Internal controls have long been an overlooked requirement under the U.S. Foreign Corrupt Practices Act. This e-Book, written by Tom Fox, Compliance Week columnist and award-winning writer on FCPA issues, is a guide that compliance officers can follow to navigate the complexities of internal controls, to help mitigate the risk of violating the books-and-records provisions of the FCPA.

Produced by Compliance Week in cooperation with Workiva, the book has three chapters. The first chapter, “What are internal controls?” introduces the concept of internal controls, geared for legal or compliance professionals who have little formal training in audit or internal control operations. Fox provides examples of internal controls in an anti-corruption context.

In Chapter 2, Fox introduces the most common framework used today to create and implement internal controls: the COSO framework of 2013, with its 17 principles of effective internal controls. Then follows a white paper from Workiva that discusses how to conduct a risk assessment and then implement internal controls for international operations.

In Chapter 3, “Assessing Compliance Internal Controls,” Fox uses the COSO Illustrative Guide to its 2013 framework to show the integrated approach a compliance officer can use to assess the strength of a company’s internal controls.

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