Corporations’ internal auditors are increasingly becoming involved in anti-corruption compliance efforts. As Kara Brockmeyer, Chief of the SEC’s FCPA Unit, stated last year, “a company’s compliance and internal audit should be the first line of defense against corruption, not part of the problem.” Indeed, in many recent FCPA enforcement actions, the SEC and DOJ have specifically highlighted the failures or successes of the defendants’ internal auditors, as well as the actions of employees who have attempted to mislead a company’s internal auditors.
Yesterday, I moderated a very interesting webcast that examined the internal audit function in the context of anti-corruption compliance. A panel consisting of leading FCPA and SEC enforcement attorneys from law firm Gibson Dunn & Crutcher (F. Joseph Warin, John Sturc and John Chesley) and an expert in internal audit from KPMG (Peter Bradford) analyzed internal audit’s current place at the “hot corner” of FCPA enforcement. Topics of discussion included issues such as anti-corruption compliance risk assessments, internal investigations, and post-enforcement remediation. The webcast was capped off with a lively Q&A session.
