January is named for the two-headed Roman god, Janus, who looks to the future and the past. I thought this visual concept was an appropriate introduction for the subject of COSO, internal controls, and Foreign Corrupt Practices Act enforcement going forward.

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Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...