Compliance Week TV

 In our first Compliance Week TV video we hear from Frank Diana, executive vice president of enherent Corporation, who discusses the challenges involved in information management.
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This week’s podcast features Lucy Marcus, CEO of Marcus Venture Consulting, talking about shareholder and director activism, and how corporate executives can work with them more effectively. Hear the podcast now or …

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Webcasts of the Week

 Defining and Executing Systematic, Risk-Based Third-Party Due Diligence for FCPA Compliance
Sponsored by The Steele Foundation

Help Wanted: Ad of the Week

 Compliance Education & Communications Mgr.
Submitted by Oracle

Event of the Week

 Corporate Governance Programs
Courtesy of Harvard Business School

Thought Leadership of the Week

Access Management: Efficiency, Confidence, Control
Courtesy of SAP

The Resource Exchange

Code of Conduct
Submitted by BP

Sample Risk Acceptance Request
Submitted by Circuit City

Featured Databases

Whistleblower Guidelines
Search Whistleblower Policies, Contract Options

Class-Action Filings
Download Text of Class-Action Complaints

GRC Illustrated Series

 Improving GRC by Visualizing Your Data
The 24th Installment in This Exclusive Series

Recent Coverage Of Internal Control Issues (SOX 404)

Below is some of the most recent Compliance Week coverage related to the internal control provisions of The Sarbanes-Oxley Act, ubiquitously known as “Section 404 of SOX.” Includes extensive coverage of ICFR issues, including the PCAOB’s Audit Standard No. 5, and related audit and “top-down, risk-based” approach issues. See also The Resource Exchange for checklists, process maps, surveys, questionnaires, and other tools submitted by public company executives to assist them in complying with SOX 404.

  Title & Description Date Type of Article
1. Podcast: FCPA and Charitable Donations
We talk with Tom Fox, an independent FCPA compliance consultant and lawyer, about the Justice Department’s latest advisory opinion on the legality of “compelled giving” to charities overseas.
 		08/06/10 Compliance Week Coverage
2. Remediation Center: CCOs, Subsidiaries & Reporting Roles
At the request of subscribers, Compliance Week offers a Remediation Center, in which readers can submit questions—anonymously—to securities and accounting experts. Compliance Week’s editors will review all questions and then submit them—confidentially, of course—to specialists who can address the issues. The questions and responses will then be reprinted in a future edition of Compliance Week. Below is one of the Q&As; ask your own questions by clicking here.
 By Ellen Brotman
08/03/10 Compliance Week Coverage
3. SAS 70 Reports, in Harsh Spotlight Again
A recent analyst report is reminding the compliance community yet again that so-called SAS 70 reports—the supposedly formal assurances software vendors give to corporate customers about their own internal controls—aren't worth much more than the paper they’re printed on.
 By Melissa Klein Aguilar
07/27/10 Compliance Week Coverage
4. Podcast: New HIPAA Compliance Regulations
We talk with Tanya Forsheit, founder of and partner at the Information Law Group, about newly proposed rules for HIPAA compliance that will affect privacy, sub-contractors and more.
 		07/16/10 Compliance Week Coverage
5. Case Study: Abiomed Conquers Segregation of Duties
Like most small public companies, Abiomed Corp., a $73 million medical device maker, must meet all the same Sarbanes-Oxley internal control compliance requirements as most large public companies—but with quite fewer resources.
 By Jaclyn Jaeger
07/07/10 Compliance Week Coverage
6. Key Steps for Auditing the Legal Department
General counsels wield lots of power inside a corporation. They are the ones who translate legal mandates that influence how a corporation internalizes its compliance duties, and they have a huge range of daily tasks.
 By José Tabuena
07/07/10 Columns & Editorials
7. When to Consider Splitting CEO, Chairman Roles
The question of whether to combine the roles of board chairman and CEO or to separate them generates robust debate, with visceral feelings and often-strained relationships. Many institutional investors and leading governance experts, and indeed many sitting directors, argue in favor of splitting the jobs; many CEOs holding the chairman title insist their authority and the company itself would be badly damaged should they be forced to wear only one hat.
 By Richard M. Steinberg, Compliance Week Columnist
06/22/10 Compliance Week Coverage
8. Social Media Use in the Financial Industry
More and more, the financial services industry is realizing the business benefits of online social media tools—as well as the legal and compliance risks that come along with them.
 By Jaclyn Jaeger
06/22/10 Compliance Week Coverage
9. Paper Argues Alternatives to SOX 404 for Small Cos.
As smaller public companies hold out hope that Congress will exempt them from compliance with the external auditor provision of Section 404(b) of the Sarbanes-Oxley Act, an academic paper may provide ammunition to the exemption’s supporters.
 By Melissa Klein Aguilar
06/15/10 Compliance Week Coverage
10. Tips for Structuring the Compliance Department
The structure of corporate compliance departments has become a hot topic lately, thanks in particular to amendments to the U.S. Sentencing Guidelines that put a spotlight on compliance officer’s reporting authority and independence.
 By Melissa Klein Aguilar
06/08/10 Compliance Week Coverage
11. Succeeding With External Compliance Monitors
Any compliance officers out there who believe they have a hard time working with a government-appointed compliance monitor, be quiet. United Launch Alliance has a story that tops yours.
 By Jaclyn Jaeger
06/02/10 Compliance Week Coverage
12. Shop Talk: Managing Third-Party Risks
On April 22, 2010, Compliance Week and SAI Global presented an exclusive editorial roundtable about strategies for managing third-party risks. The roundtable, held at the Jefferson Hotel in Washington D.C., was moderated by Compliance Week Editor Matt Kelly and Christine Mills, senior vice president of SAI Global. Panelists included executives from Hewlett-Packard, Johnson Controls, Aramark Corp., among others. The following article provides readers with an in-depth look at their discussion.
 By Jaclyn Jaeger
05/11/10 Compliance Week Coverage
13. Study Finds Gap in Privacy Expectations, Delivery
Corporations are still failing to deliver on efforts to tighten up information security and consumer privacy, despite all the bad publicity and legal risks that they—and everyone else—are already painfully aware of, according to a new study on the problem.
 By Melissa Klein Aguilar
05/04/10 Compliance Week Coverage
14. Auditing the HR Function
Workforce issues such as recruitment, retention, diversity, and business conduct are often the expression of a company’s commitment to good values. A company with poor values is probably going to have confused and disgruntled employees. So it should be no surprise that human resource (HR) issues have been at the forefront of major business frauds or reputational breakdowns for years.
 By José Tabuena
05/04/10 Columns & Editorials
15. Podcast: Effective Corporate Training
This week we talk with Tom Yorton, CEO of Second City Communications, about how to make corporate training sessions more popular with employees and more effective.
 		04/30/10 Compliance Week Coverage
16. Survey: IT Risk, IFRS Are Internal Auditors’ Top Worries
A new survey of internal auditors finds that they are most concerned about improving their mastery of IT risks and global accounting standards, but seem to be less worried about their expertise in enterprise risk management.
 By Jaclyn Jaeger
04/27/10 Compliance Week Coverage
17. Podcast: Export Controls Reform
We chat with Doug Jacobson, a trade lawyer with the law firm Sandler, Travis and Rosenberg, about proposals to reform the U.S. export controls regime unveiled by Defense Secretary Robert Gates last week.
 		04/26/10 Compliance Week Coverage
18. Podcast: The Value of Commitment Controls
We talk with veteran internal control expert Timothy Leech about the idea of “commitment controls” to align employee behavior with company objectives, and how such controls might fit into your control environment.
 		04/20/10 Compliance Week Coverage
19. Four Steps to Better Privacy Compliance
The floodgates of guidance about Massachusetts’ new data privacy regulations are officially open.
 By Jaclyn Jaeger
03/30/10 Compliance Week Coverage
20. Learning From Culture Mistakes at Toyota, J&J
Oh, how the mighty have fallen—or at least seen their reputations for quality products and “doing the right thing” for customers badly damaged. Let’s take a look at two recent high-profile cases.
 By Richard M. Steinberg, Compliance Week Columnist
03/23/10 Compliance Week Coverage
21. Split Opinions on Internal Audit Scrutinizing Compliance
Internal auditors and chief compliance officers appear to have differing opinions about the internal audit department’s ability to assess risk and compliance functions.
 By Jaclyn Jaeger
03/23/10 Compliance Week Coverage
22. Small Filers Struggle With Internal Controls Over Fraud
A large school of thought has developed to support the argument that non-accelerated filers should be exempt from compliance with Section 404(b) of Sarbanes-Oxley, which requires external auditors to review and attest to the strength of a company’s internal controls.
 By Melissa Klein Aguilar
03/16/10 Compliance Week Coverage
23. Getting Ready for the 2010 Proxy Season
Are you ready for the 2010 proxy season? Companies are faced with new rules for expanded disclosure of executive compensation and director experience in the proxy statement. They have more issues that will come under more scrutiny from more people, be they activist investors, proxy advisory services, pension and union funds, or the media. Here’s what you need to consider to be prepared for the proxy season ahead.
 By Louis M. Thompson, Jr., Compliance Week Columnist
02/17/10 Columns & Editorials
24. Study: Policy Management Needs Improvement
Compliance officers might be a bit dispirited by a new study of policy-management efforts in Corporate America, which shows that companies are making some improvements at the task but still struggling to achieve the mythical “effective” compliance program amid increasing regulation and tough budgets.
 By Jaclyn Jaeger
02/09/10 Compliance Week Coverage
25. Study: Cos. Still Lagging on Records Management
A new study of corporations’ records management programs paints a troubling picture of companies still struggling to keep pace with the huge compliance demands piling onto them, despite the strides made in the last several years.
 By Jaclyn Jaeger
01/26/10 Compliance Week Coverage
26. How to Manage Communication About Risks
Every corporate director knows he or she needs relevant information to carry out oversight responsibilities effectively. But it’s not easy to know exactly what that information should be, the form it should take, or where it should come from. Unfortunately, experience shows that too often boards of directors don’t sufficiently focus on these issues, get caught by surprise, and pay a high price.
 By Richard M. Steinberg, Compliance Week Columnist
01/20/10 Columns & Editorials
27. Chief Compliance Officer Now a Full-Time Job
Two new studies confirm what those tasked with oversight of corporate compliance probably already know: More and more often these days, the chief compliance officer’s job is a full-time, stand-alone gig, rather than a secondary duty one handles while wearing some other title.
 By Melissa Klein Aguilar
12/15/09 Compliance Week Coverage
28. Navigating Import-Export Compliance
Compliance executives at companies conducting business internationally may want to add a check of their import-export compliance policies to their to-do list. You might have more work to do on that front than you think.
 By Melissa Klein Aguilar
12/08/09 Compliance Week Coverage
29. Podcast: SAS 70 Audits
Compliance Week editor Matt Kelly talks with David Barton of UHY Advisers about SAS 70 audits for service providers, and the assurance those audits do—and do not—provide.
 		11/30/09 Compliance Week Coverage
30. Case Study: Small Alaska Utility Gets SOX Compliant
Doing business as an electric utility in Alaska has its special challenges, such as bad weather and sometimes-uncertain fuel supplies. But as the leaders of Chugach Electric Association, Alaska’s largest electric utility, will tell you, regulatory compliance is much the same there as in the Lower 48.
 By Todd Neff
11/10/09 Compliance Week Coverage
31. 404 Study Shows Little Automation Yet
Automated internal controls may be the buzzword for compliance with Section 404 of Sarbanes-Oxley, but most companies still rely on old-fashioned manual controls even today, nearly six years after 404 first started going into effect.
 By Melissa Klein Aguilar
11/03/09 Compliance Week Coverage
32. Why ERM Fails at Small Companies
In my 34 years of experience as an internal auditor, I’ve seen a wide variety of enterprise risk management control failures. And to my thinking, they all share one common denominator: a failure by the board or the CEO to implement an effective ERM program that addressed the right risks.
 By Bill Stephens
10/06/09 Compliance Week Coverage
33. Constructing a Privacy-Risk Assessment
At the request of subscribers, Compliance Week offers a Remediation Center, in which readers can submit questions—anonymously—to securities and accounting experts. Compliance Week’s editors will review all questions and then submit them—confidentially, of course—to specialists who can address the issues. The questions and responses will then be reprinted in a future edition of Compliance Week. Below is one of the Q&As; ask your own questions by clicking here.


By David Wood

10/06/09 Compliance Week Coverage
34. Maintaining Efficiency, Despite Cutbacks
“Doing more with less” sounds like a wise, if unwanted, business policy these days—right up until reckless cost-cutting alienates employees and weakens carefully crafted segregation of duties.
 By Jaclyn Jaeger
09/15/09 Compliance Week Coverage
35. Auditing Governance: It Can Be Done
A few columns ago, I posited the idea that you can develop an integrated approach to auditing corporate governance, risk, and compliance. First I explored auditing compliance, and the risk. Now I will conclude the series and explain (finally) how governance (the “G” in GRC) provides the foundation that binds these disciplines together in a coherent way.
 By José Tabuena
09/09/09 Columns & Editorials
36. Amid Anxiety, Red Flag Rules Take Effect
The Federal Trade Commission’s compliance deadline for its so-called Red Flag Rules has finally arrived, requiring banks and other creditors to have written programs in place to find, stop, and mitigate theft of consumers’ personal data.
 By Jaclyn Jaeger
07/28/09 Compliance Week Coverage
37. Podcast: Red Flag Rules
In this week’s podcast, Compliance Week editor Matt Kelly talks with Vita Zeltser, a corporate governance lawyer at the law firm Locke Lord Bissell & Liddell, about the impending compliance deadline for the Federal Trade Commission’s Red Flag Rules.
 		07/24/09 Compliance Week Coverage
38. Podcast: Spreadsheet Controls
In our latest podcast, Compliance Week editor Matt Kelly talks with Kurt Underwood, head of the IT control practice at consulting firm Protiviti, about spreadsheets and how to manage the risk to internal control that they present.
 		07/02/09 Compliance Week Coverage
39. Overseeing Subsidiaries’ Internal Controls for SOX
At the request of subscribers, Compliance Week offers a Remediation Center, in which readers can submit questions—anonymously—to securities and accounting experts. Compliance Week’s editors will review all questions and then submit them—confidentially, of course—to specialists who can address the issues. The questions and responses will then be reprinted in a future edition of Compliance Week. Below is one of the Q&As; ask your own questions by clicking here.


 By Brian Gramm, Milo Belle Consultants
06/23/09 Compliance Week Coverage
40. SOX Compliance in the Tech Sector
A KPMG survey of technology companies has found that the cost of Sarbanes-Oxley compliance is falling, the number of key controls shrinking, and, most surprisingly, the number of automated controls declining as well.
 By Todd Neff
06/16/09 Compliance Week Coverage
41. Podcast: Continuous Auditing
Compliance Week editor Matt Kelly talks with Norman Marks, vice president of governance for SAP Business Objects, about ”continuous auditing“ and how to implement such a program.
 		06/16/09 Compliance Week Coverage
42. Toy Story: Industry Mounts Compliance Campaign
Earlier this year, the toy industry knew it had a big problem: tough new product-safety rules barreling down the regulatory turnpike, and most toy businesses too small to manage compliance with those rules well.
 By Todd Neff
06/09/09 Compliance Week Coverage
43. Managing IT Controls for SOX Compliance
The Sarbanes-Oxley Act is considered by many to be the road to redemption for the past sins of Enron, WorldCom, and other corporate players who subverted the rules of business by using financial engineering to inflate the performance of their businesses. Advocates for SOX consider this legislation an approach to ensure corporate responsibility for financial reports. Others call it over-regulation at its best.
 By James Bone
06/02/09 Columns & Editorials
44. Achieving a Risk-Free Outsourcing System
Corporations face brutal economic conditions these days. To improve business performance, many have cut costs by outsourcing some of their business processes to cheaper labor, often based overseas.
 By Yanan Bledsoe
05/27/09 Columns & Editorials
45. Tips, Tactics, and Tools for Managing Disclosure Risk
For most corporate counselors and advisers, hardly a day passes now when we’re not talking or reading about the latest cautionary tales about risk assessment and management.
 By Rick Hansen
05/12/09 Columns & Editorials
46. Podcast: Generally Accepted Recordkeeping Principles
Compliance Week editor Matt Kelly talks with Robert Pulzello, treasurer of ARMA International, about the organization’s new Generally Accepted Recordkeeping Principles and how to put them into practice.
 		05/01/09 Compliance Week Coverage
47. Preventing Fraud in the Era of Budget Cuts
The cost-cutting craze sweeping Corporate America is leaving internal control systems full of holes that could be potential entry points for fraud, even as temptation to commit fraud is soaring, a new survey says.
 By Melissa Klein Aguilar
04/28/09 Compliance Week Coverage
48. As 404(b) Nears, Small Filers Hear Advice
Non-accelerated filers may still be hoping for yet another delay in full compliance with Section 404 of Sarbanes-Oxley, but the wise ones should prepare for the inevitable now rather than risk incurring more audit costs later this year.
 By Melissa Klein Aguilar
04/21/09 Compliance Week Coverage
49. Scoping Out an Audit of Privacy Programs
Any corporation of any size today must worry about privacy and information security. Protecting sensitive information has always made good sense, but most developed nations now have laws that restrict some uses of at least some types of data.
 By Dan Swanson, Compliance Week Columnist
04/07/09 Columns & Editorials
50. The Simple Truth Behind the Complex Idea of Risk
Perhaps nothing in business circles today generates more heated debate than risk and risk management—not only in financial institutions, but also in every industry, and from the lowest manager level to the boardroom.
 By Richard M. Steinberg, Compliance Week Columnist
03/24/09 Columns & Editorials

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