For the compliance practitioner there are several clear lessons to be drawn from this horrific scandal. Most people have somewhere heard the journalistic technique of a second source to confirm information. It was enshrined in a scene from the movie version of All The President’s Men. In any process there must be validation of said process. You can easily remember this as ‘a second set of eyes’ on any process, compliance or other. It acts like a second source in that it validates the original information.
In the more formal world of internal controls, it is called ‘segregation of duties’. This technique acts to require a double check of any action by requiring a second set of eyes to take a look at an issue. In business the separation by sharing of information with more than one individual in one single task is an internal control intended to prevent fraud and errors….
‘Enforcement 40’ for 2020
Join Us On LinkedIn
Join the Securities Litigation and Enforcement Group on LinkedIn