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FCPA Compliance Report

Tom Fox has practiced law in Houston for 30 years and now brings you the FCPA Compliance and Ethics Report. Learn the latest in anti-corruption and anti-bribery compliance and international transaction issues, as well as business solutions to compliance problems.
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Jul 29, 2017

I conclude this section on the COSO 2013 Internal Controls Framework by considering what COSO says about assessing compliance internal controls. In its Illustrative Guide, entitled “Internal Controls – Integrated Framework, Illustrative Tools for Assessing Effectiveness of a System of Internal Controls” (herein ‘the Illustrative Guide’), COSO laid out its views on “how to assess the effectiveness of its internal controls”. It went on to note, “An effective system of internal controls provides reasonable assurance of achievement of the entity’s objectives, relating to operations, reporting and compliance.” Moreover, there are two over-arching requirements that can only be met through such a structured post. First, each of the five components are present and functioning. Second, are the five components “operating together in an integrated approach”. One of the most critical components of the COSO Framework is that it sets internal control standards against those which you can audit to assess the strength of your compliance internal control. 

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