Fcpa Compliance Report

Today, New York Times columnist David Brooks’ thoughts on building and maintaining order inform our discussion on internal controls. In the area of internal controls, I believe it is incumbent to consider not only the most obvious risk areas for your internal controls but also the universe of potential transactions within the operations of a particular company. There is a clear need for rigor in your internal controls protocols and adherence to that rigor can increased operationalization around the internal controls a company should consider including gifts, travel and entertainment (GTE).  One area that companies need to be mindful of is corporate checks and wire transfers, in response to falsified supporting documentation, such as check requests, purchase orders, or vendor invoices. The Delegation of Authority (DOA) is a critical internal control. So, for example a wire transfer of $X between company bank accounts in the US might require approval by the Finance Manager at the initiating location and one off