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  • Article at CFO.com: When Your Compliance Program Fails

    The steps to take when an employee comes forward with a fraud tip, whether the allegations are false or not. By Tracy Coenen, Contributor to CFO.com You think your company has a robust compliance program to prevent financial-statement fraud, asset […]

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  • CFO Magazine: Creating a Culture of Compliance

    I was recently quoted in CFO Magazine for an article on creating an ethical culture within companies. Below are a few excerpts, including my comments. In December, the federal government cited a “lax corporate control environment” at Alcatel, which extended […]

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  • Dodd-Frank Whistleblower Rule Adopted by SEC Discourages Internal Reporting

    The Dodd-Frank Wall Street Reform and Consumer Protection Act, enacted on July 21, 2010, established a whistleblower incentive program requiring the Securities and Exchange commission to provide monetary awards to whistleblowers who come forward with information about the violation of […]

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  • Las Vegas Sands FCPA Investigation: What Did Management Do When they First Found Out About Allegations of Bribery and Corruption?

    Earlier this week, Las Vegas Sands (NYSE:LVS) announced in its 10-K for the year ended December 31, 2010 that it is the subject of an FCPA investigation: On February 9, 2011, LVSC received a subpoena from the Securities and Exchange Commission […]

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  • Financial Analysis in FCPA Cases

    This week I recorded a podcast for the International Association for Asset Recovery (IAAR), which is accessible on the IAAR site. We talked a bit about where financial investigations are going, and how I am using technology to complete these […]

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