Audit Committee Responsibilities Before, During and After Anti-Corruption Investigations: Five Steps to Take Before the Investigation Begins (Part One of Four)

The audit committee of a multi-national company has a front-and-center seat for an anti-corruption investigation and the host of unwelcome consequences that can accompany that investigation: multi-million dollar legal bills, media scrutiny, civil litigation and potential civil and criminal sanctions for the company.  The role of an audit committee member is a high-stakes one – he or she can be instrumental in putting the company in the best position if a potential violation is detected and an investigation is needed and can also be held personally liable if a serious violation occurs.  In a four-part series, the Anti-Corruption Report is examining fundamental questions regarding the audit committee’s role in internal investigations.  This article, the first in the series, outlines the responsibilities of the audit committee, describes the risks and liabilities the audit committee faces and articulates five steps the audit committee should take before there is cause for investigation.  See also “Five Tools Every Chief Compliance Officer Needs for Effective FCPA Compliance: Title, Authority, Access, Budget and Culture (Part One of Two)” (Apr. 3, 2013); Part Two of Two (Apr. 17, 2013).

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