Fcpa Compliance Report

As they made clear with several FCPA enforcement actions in 2016, the SEC has placed a renewed interest in the accounting provisions of the FCPA, specifically the internal controls provisions. The BHP enforcement continued this trend, where there was no evidence that bribes were paid or offered in violation of the FCPA,  the poor internal compliance controls at BHP led to a $25MM fine. Indeed Kara Brockmeyer, Chief, FCPA Unit; Division of Enforcement of the SEC, reiterated that the SEC was committed to protecting investors in US public companies and those which list other securities in the US, through enforcement of the accounting provisions, including internal controls provisions of the FCPA. It would seem that the reason is straightforward; a company with rigorous internal compliance controls is better able to prevent, detect and remedy any FCPA violations that may occur. What can you do around the FCPA’s requirements for internal controls and current SEC emphasis? I would suggest that you begin with an exe