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@jtmarkscpa
COSO ERM and Cloud Computing
COSO ERM and Cloud Computing
The Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) issued new guidance on enterprise risk management for cloud computing. This writing is designed to help organizations using COSO’s ERM framework to improve their cloud governance. Cloud governance helps and organization be better positioned to deal with risks that could impact its strategy and goals. Specifically, the…
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Governance, Fraud, and Corporate Culture: Sorting Through a Complicated Relationship
Governance, Fraud, and Corporate Culture: Sorting Through a Complicated Relationship
By Jonathan T. Marks, CPA, CFF, CITP, CGMA, CFE, NACD Board Fellow Background I recall being asked to perform a cultural risk assessment in late 2004 because certain members of a client company’s board of directors were concerned about communication and information flow. Specifically, they wanted to know if issues were being raised timely and appropriately and not extinguished by mid-level…
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Environmental, Social, and Governance or ESG
Environmental, Social, and Governance or ESG
ESG? Environmental, social, and governance (“ESG”) criteria are standards for a company’s operations that socially conscious investors use to screen potential investments. Recall that on March 4, 2021, The Securities and Exchange Commission (“SEC”) announced the creation of a Climate and ESG Task Force in the Division of Enforcement. Kelly L. Gibson, the Acting Deputy Director of Enforcement,…
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Internal Controls - 5 Step Process to Help Ensure Internal Controls are Designed Consistently and Appropriately
Internal Controls – 5 Step Process to Help Ensure Internal Controls are Designed Consistently and Appropriately
DEVELOPED BY ROBERT MAINARDI AND JONATHAN T. MARKS Background The concept of Internal Control appeared as a practice in the USA at the beginning of the 20th century, whereas in the economic literature began to be extensively approached after the ‘50s. The internal control concept originated in 1949 from the American Institute of Certified Public Accountants (AICPA), with a plan to coordinate…
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Ethics and Compliance: Active Board Involvement Is a Must
Ethics and Compliance: Active Board Involvement Is a Must
By Jonathan T. Marks, CPA, CFF, CITP, CGMA, CFE, NACD Board Fellow Establishing and supporting a corporate compliance program is widely recognized as one of the fundamental responsibilities of a corporate board of directors. But merely seeing that there is a compliance program in place is by no means an adequate effort. The Board must also actively oversee that function. Active oversight is…
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Governance: Board of Directors Effectiveness
Governance: Board of Directors Effectiveness
On February 26, 2021, The Board of Governors of the Federal Reserve System issued guidance on the “Supervisory Guidance on Board of Directors’ Effectiveness.” This guidance focuses on a board’s performance of its core responsibilities in describing five key attributes of an effective board. Although the guidance is directed to all domestic bank holding companies and savings and loan holding…
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Ethics - eSports Cheating
Ethics – eSports Cheating
Chinese police have arrested ten people connected to a video game cheating ring that made an outrageous $100 million in profit. Overview eSports can be defined as a multiplayer video game played competitively for spectators, typically by professional gamers, but has grown in popularity in colleges and universities. More than 50 colleges have varsity eSports programs governed by the National…
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Compliance: Let's Talk about FARA
Compliance: Let’s Talk about FARA
Overview The Foreign Agents Registration Act “(FARA”) was enacted in 1938. FARA requires certain agents (see definition below) of foreign principals (see definition below) who are engaged in political activities or other activities specified under the statute to make periodic public disclosure of their relationship with the foreign principal, as well as activities, receipts, and disbursements in…
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Fraud Tip Friday: Using Continuous Monitoring and Continuous Auditing to Enhance Compliance
Fraud Tip Friday: Using Continuous Monitoring and Continuous Auditing to Enhance Compliance
The DOJ and SEC have increasingly used data analytics to identify potential wrongdoing and have recently sent messages that companies should follow suit and incorporate data analytics in their compliance programs. How is this done? How can a company monitor the effectiveness of their compliance programs and identify potential misconduct? Using Data Analytics with Continuous Auditing and…
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Root Cause Analysis: A Critical Ethics and Compliance Practice
Root Cause Analysis!
By Jonathan T. Marks, CPA, CFF, CITP, CGMA, CFE and NACD Board Fellow “If you don’t ask the right questions, you don’t get the right answers. A question asked in the right way often points to its own answer. Asking questions is the ABC of diagnosis. Only the inquiring mind solves problems.” – Edward Hodnett When Edward Hodnett, author of “The Art of Problem Solving,” offered his thoughts on…
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Root Cause Analysis: A Critical Ethics and Compliance Practice
Root Cause Analysis: A Critical Ethics and Compliance Practice
By Jonathan T. Marks, CPA, CFF, CITP, CGMA, CFE and NACD Board Fellow “If you don’t ask the right questions, you don’t get the right answers. A question asked in the right way often points to its own answer. Asking questions is the ABC of diagnosis. Only the inquiring mind solves problems.” – Edward Hodnett When Edward Hodnett, author of “The Art of Problem Solving,” offered his thoughts on…
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FCPA Themes from 2020 with Compliance Commenatry
FCPA Themes from 2020 with Compliance Commenatry
Some Statistics The table and graph below detail the number of FCPA enforcement actions initiated by DOJ and the SEC, the statute’s dual enforcers, during each of the past ten years. Aggressive Internal Controls Enforcement It has been hiding in plain sight all along. The FCPA requirement that “reporting companies to devise and maintain a system of internal accounting controls sufficient to…
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Fraud Tip Friday: Fraud Risk Assessments Common Pitfalls
Fraud Tip Friday: Fraud Risk Assessments Common Pitfalls
Background Risk assessments are part of the discipline of risk management, where enhanced frameworks and techniques have emerged. Risk management comprises the identification, assessment, and prioritization of risks followed by the coordinated and efficient use of resources to monitor, minimize, and otherwise control the organization’s risks. Risks arise in many forms and range from uncertainty…
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The Continued Evolution of Best Practices for Compliance Programs!
The Continued Evolution of Best Practices for Compliance Programs!
Background There have been significant releases of information by the federal government which directly impacted compliance professionals. Two came from the Department of Justice and one came from the Department of Treasury, Office of Foreign Asset Control. This eBook will discuss them all in depth and provide a structure for the compliance practitioner to use guidance from all three cases to…
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Red Flags That May Indicate You Might be at Risk of Violating FCPA
Red Flags That May Indicate You Might be at Risk of Violating FCPA
Some FCPA Risk Exposure Questions If this is your answer, you might be exposed. Is your company buying or selling products or services internationally? Yes Are there any suspicions of FCPA violations by company personnel or third-party agents acting on the company’s behalf within any countries where the business is conducted internationally? Yes Do employees or third-party agents acting…
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CARES Act- First Civil Settlement for Fraud on Cares Act Paycheck Protection Program
CARES Act- First Civil Settlement for Fraud on Cares Act Paycheck Protection Program
“The defendants made false statements to multiple banks in order to obtain a Paycheck Protection Program loan that should have been disbursed to an honest small business suffering financially from the economic effects of the COVID-19 pandemic,” said U.S. Attorney Scott. “The Department of Justice and our partners at the SBA will use all tools at our disposal, including civil fraud statutes, to…
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SEC’s Enforcement Powers Increase!
SEC’s Enforcement Powers Increase!
Background Courts have been awarding disgorgement as an equitable remedy since the 1970s, on the assumption that securities laws provide courts with equity jurisdiction. However, the SEC’s authorizing statutes do not list disgorgement as an available judicial remedy. The SEC has express statutory authority to obtain “disgorgement” in enforcement proceedings it brings before its administrative law…
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