you focus your anti-corruption risk assessments and be sure that your compliance program has the right structure and resources to tackle the threat. The guidance was released just before Christmas by the…
Read MoreMore Musings on FCPA Enforcement
I wanted to share more thoughts today about President Trump’s order to pause all enforcement of the Foreign Corrupt Practices Act. Lots of corporate compliance professionals have been talking about it — and while nobody has any clear sense yet of what comes next, we do have a better sense of the important questions to…
Read MoreEntergy Pays $12M on Poor Controls
Pull up a chair, SOX compliance professionals! Utilities giant Entergy Corp. just settled an accounting controls case with the Securities and Exchange Commission that offers several lessons about oversight of accounting processes and the failure to address weaknesses in a timely manner. The settlement was announced last Friday. Entergy is paying $12 million to settle…
Read MoreSome Reminders on Fraud Risk
Last week a former employee of Takeda Pharmaceuticals was sentenced to prison for a multi-million dollar embezzlement scheme against the company. The case is a good reminder that companies will always need strong internal accounting controls no matter what regulatory changes might happen in Washington, so let’s take a look. The ex-employee at the center…
Read MoreTelefónica Pays $85M on FCPA Fails
The Latin American telecom giant Telefónica settled FCPA charges late last week, paying $85 million and reminding everyone that at least for now (and possibly for a good long while yet), the world of corporate compliance and FCPA enforcement continues to turn. Let’s take a look at the lessons we can learn here. The Justice…
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