Segregation of duties: a practical matrix for mid-size firms
Segregation of duties (SoD) means splitting the critical steps of a process: initiation, approval, execution, recording, and review, so that no single person can both create and validate a risky transaction. A mid-size firm does not need five people per process. It needs three things: incompatible steps never held by the same person, a documented compensating control wherever headcount makes separation impossible, and an exceptions register that proves the gaps are governed rather than ignored.
DOJ FCPA priorities in 2025: what to expect in 2026
If you support a France or Spain headquartered group with any US touchpoints (US investors, US subsidiaries, USD payments, US-listed securities, or business routed through the US financial system), the US Department of Justice (DOJ) still matters for your anti-corruption program,
Fines for Non-Compliance Start Before the Penalty
The fine is announced on a Tuesday, but the company started paying for it months earlier, when Legal sent the first preservation notice and Finance froze a payment batch. That is the part most board reports miss. The public penalty is clean. One press release.
Customer due diligence questionnaires: mistakes that quietly kill deal trust
It’s 6:12 pm. Sales forwards a customer due diligence questionnaire and writes: “can you just fill this tonight? they won’t send the contract until it’s done.
5 due diligence questionnaire blind spots to fix at every due diligence level
Due diligence questionnaires are supposed to reduce risk. In practice, they often create two outcomes that compliance teams hate: The fix is not “a better questionnaire” in the abstract.