In this episode, Matt Kelly and I explore last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide lessons for the compliance practitioner. We consider the enforcement action around the issue of internal controls, their effectiveness (or lack thereof) and management over-ride of internal controls.

For more information, see my blog posts:

Lessons in Failures of Internal Controls; and

Halliburton Resolves FCPA Enforcement Action