With statistics like these (pulled from the PwC 2014 Global Economic Crime Survey), it is more important than ever for companies to focus on an effective anti-bribery and anti-corruption program. That’s why ACL hit the road with PwC to put on a series of FCPA roundtables. We gathered a focused group of senior executives from Fortune 500 companies in Toronto, New York City, Washington DC, Chicago, and San Francisco to discuss their toughest FCPA issues.
After a delicious breakfast buffet and plenty of networking time, the PwC Forensics team and ACL Solutions Consultants led the discussions by focusing on topics such as recent trends in enforcement proceedings, lessons learned from recent cases and hallmarks of a good compliance program. Below is a summary of the key learnings:
At the end of these events, we asked the attendees to fill out a survey about the current state of their FCPA program.
Q: Does your organization have an enterprise risk assessment program that assesses the most urgent risks facing your organization, taking into consideration your strategic objectives, your entity structure and your regulatory environment?
A: 87% answered “Yes”
Q: Have you documented a comprehensive anti-bribery and anti-corruption framework of vulnerable process level risks and controls?
A: 72% answered “Yes”
Q: Have you implemented a continuous monitoring to test your control framework, material process areas, your agents and vendors by testing transactions across your enterprise?
A: 52% answered “Yes”
Interestingly, while almost 90% of the survey respondents have an enterprise risk assessment program, only half have a continuous monitoring program in place. This highlights a quote in PwC’s presentation:
“More often, we encounter companies with compliance programs that are strong on paper, but much weaker in practice.”
– Leslie Caldwell, Assistant Attorney General for the Criminal Division
October 1, 2014
Contact us today to learn about how you can strengthen your compliance program and protect your organization.
(Source: ACL Blog)