Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly and I go into the weeds about the Ericsson FCPA enforcement action from the internal controls perspective.

Some of the highlights include:

Ø What does this enforcement action tell up about internal controls?

Ø How were the business units able to evade internal controls for so long?

Ø Was there control override?

Ø What is the role of ERP systems such as Oracle and SAP in compliance?

Ø If a company refuses to use standard ERP systems, is that a control failure under the FCPA?

Ø What are the lessons learned for a corporate compliance program?

Ø What does all this mean for compliance professionals going forward?

Resources

Tom’s blog posts, both the FCPA Compliance and Ethics Blog.

Part 1-Overview

Part 2-The Bribery Schemes

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Ericsson from the Internal Controls Perspective