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Internal Accounting Controls and Internal Compliance Controls: What Public Companies Need to Know for Anti-Corruption, Sanctions, and Anti-Money Laundering Compliance Programs
Daniel Wendt, Member, Miller & Chevalier.
September 15, 2020
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Background on the FCPA's accounting provisions, including the requirement for public companies to maintain internal accounting controls
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A review of the internal accounting control failures noted in recent DOJ and SEC Resolutions, including FCPA issues, but also sanctions, commercial bribery, and money laundering
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Practical guidance for Compliance and Legal professionals at public companies for working across functions within companies to establish functioning internal controls that implement Compliance programs and minimize risk of SEC enforcement
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