Frequent, vigorous internal audits are a cornerstone of any robust corporate compliance and anti-corruption program. But merely having an effective audit team in place, which is no small feat, is not enough. A number of companies have been getting burned by the SEC and DOJ for not acting quickly enough after internal audits yielded evidence suggestive of FCPA violations or other internal control deficiencies. In a guest article, Steptoe & Johnson partner Matthew Herrington and associate Brady Cassis unpack the recent settlements revealing several strategies for successfully managing internal audits. For more from Herrington see “Developing Key Performance Indicators and Tracking Metrics for an Anti-Corruption Program (Part One of Two)” (Feb. 24, 2016); Part Two (Mar. 9, 2016).