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.
I recently wrote about the importance of effective internal controls under FCPA enforcement. That’s the rear-facing focus for Janus as he related to compliance officers. But Janus looks forward as well, and I suspect that one thing we will see for FCPA enforcement going into 2015 and beyond is that the Securities and Exchange Commission will use the COSO framework to evaluate corporate internal controls that may be in question during an anti-bribery probe.
