FCPA Reminders From Stericycle

Stericycle, the global medical waste giant, has agreed to settle FCPA charges against the company for widespread bribery in Latin America, giving the rest of us another case with lessons about the risks of rapid international growth and poor corporate culture. The settlement was announced Wednesday. Stericycle will pay $84 million in penalties to the…

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KT Pays $6.3M to End FCPA Case

KT

Compliance professionals have quite the FCPA case to consider this week, courtesy of the Securities and Exchange Commission hitting Korea’s largest telecommunications carrier with $6.3 million in penalties and disgorgement for all manner of corrupt practices in the 2010s. The company, KT Corp., has a long history of corruption. KT agreed to settle the SEC…

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SEC’s Interesting Remediation Example

lawyers

The Securities and Exchange Commission published a press release Friday afternoon that compliance professionals should welcome: news that a tech startup mired in financial fraud will not pay any monetary penalties, thanks to the company’s extensive cooperation and remediation.  We rarely see an announcement like this, where the SEC’s principal point is to discuss its…

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Notes on Assessing Your Internal Controls

internal control

One of the Securities and Exchange Commission’s senior enforcement officials gave a pep talk in Washington this week about the importance of internal controls, and how a company should evaluate its internal controls this winter as the world tries to prevail over the disruptions of covid-19. The official was Matthew Jacques, chief accountant in the…

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That Lawsuit Against J.P.Morgan

JP Morgan

As you might have already heard (because compliance is such a gossipy profession), last week a former compliance officer for J.P.Morgan filed a lawsuit against the bank, accusing executives there of retaliating against her because she was raising concerns about failures and weaknesses in the compliance program.  I spent the weekend reading the complaint, which…

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‘Master of Kickbacks’ and Credit Suisse

Credit Suisse

Compliance professionals have another large FCPA enforcement action to pore over this week, thanks to the perpetually struggling Credit Suisse and several economic development loans for the country of Mozambique that were, quite literally, soaked in corruption.  The headline, announced on Tuesday, is that Credit Suisse will pay $475 million to regulators in the United…

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Food for Thought From Kraft Heinz

Kraft

We have a fascinating enforcement action from the Securities and Exchange Commission to study, this time against Kraft Heinz Co., which is paying $62 million to settle charges that it committed accounting fraud with a bogus cost-savings scheme. The case is a glimpse into how strategic imperatives can pressure internal controls — and at least…

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Firm Fined on Loss Contingency Failures

contingency

The Securities and Exchange Commission has fined a Pennsylvania healthcare services firm $6 million for poor internal controls that allowed the company to keep looming lawsuit costs out of the financial statements, which in turn helped the company to meet Wall Street earnings expectations. The firm in question is Healthcare Services Group ($HCSG), which provides…

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Podcast: The Importance of ‘ITGCs’ 

internal control

Everybody understands that strong controls over technology are crucial to effective corporate compliance, governance, and external reporting — but not enough people (myself included) understand how those IT controls are supposed to work. So when the Institute of Internal Auditors recently announced a certificate in IT general controls, I was intrigued. What education need did…

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Another Look at Cybersecurity Shortcomings

disclosure

The other week the Biden Administration issued an executive order to improve cybersecurity across the federal government. Now we have a peek at just how bad numerous government agencies are at the task — and what steps they’re likely to take to improve the situation, which could affect government contractors providing IT services. Said peek…

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