It’s the day before a Fourth of July weekend and the General Counsel (GC) of a Securities Exchange Commission (SEC) registrant requests an urgent meeting with the Chief Compliance Officer (CCO) and the Vice President of Internal Audit (VP-IA).
The GC tells the stunned executives that a whistleblower has come forward with allegations that bribes, disguised as consulting fees, are being paid by the company’s South Korean subsidiary. How, the GC asks, could this have happened, when the compliance and internal audit teams performed what appeared to be a thorough anti-corruption compliance audit in Seoul just last year?
What do you think happened? Let’s analyze.