Lessons from False Claims Act Case Studies

Lessons from False Claims Act Case Studies

Importance of Annual Updates in Medical Coding

Medical coding is a critical component of the healthcare industry, serving as the bridge between clinical care and administrative functions such as billing and compliance. It involves the transformation of healthcare diagnoses, procedures, medical services, and equipment into universal medical alphanumeric codes. The importance of medical coding cannot be overstated, especially when considering its role in ensuring accurate billing and maintaining compliance with legal standards.


Effective staffing ensures appropriate resource allocation in healthcare settings medical staffing services dentist.

The significance of precise medical coding is underscored by examining cases related to the False Claims Act (FCA), which serve as cautionary tales for healthcare providers. The FCA is a federal law that imposes liability on individuals and companies who defraud governmental programs. Inaccurate or fraudulent medical coding can lead to false claims being submitted to government payers like Medicare and Medicaid, resulting in severe penalties including hefty fines and reputational damage.


One lesson from past FCA case studies is the necessity for rigorous training and oversight in medical coding practices. Many cases reveal that errors often stem from inadequate training or lack of understanding of complex coding systems among healthcare staff. This highlights the need for continuous education and certification programs to ensure that coders are well-versed with current guidelines and changes in regulations.


Another key takeaway is the importance of implementing robust audit systems within healthcare facilities. Regular audits can help identify discrepancies or patterns indicative of incorrect coding before they escalate into larger issues. This proactive approach not only aids in maintaining compliance but also enhances overall operational efficiency by preventing revenue loss due to denied claims or potential legal action.


Moreover, these case studies emphasize fostering a culture of transparency and accountability within organizations. Encouraging open communication about concerns related to billing practices can help uncover potential issues early on. An environment where employees feel empowered to report suspected inaccuracies without fear of retaliation can significantly reduce instances of fraud.


Furthermore, investing in technology solutions such as sophisticated electronic health record (EHR) systems can greatly improve accuracy in medical coding. Advanced software tools equipped with artificial intelligence capabilities can assist coders by flagging anomalies or suggesting correct codes based on patient records, thereby minimizing human error.


In conclusion, lessons from False Claims Act case studies illustrate that accurate medical coding is indispensable not only for efficient billing processes but also for adherence to legal standards. Healthcare providers must prioritize comprehensive training programs, establish effective audit mechanisms, promote transparency within their organizations, and leverage technology to enhance their coding practices. By doing so, they can safeguard themselves against legal repercussions while ensuring optimal patient care through reliable documentation practices.

The False Claims Act (FCA), a powerful tool in combating fraud against government programs, has been instrumental in holding entities accountable for false medical coding practices. Through several notable case studies, we can extract valuable lessons on compliance, ethics, and the consequences of fraudulent activities in the healthcare sector.


One pivotal case involved a major hospital chain that was found guilty of systematically upcoding-billing for more expensive services than were actually provided. This practice not only resulted in hefty fines but also highlighted the importance of accurate medical coding as a cornerstone of ethical billing practices. The lesson here is clear: healthcare providers must ensure robust internal auditing processes to prevent and detect inaccuracies in coding that could lead to FCA violations.


Another significant case involved a group of diagnostic laboratories accused of bundling services improperly. By unbundling these services and submitting separate claims for each procedure, they falsely inflated their billings to Medicare. This case underscores the necessity for comprehensive training concerning proper coding techniques and billing regulations. Healthcare organizations should invest in ongoing education for their staff to remain compliant with current laws and guidelines.


A third noteworthy example featured a pharmaceutical company that engaged in off-label marketing tactics, subsequently leading physicians to submit false claims unknowingly. This situation serves as a cautionary tale about the ripple effect one entity's actions can have throughout the healthcare system. It illustrates the critical need for transparency and strict adherence to approved uses of drugs when communicating with healthcare providers.


These cases collectively teach us that beyond financial penalties, reputational damage can be severe and long-lasting following FCA violations. Organizations implicated in such cases often face diminished trust from patients and partners alike, underscoring the broader impact of unethical practices.


Ultimately, these case studies reveal that vigilance is key; maintaining detailed records, conducting regular audits, providing thorough training, and fostering an organizational culture centered around integrity are all essential strategies to avoid falling afoul of FCA regulations. As we learn from past missteps within medical coding practices under FCA scrutiny, it becomes evident that commitment to compliance benefits not only individual entities but enhances overall trust within our healthcare systems.

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Key Changes and Additions to the Latest ICD-10-CM Code Set

The False Claims Act (FCA), a powerful tool in the fight against fraud, waste, and abuse in government programs, has been instrumental in uncovering various fraudulent practices over the years. Through numerous case studies, we can identify common schemes that perpetrators employ to deceive and exploit government funds. By examining these fraudulent practices, we glean valuable lessons for prevention and enforcement.


One prevalent form of fraud uncovered in FCA cases is billing for services not rendered. This deceptive practice involves submitting claims for medical procedures or services that were never provided to patients. For instance, healthcare providers might bill Medicare or Medicaid for phantom appointments or unnecessary tests. The motivation behind this scheme is often financial gain at the expense of taxpayer dollars. To counteract such fraud, it is crucial to implement robust auditing systems and encourage whistleblowers to report suspicious activities.


Another common fraudulent practice is upcoding, where service providers submit claims using codes that indicate more expensive procedures than those actually performed. This manipulation results in higher reimbursements from government programs like Medicare and Medicaid. Upcoding can be difficult to detect without meticulous review of patient records and billing statements. Therefore, training auditors to recognize discrepancies and anomalies in coding practices becomes essential in combating this type of fraud.


Kickbacks also feature prominently among fraudulent schemes revealed by FCA case studies. These unethical arrangements typically involve healthcare providers receiving financial incentives from pharmaceutical companies or other entities in exchange for prescribing certain medications or referring patients to specific facilities. Such kickbacks undermine patient care by prioritizing financial interests over medical necessity. To address this issue, stricter regulations and penalties are necessary to deter entities from engaging in such corrupt practices.


False certification is another tactic used by fraudsters to mislead the government into awarding contracts or grants under false pretenses. Companies may falsify qualifications or compliance with regulatory standards to secure lucrative contracts they would otherwise be ineligible for. Detecting false certification requires rigorous vetting processes during contract awards and regular compliance checks throughout the project's duration.


These case studies also highlight the importance of whistleblower provisions within the FCA framework. Many fraudulent schemes have been exposed thanks to insiders who reported malpractices through qui tam lawsuits-an avenue that allows individuals with knowledge of fraud against the government to file actions on its behalf. Whistleblowers play a critical role in uncovering complex schemes that might go unnoticed by external audits alone.


In conclusion, analyzing common fraudulent practices through FCA case studies reveals patterns that can inform preventative measures across industries reliant on government funding. Vigilance through comprehensive audits, stringent regulatory oversight, and incentivizing whistleblowers are key strategies for minimizing these deceptive activities' impact on public resources while safeguarding integrity within governmental programs.

Key Changes and Additions to the Latest ICD-10-CM Code Set

Impact of Updates on Healthcare Providers and Coders

In recent years, the healthcare sector has witnessed a surge in False Claims Act (FCA) cases, serving as poignant reminders of the legal and ethical obligations that healthcare providers must uphold. The FCA, originally enacted during the Civil War to combat fraud against the federal government, has evolved into a powerful tool for ensuring integrity in healthcare billing practices. As these legal battles unfold, they offer valuable lessons that every healthcare provider should heed to avoid similar pitfalls.


One of the primary lessons from FCA cases is the critical importance of compliance programs. The establishment of robust compliance measures serves as both a shield and a guide for healthcare entities navigating complex regulatory landscapes. Comprehensive training programs and regular audits are vital components that help detect and prevent fraudulent practices before they escalate into legal challenges. By fostering an organizational culture centered on compliance and ethical behavior, providers can significantly mitigate risks associated with false claims.


Another key takeaway is the necessity for transparency in billing practices. Many FCA cases arise from inaccurate or deceptive billing, whether intentional or due to oversight. Healthcare providers must ensure that all claims submitted for reimbursement accurately reflect services rendered and comply with all applicable regulations. This includes maintaining meticulous records that document patient care activities thoroughly and truthfully. Transparency not only protects against legal repercussions but also builds trust with patients and payers alike.


Furthermore, these cases highlight the role of whistleblowers in uncovering fraudulent activities within organizations. Often driven by conscience or awareness of misconduct, whistleblowers can initiate FCA suits by filing qui tam lawsuits on behalf of the government. For healthcare providers, this underscores the importance of creating safe channels for employees to report concerns without fear of retaliation. Encouraging open dialogue about potential issues can preempt external whistleblower actions and foster internal resolution methods.


The cost implications associated with FCA violations cannot be overstated either. Beyond hefty financial penalties, settlements often include additional expenses related to corrective actions mandated by Corporate Integrity Agreements (CIAs). These agreements require organizations to undertake comprehensive compliance reforms under strict oversight-highlighting how preventive investments in compliance infrastructure can outweigh retrospective remediation costs.


Finally, there's an overarching lesson regarding accountability at all levels of an organization-from executives down to frontline staff members who interact directly with patients daily-to ensure adherence not only to laws but also ethical standards vital for patient care delivery systems' credibility.


In conclusion: As illustrated through numerous historical precedents set forth by False Claims Act case studies-healthcare providers must prioritize establishing rigorous internal controls alongside cultivating transparent environments conducive towards safeguarding both their reputations financially legally ethically amidst ever-evolving expectations surrounding quality service provision nationwide globally alike!

Strategies for Staying Informed About Code Changes

In the ever-evolving landscape of healthcare, the integrity of medical coding is crucial not just for financial accuracy but also for adhering to legal and ethical standards. With the rise in scrutiny from regulatory bodies, ensuring compliant and accurate medical coding has become a central focus for many healthcare organizations. One effective way to understand the importance of this practice is by examining lessons learned from False Claims Act (FCA) case studies.


The False Claims Act serves as a powerful tool against fraud in government-funded programs, including Medicare and Medicaid. It imposes liability on individuals and companies who defraud governmental programs, offering whistleblowers financial incentives to report misconduct. Over the years, numerous FCA cases have highlighted common pitfalls in medical coding practices that lead to significant penalties and reputational damage.


One of the key lessons from these case studies is the importance of robust training programs for coders. Ensuring that medical coders are well-versed in current coding guidelines and updates is essential. Many FCA cases reveal that errors often stem from outdated knowledge or misunderstanding of complex codes. Regular training sessions and certification renewals can mitigate this risk by keeping staff informed about changes in regulations and best practices.


Another critical strategy is implementing comprehensive auditing systems. Internal audits serve as proactive measures to identify discrepancies before they escalate into larger issues. By routinely reviewing claims submissions, healthcare providers can detect patterns of inaccurate coding or potential compliance breaches early on. This not only helps avoid FCA violations but also enhances overall operational efficiency.


Furthermore, fostering a culture of accountability within healthcare organizations plays an instrumental role in maintaining compliance. Employees should feel empowered to report any concerns without fear of retaliation. Encouraging open communication creates an environment where ethical practices are prioritized, reducing the likelihood of fraudulent activities going unnoticed.


Technology also offers promising solutions for accurate medical coding. Advanced software tools equipped with artificial intelligence can assist coders by flagging anomalies or suggesting correct codes based on patient records and documentation. While technology should not replace human oversight, it can significantly reduce human error rates and improve consistency across coding practices.


Lastly, learning from past FCA cases underscores the necessity for clear documentation procedures. Accurate documentation provides a solid foundation upon which proper coding relies. Ambiguities or omissions in medical records often lead to incorrect code assignments, paving the way for potential FCA violations.


In conclusion, strategies drawn from False Claims Act case studies emphasize a multifaceted approach to achieving accurate and compliant medical coding: continuous education and training, rigorous auditing protocols, fostering an accountable workplace culture, leveraging technological advancements, and ensuring meticulous documentation practices all form critical components of a successful compliance strategy. By adopting these measures proactively, healthcare organizations can safeguard themselves against costly legal repercussions while upholding their commitment to delivering high-quality patient care within legal frameworks.

Challenges and Solutions in Adapting to New Codes

Training and education play pivotal roles in the realm of medical coding, particularly when it comes to preventing false claims-whether intentional or accidental-that can lead to significant legal repercussions under the False Claims Act (FCA). A review of case studies related to the FCA reveals that many instances of false claims can be traced back to a lack of proper training and understanding among healthcare professionals.


Medical coding is a complex task that requires precision, attention to detail, and an up-to-date knowledge of ever-evolving codes and regulations. Coders, billers, and healthcare providers must accurately translate patient encounters into standardized codes that are used for billing purposes. When errors occur in this translation process-whether through misinterpretation or oversight-claims submitted for reimbursement may become false under the law. The implications of such errors are severe; they can result in substantial fines, penalties, and reputational damage for healthcare institutions.


In numerous FCA case studies, a recurring theme is inadequate training as a root cause of non-compliance. Healthcare facilities often face challenges in keeping their staff abreast of changes in coding standards, payer rules, and compliance regulations. Without ongoing education, even well-intentioned employees may inadvertently submit incorrect claims simply because they lack sufficient knowledge about current requirements.


To address this issue effectively, organizations must prioritize comprehensive training programs that cover both foundational aspects of medical coding and advanced topics pertinent to regulatory compliance. These programs should be tailored to meet the specific needs of different roles within the organization-from front-line coders to administrative staff responsible for overseeing billing processes.


Moreover, education initiatives should not be static but instead adopt a continuous learning model. This ensures that all personnel remain informed about updates in the field as well as best practices for accurate documentation and claim submission. Regular workshops, webinars led by industry experts, and access to updated resources form part of an effective educational strategy.


Beyond technical proficiency with codes themselves lies another critical element: fostering an organizational culture committed to ethical practices. Training efforts must instill values such as integrity and accountability alongside skills-based learning objectives; employees who understand why accuracy matters are more likely motivated towards diligent work habits than those merely following rote instructions without context.


Furthermore-and perhaps most importantly-a robust compliance program should include mechanisms for auditing coded data before it reaches external payers: regular internal audits help catch potential discrepancies early on while providing additional opportunities for targeted retraining where necessary based on identified patterns from audit findings.


In conclusion then-it becomes clear through examining various FCA-related case studies-that investing time energy into effective training education frameworks ultimately serves dual purposes: safeguarding against inadvertent violations whilst simultaneously promoting high-quality care delivery via consistent adherence ethical guidelines governing healthcare operations today tomorrow alike!

Occupation
Names Certified Public Accountant (Accounts Officer), Chartered Certified Accountants, Chartered Accountant, Chartered Management Accountant, Cost and Management Accountants, Certified Management Accountants, etc.
Occupation type
Profession
Activity sectors
Business
Description
Competencies Corporate law, taxation, audit, finance, insolvency, management, mathematics, analytical skills and critical thinking skills
Education required
In some countries bachelor's degree or master's degree is needed, see professional requirements
Fields of
employment
Private corporations,
financial industry,
government
Related jobs
Bookkeeper

An accountant is a practitioner of accounting or accountancy. Accountants who have demonstrated competency through their professional associations' certification exams are certified to use titles such as Chartered Accountant, Chartered Certified Accountant or Certified Public Accountant, or Registered Public Accountant. Such professionals are granted certain responsibilities by statute, such as the ability to certify an organization's financial statements, and may be held liable for professional misconduct. Non-qualified accountants may be employed by a qualified accountant, or may work independently without statutory privileges and obligations.

Cahan & Sun (2015)[1] used archival study to find out that accountants' personal characteristics may exert a very significant impact during the audit process and further influence audit fees and audit quality. Practitioners have been portrayed in popular culture by the stereotype of the humorless, introspective bean-counter.[2][3] It has been suggested that the stereotype has an influence on those attracted to the profession with many new entrants underestimating the importance of communication skills and overestimating the importance of numeracy in the role.[4]

An accountant may either be hired for a firm that requires accounting services on a continuous basis, or may belong to an accounting firm that provides accounting consulting services to other firms. The Big Four auditors are the largest employers of accountants worldwide. However, most accountants are employed in commerce, industry, and the public sector.[5]

Commonwealth of Nations

[edit]
Accountant at work

In the Commonwealth of Nations, which include the United Kingdom, Canada, Australia, New Zealand, Hong Kong pre-1997, and several other states, commonly recognised accounting qualifications are Chartered Certified Accountant (ACCA), Chartered Accountant (CA or ACA), Certified Management Accountant (Institute of Certified Management Accountants) (CMA), Chartered Management Accountant (ACMA) and International Accountant (AAIA). Other qualifications in particular countries include Certified Public Accountant (CPA – Ireland and CPA – Hong Kong), Chartered Professional Accountant (CPA – Canada), Certified Management Accountant (Institute of Certified Management Accountants|CMA – Australia) (CMA – Sri Lanka), Certified Practising Accountant (CPA – Australia) and members of the Institute of Public Accountants (Australia), and Certified Public Practising Accountant (CPPA – New Zealand).

The Institute of Chartered Accountants of Scotland (ICAS) received its Royal Charter in 1854 and is the world's first professional body of accountants.[6]

United Kingdom and Ireland

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Excepting the Association of Certified Public Accountants, each of the above bodies admits members only after passing examinations and undergoing a period of relevant work experience. Once admitted, members are expected to comply with ethical guidelines and gain appropriate professional experience.

Chartered, Chartered Certified, Chartered Public Finance, and International Accountants engaging in practice (i.e. selling services to the public rather than acting as an employee) must gain a "practising certificate" by meeting further requirements such as purchasing adequate insurance and undergoing inspections.

The ICAEW, ICAS, ICAI, ACCA and AAPA are five Recognised Supervisory Bodies (RSB) in the UK. A member of one of them may also become a Statutory Auditor in accordance with the Companies Act, providing they can demonstrate the necessary professional ability in that area and submit to regular inspection. It is illegal for any individual or firm that is not a Statutory Auditor to perform a company audit.[9][10]

The ICAEW, ICAS, ICAI, ACCA, AIA and CIPFA are six recognised qualifying bodies statutory (RQB) in the UK. A member of one of them may also become a Statutory Auditor in accordance with the Companies Act, providing they are a member of one of the five Recognised Supervisory Bodies RSB mentioned above.

All six RQBs are listed under EU mutual recognition directives to practise in 27 EU member states and individually entered into agreement with the Hong Kong Institute of Certified Public Accountants (HKICPA).

Further restrictions apply to accountants who carry out insolvency work.

In addition to the bodies above, technical qualifications are offered by the Association of Accounting Technicians, ACCA and AIA, which are respectively called AAT Technician, CAT (Certified Accounting Technician) and IAT (International Accounting Technician).

United States

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In the United States, licensed accountants are Certified Public Accountants (CPAs), and in certain states, Public Accountants (PAs). Unlicensed accountants may be Certified Internal Auditors (CIAs) and Certified Management Accountants (CMAs). The difference between these certifications is primarily the legal status and the types of services provided, although individuals may earn more than one certification. Additionally, much accounting work is performed by uncertified individuals, who may be working under the supervision of a certified accountant. As noted above, the majority of accountants work in the private sector or may offer their services without the need for certification.

The training time required for accountancy certification in the US requires specific guidelines:

  • Certificate: Several months to a year
  • Associate degree: One–two years
  • Bachelor's degree: Three–four years
  • CPA: Five years of education (150 semester college credits) plus one–two years of work experience (length of work experience requirement depends on which state is granting the license)
  • Master's degree: One–two years
  • Doctoral degree: Three–five years

A CPA is licensed by a state to provide auditing services to the public. Many CPA firms also offer accounting, tax, litigation support, and other financial advisory services. The requirements for receiving the CPA license vary from state to state, although the passage of the Uniform Certified Public Accountant Examination is required by all states. This examination is designed and graded by the American Institute of Certified Public Accountants (AICPA).

A PA (sometimes referred to as LPA—Licensed Public Accountant) is licensed by the state to practice accountancy to the same extent as are CPAs, although in some states PAs are not permitted to perform audits or reviews (notably Iowa, Minnesota, Oregon, & South Carolina). A PA's ability to practice out of state is very limited due to most states having phased out the PA designation. While most states no longer accept new PA license applicants, four states still accept PA applicants for practice privileges within the state. As with the CPA, the requirements for receiving the PA license vary from state to state. Most states require a passage of either two or three (out of four) sections of the CPA exam or passage of the Comprehensive Examination for Accreditation in Accounting which is administered and graded by the Accreditation Council for Accountancy and Taxation (ACAT).

A certified internal auditor (CIA) is granted a certificate from the Institute of Internal Auditors (IIA), provided that the candidate has passed a four-part examination. One of the four parts is waived if the candidate has already passed the CPA Exam. A CIA typically provides services directly to an employer rather than to the public.

A person holding the Certificate in Management Accounting (CMA) is granted the certificate by the Institute of Management Accountants (IMA), provided that the candidate has passed an examination of two parts and has met the practical experience requirement of the IMA. A CMA provides services directly to employers rather than to the public. A CMA can also provide services to the public, but to an extent much lesser than that of a CPA.

An Enrolled Agent (EA) is a federally authorized tax practitioner empowered by the U.S. Department of the Treasury to represent taxpayers before the Internal Revenue Service (IRS). Enrolled agent status is the highest credential awarded by the IRS, unlimited rights of representation.[11] The EA credential is recognized across all 50 U.S. states. Candidates must pass a three-part exam (called the Special Enrollment Examination) covering the subjects of individual tax, business tax, and client representation, or must have worked at the IRS for five consecutive years in a position which regularly engaged in these areas.

The United States Department of Labor's Bureau of Labor Statistics estimates that there are about one million persons[12] employed as accountants and auditors in the U.S.

U.S. tax laws grant CPAs and EAs a form of accountant–client privilege.

Non-certified accountants

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Australia

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In Australia, there are three legally recognised local professional accounting bodies which all enjoy the same recognition and can be considered as "qualified accountant": the Institute of Public Accountants (IPA), CPA Australia (CPA) and the Chartered Accountants Australia and New Zealand (CAANZ). Other international bodies such as ACCA (The Association of Chartered Certified Accountants) and Institute of Chartered Accountants in England and Wales (ICAEW) enjoy recognition for the purposes of supporting their members in their careers. For instance, ACCA has achieved recognition by the Tax Practitioner Board, as Tax and BAS agents, in 2010.

Canada

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In Canada, a Chartered Professional Accountant (CPA) must be a member of the Chartered Professional Accountants of Canada (designatory letters CPA).

Up to 2013, there were three nationally recognized accounting designations in Canada: Chartered Accountant (CA), Certified General Accountant (CGA), and Certified Management Accountants (CMA). The national CA and CGA bodies were created by Acts of Parliament in 1902 and 1913 respectively, The national CMA organization was established under the Canada Corporations Act in 1920.

In January 2012, following eight months of member and stakeholder consultation, the Canadian Institute of Chartered Accountants (CICA), the Society of Management Accountants of Canada (CMA Canada) and Certified General Accountants of Canada (CGA-Canada) issued A Framework for Uniting the Canadian Accounting Profession under a new Canadian Chartered Professional Accountant (CPA) designation. Chartered Professional Accountants of Canada (CPA Canada) was established by CICA and CMA Canada on January 1, 2013, under the Canada Not-for-profit Corporations Act, to support Canadian provincial accounting bodies that were unifying under the CPA banner. CGA-Canada integrated with CPA Canada on October 1, 2014, completing the unification of Canada's accounting profession at the national level.

All recognized national and provincial accounting bodies in Canada have now unified under the CPA banner. The Canadian CPA designation is held by more than 200,000 members in Canada and around the world.

Japan

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In Japan, a certified public accountant must be a member of the Japanese Institute of Certified Public Accountants (JICPA). It is the sole professional accountancy organization in Japan.

India

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Chartered accountancy is offered in India by the Institute of Chartered Accountants of India (ICAI), the second largest accounting body in the world. This Institute was established in 1949 under the Chartered Accountants Act, 1949 for the regulation of the profession of chartered accountants in India.

The ICAI set up the Accountancy Museum of India in 2009, the third museum of accounting in the world. It is located at ICAI's office in Noida.A Cost and Management Accountant is registered as a member under the Institute of Cost Accountants of India(ICMAI) previously known as (ICWAI) which is a statutory body constituted under the Cost and Works Accountants Act 1959 enacted by the Parliament of India, it is also the second largest Management Accountancy body in the world. The members of the Institute are widely recognized as Cost and Management Accountants (FCMA, ACMA).[13]

Indonesia

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Under Public Accountants Law ( UU 5/2011), the Institute of Certified Public Accountants of Indonesia (IAPI) is the professional organization having the authority to issue CPA designation which is the statutory requirements for obtaining public accountant license from the government.

Pakistan

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The Institute of Chartered Accountants of Pakistan (ICAP) offers chartered accountant studies in Pakistan. ICAP was established under The Chartered Accountants Ordinance, 1961 as a self-regulatory body.

The Institute of Cost and Management Accountants of Pakistan (ICMAP) offers accountant studies in Pakistan. ICMAP was established under The Cost and Management Accountants Act, 1966.

Pakistan Institute of Public Finance Accountants (PIPFA) is an autonomous body recognized mainly in the government sector and established under license from the Securities and Exchange Commission of Pakistan by the authority given under section 42 of the Companies Ordinance, 1984.

The body is co-sponsored by the Institute of Chartered Accountants of Pakistan, the Institute of Cost and Management Accountants of Pakistan and the Auditor General of Pakistan.PIPFA has more than 5,000 members and a number of them are members of ICAP and ICMAP.

The institute was established to produce a second tier of accounting professionals in Pakistan

Bangladesh

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Chartered accountancy is governed in Bangladesh by the Institute of Chartered Accountants of Bangladesh (ICAB).

And The Institute of Cost and Management Accountants of Bangladesh (ICMAB) offers management accountant studies in Bangladesh.

New Zealand

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In New Zealand, there are two local accountancy bodies the Chartered Accountants Australia and New Zealand (CAANZ) and the New Zealand Association of Certified Public Accountants (NZACPA) the operating name of New Zealand Association of Accountants Inc (NZAA).

To audit public companies an individual must be a member of either the CAANZ or an otherwise gazetted body. Chartered Certified Accountant (Association of Chartered Certified Accountants or FCCA) qualification has also been gazetted under. An ACCA member can practice as long as they hold an ACCA public practice certificate (with audit qualification) in their country of origin.

Singapore

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In Singapore, a public accountant must be a member of any professional accountancy body in Singapore.[14] Institute of Singapore Chartered Accountants (ISCA) is the sole local accountancy body, therefore the public accountant must be a member of the ISCA.[15]

Sri Lanka

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In Sri Lanka, a chartered accountant must be a member of the Institute of Chartered Accountants of Sri Lanka (designatory letters ACA or FCA). It is the sole local accountancy body, therefore to audit public companies an individual must be a member of the ICASL. A Certified management account also must be a member of the Institute of Management Accountants of Sri Lanka (designatory letters ACMA or FCMA).

Austria

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In Austria, the accountancy profession is regulated by the Bilanzbuchhaltungsgesetz 2006 (BibuG – Management Accountancy Law).[citation needed]

Hong Kong

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In Hong Kong, the accountancy industry is regulated by Hong Kong Institute of Certified Public Accountants(HKICPA) under the Professional Accountants Ordinance (Chapter 50, Laws of Hong Kong). The auditing industry for limited companies is regulated under the Companies Ordinance (Chapter 32, Laws of Hong Kong), and other ordinances such as the securities and futures ordinance, the listing rules, etc.

HKICPA terminated all recognition of overshare bodies in 2005 for accreditation under professional accountants ordinance. In general, all British RQBs except for CIPFA were re-accredited. Please refer to HKICPA for latest recognition.

Portugal

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In Portugal, there are two accountancy qualifications: the Contabilistas Certificados (CC), responsible for producing accounting and tax information, and the Revisor Oficial de Contas (ROC), more related to auditing practices. The CC certification is exclusively awarded by the professional organization Ordem dos Contabilistas Certificados (OCC), and the certification to become an auditor is awarded by another professional organization, the Ordem dos Revisores Oficiais de Contas (OROC).[16] In general, accountants or auditors accredited by OTOC or OROC are individuals with university graduation diplomas in business management, economics, mathematics or law who, after further studies, applied for an exam and received the certification to be a CC or ROC. That certification is only received after a one-year (CC) or three-year (ROC) internship. Any citizen having a polytechnic degree as a bookkeeper is also entitled to apply for the exam and certification at the OCC.[17]

See also

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References

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  1. ^ Cahan, Steven F.; Sun, Jerry (2014-08-11). "The Effect of Audit Experience on Audit Fees and Audit Quality". Journal of Accounting, Auditing & Finance. 30 (1): 78–100. doi:10.1177/0148558x14544503. S2CID 154369246.
  2. ^ Friedman, A. L., & Lyne, S. R. (2001). The beancounter stereotype: towards a general model of stereotype generation. Critical perspectives on accounting, 12(4), 423-451.
  3. ^ Jeacle, I., Miley, F., & Read, A. (2012). Jokes in popular culture: the characterisation of the accountant. Accounting, Auditing & Accountability Journal.
  4. ^ "Written Communication Apprehension Experienced by First-Year Undergraduate Accounting Students". INTED2023 Proceedings. 17th Annual International Technology, Education and Development Conference. Vol. 1. Valencia, Spain. March 2023. pp. 1082–1091. doi:10.21125/inted.2023.0322.
  5. ^ For example, in 2009 in Ontario, Canada, national firms employ 4,425 Chartered Accountants, which is less than 50% of the members in public practice.(Chartered Accountants in National Firms in Ontario, Canada Archived July 6, 2011, at the Wayback Machine) As total membership is 33,146, the national firms employ about 13% of all Chartered Accountants in Ontario. (Ontario Chartered Accountants demographics Archived July 6, 2011, at the Wayback Machine) Most of the members are employed in industry, with the majority in small and medium sized enterprises.
  6. ^ Perks, R.W.(1993): Accounting and Society. Chapman & Hall (London); ISBN 0-412-47330-5. p.16
  7. ^ "Accountants Institute". Archived from the original on 2021-02-24. Retrieved 2019-03-30.
  8. ^ United Kingdom, Intellectual Property Office, Concept House, Cardiff Road, Newport, NP10 8QQ. "Intellectual Property Office". www.ipo.gov.uk. Archived from the original on 2023-07-01. Retrieved 2016-04-11.cite web: CS1 maint: multiple names: authors list (link) CS1 maint: numeric names: authors list (link)
  9. ^ "Recognised Supervisory Body List". www.AuditRegister.org.uk. Archived from the original on 26 September 2014. Retrieved 2 August 2017.
  10. ^ team, FRC web. "FRC". www.FRC.org.uk. Archived from the original on 3 August 2017. Retrieved 2 August 2017.
  11. ^ Enrolled Agent Information, Internal Revenue Service, U.S. Dep't of the Treasury, at [1] Archived 2022-09-26 at the Wayback Machine.
  12. ^ "Accountants and Auditors". www.BLS.gov. Archived from the original on 14 July 2017. Retrieved 2 August 2017.
  13. ^ "ICWAI Act on MCA website" (PDF). Archived (PDF) from the original on 2012-04-25. Retrieved 2012-07-30.
  14. ^ "Registering as a Public Accountant : Chapters – ACRA". www.ACRA.gov.sg. Archived from the original on 3 August 2017. Retrieved 2 August 2017.
  15. ^ "Professional Requirements for Registration as Public Accountants : Chapters – ACRA". www.ACRA.gov.sg. Archived from the original on 3 August 2017. Retrieved 2 August 2017.
  16. ^ Seara.com. "Ordem dos Revisores Oficiais de Contas". www.OROC.pt. Archived from the original on 17 September 2009. Retrieved 2 August 2017.
  17. ^ "OCC official site". Archived from the original on 2023-06-01. Retrieved 2021-08-31.

 

In general, compliance means conforming to a rule, such as a specification, policy, standard or law. Compliance has traditionally been explained by reference to deterrence theory, according to which punishing a behavior will decrease the violations both by the wrongdoer (specific deterrence) and by others (general deterrence). This view has been supported by economic theory, which has framed punishment in terms of costs and has explained compliance in terms of a cost-benefit equilibrium (Becker 1968). However, psychological research on motivation provides an alternative view: granting rewards (Deci, Koestner and Ryan, 1999) or imposing fines (Gneezy Rustichini 2000) for a certain behavior is a form of extrinsic motivation that weakens intrinsic motivation and ultimately undermines compliance.

Regulatory compliance describes the goal that organizations aspire to achieve in their efforts to ensure that they are aware of and take steps to comply with relevant laws, policies, and regulations.[1] Due to the increasing number of regulations and need for operational transparency, organizations are increasingly adopting the use of consolidated and harmonized sets of compliance controls.[2] This approach is used to ensure that all necessary governance requirements can be met without the unnecessary duplication of effort and activity from resources.

Regulations and accrediting organizations vary among fields, with examples such as PCI-DSS and GLBA in the financial industry, FISMA for U.S. federal agencies, HACCP for the food and beverage industry, and the Joint Commission and HIPAA in healthcare. In some cases other compliance frameworks (such as COBIT) or even standards (NIST) inform on how to comply with regulations.

Some organizations keep compliance data—all data belonging or pertaining to the enterprise or included in the law, which can be used for the purpose of implementing or validating compliance—in a separate store for meeting reporting requirements. Compliance software is increasingly being implemented to help companies manage their compliance data more efficiently. This store may include calculations, data transfers, and audit trails.[3][4]

Standards

[edit]

The International Organization for Standardization (ISO) and its ISO 37301:2021 (which deprecates ISO 19600:2014) standard is one of the primary international standards for how businesses handle regulatory compliance, providing a reminder of how compliance and risk should operate together, as "colleagues" sharing a common framework with some nuances to account for their differences. The ISO also produces international standards such as ISO/IEC 27002 to help organizations meet regulatory compliance with their security management and assurance best practices.[5]

Some local or international specialized organizations such as the American Society of Mechanical Engineers (ASME) also develop standards and regulation codes. They thereby provide a wide range of rules and directives to ensure compliance of the products to safety, security or design standards.[6]

By nation

[edit]

Regulatory compliance varies not only by industry but often by location. The financial, research, and pharmaceutical regulatory structures in one country, for example, may be similar but with particularly different nuances in another country. These similarities and differences are often a product "of reactions to the changing objectives and requirements in different countries, industries, and policy contexts".[7]

Australia

[edit]

Australia's major financial services regulators of deposits, insurance, and superannuation include the Reserve Bank of Australia (RBA), the Australian Prudential Regulation Authority (APRA), the Australian Securities & Investments Commission (ASIC), and the Australian Competition & Consumer Commission (ACCC).[8] These regulators help to ensure financial institutes meet their promises, that transactional information is well documented, and that competition is fair while protecting consumers. The APRA in particular deals with superannuation and its regulation, including new regulations requiring trustees of superannuation funds to demonstrate to APRA that they have adequate resources (human, technology and financial), risk management systems, and appropriate skills and expertise to manage the superannuation fund, with individuals running them being "fit and proper".[8]

Other key regulators in Australia include the Australian Communications & Media Authority (ACMA) for broadcasting, the internet, and communications;[9] the Clean Energy Regulator for "monitoring, facilitating and enforcing compliance with" energy and carbon emission schemes;[10] and the Therapeutic Goods Administration for drugs, devices, and biologics;[11]

Australian organisations seeking to remain compliant with various regulations may turn to AS ISO 19600:2015 (which supersedes AS 3806-2006). This standard helps organisations with compliance management, placing "emphasis on the organisational elements that are required to support compliance" while also recognizing the need for continual improvement.[12][13]

Canada

[edit]

In Canada, federal regulation of deposits, insurance, and superannuation is governed by two independent bodies: the OSFI through the Bank Act, and FINTRAC, mandated by the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, 2001 (PCMLTFA).[14][15] These groups protect consumers, regulate how risk is controlled and managed, and investigate illegal action such as money laundering and terrorist financing.[14][15] On a provincial level, each province maintain individuals laws and agencies. Unlike any other major federation, Canada does not have a securities regulatory authority at the federal government level. The provincial and territorial regulators work together to coordinate and harmonize regulation of the Canadian capital markets through the Canadian Securities Administrators (CSA).[16]

Other key regulators in Canada include the Canadian Food Inspection Agency (CFIA) for food safety, animal health, and plant health; Health Canada for public health; and Environment and Climate Change Canada for environment and sustainable energy.[17]

Canadian organizations seeking to remain compliant with various regulations may turn to ISO 19600:2014, an international compliance standard that "provides guidance for establishing, developing, implementing, evaluating, maintaining and improving an effective and responsive compliance management system within an organization".[18] For more industry specific guidance, e.g., financial institutions, Canada's E-13 Regulatory Compliance Management provides specific compliance risk management tactics.[19]

The Netherlands

[edit]

The financial sector in the Netherlands is heavily regulated. The Dutch Central Bank (De Nederlandsche Bank N.V.) is the prudential regulator while the Netherlands Authority for Financial Markets (AFM) is the regulator for behavioral supervision of financial institutions and markets. A common definition of compliance is:'Observance of external (international and national) laws and regulations, as well as internal norms and procedures, to protect the integrity of the organization, its management and employees with the aim of preventing and controlling risks and the possible damage resulting from these compliance and integrity risks'.[20]

India

[edit]

In India, compliance regulation takes place across three strata: Central, State, and Local regulation. India veers towards central regulation, especially of financial organizations and foreign funds. Compliance regulations vary based on the industry segment in addition to the geographical mix. Most regulation comes in the following broad categories: economic regulation, regulation in the public interest, and environmental regulation.[21] India has also been characterized by poor compliance - reports suggest that only around 65% of companies are fully compliant to norms.[22]

Singapore

[edit]

The Monetary Authority of Singapore is Singapore's central bank and financial regulatory authority. It administers the various statutes pertaining to money, banking, insurance, securities and the financial sector in general, as well as currency issuance.[23]

United Kingdom

[edit]

There is considerable regulation in the United Kingdom, some of which is derived from European Union legislation. Various areas are policed by different bodies, such as the Financial Conduct Authority (FCA),[24] Environment Agency,[25] Scottish Environment Protection Agency,[26] Information Commissioner's Office,[27] Care Quality Commission,[28] and others: see List of regulators in the United Kingdom.

Important compliance issues for all organizations large and small include the Data Protection Act 2018[29] and, for the public sector, Freedom of Information Act 2000.[30]

Financial compliance

[edit]

The U.K. Corporate Governance Code (formerly the Combined Code) is issued by the Financial Reporting Council (FRC) and "sets standards of good practice in relation to board leadership and effectiveness, remuneration, accountability, and relations with shareholders".[31] All companies with a Premium Listing of equity shares in the U.K. are required under the Listing Rules to report on how they have applied the Combined Code in their annual report and accounts.[32] (The Codes are therefore most similar to the U.S.' Sarbanes–Oxley Act.)

The U.K.'s regulatory framework requires that all its publicly listed companies should provide specific content in the core financial statements that must appear in a yearly report, including balance sheet, comprehensive income statement, and statement of changes in equity, as well as cash flow statement as required under international accounting standards.[33] It further demonstrates the relationship that subsists among shareholders, management, and the independent audit teams. Financial statements must be prepared using a particular set of rules and regulations hence the rationale behind allowing the companies to apply the provisions of company law, international financial reporting standards (IFRS), as well as the U.K. stock exchange rules as directed by the FCA.[34] It is also possible that shareholders may not understand the figures as presented in the various financial statements, hence it is critical that the board should provide notes on accounting policies as well as other explanatory notes to help them understand the report better.

Challenges

[edit]

Data retention is a part of regulatory compliance that is proving to be a challenge in many instances. The security that comes from compliance with industry regulations can seem contrary to maintaining user privacy. Data retention laws and regulations ask data owners and other service providers to retain extensive records of user activity beyond the time necessary for normal business operations. These requirements have been called into question by privacy rights advocates.[35]

Compliance in this area is becoming very difficult. Laws like the CAN-SPAM Act and Fair Credit Reporting Act in the U.S. require that businesses give people the right to be forgotten.[36][37] In other words, they must remove individuals from marketing lists if it is requested, tell them when and why they might share personal information with a third party, or at least ask permission before sharing that data. Now, with new laws coming out that demand longer data retention despite the individual’s desires, it can create some real difficulties.

Money laundering and terrorist financing pose significant threats to the integrity of the financial system and national security. To combat these threats, the EU has adopted a risk-based approach to Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) that relies on cooperation and coordination between EU and national authorities. In this context, risk-based regulation refers to the approach of identifying and assessing potential risks of money laundering and terrorist financing and implementing regulatory measures proportional to those risks. However, the shared enforcement powers between EU and national authorities in the implementation and enforcement of AML/CFT regulations can create legal implications and challenges. The potential for inconsistent application of AML regulations across different jurisdictions can create regulatory arbitrage and undermine the effectiveness of AML efforts. Additionally, a lack of clear and consistent legal frameworks defining the roles and responsibilities of EU and national authorities in AML enforcement can lead to situations where accountability is difficult to establish.

United States

[edit]

Corporate scandals and breakdowns such as the Enron case of reputational risk in 2001 have increased calls for stronger compliance and regulations, particularly for publicly listed companies.[1] The most significant recent statutory changes in this context have been the Sarbanes–Oxley Act developed by two U.S. congressmen, Senator Paul Sarbanes and Representative Michael Oxley in 2002 which defined significantly tighter personal responsibility of corporate top management for the accuracy of reported financial statements; and the Dodd-Frank Wall Street Reform and Consumer Protection Act.

The Office of Foreign Assets Control (OFAC) is an agency of the United States Department of the Treasury under the auspices of the Under Secretary of the Treasury for Terrorism and Financial Intelligence. OFAC administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign states, organizations, and individuals.

Compliance in the U.S. generally means compliance with laws and regulations. These laws and regulations can have criminal or civil penalties. The definition of what constitutes an effective compliance plan has been elusive. Most authors, however, continue to cite the guidance provided by the United States Sentencing Commission in Chapter 8 of the Federal Sentencing Guidelines.[38][39]

On October 12, 2006, the U.S. Small Business Administration re-launched Business.gov (later Business.USA.gov and finally SBA.Gov)[40] which provides a single point of access to government services and information that help businesses comply with government regulations.

The U.S. Department of Labor, Occupational Health and Safety Administration (OSHA) was created by Congress to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education, and assistance. OSHA implements laws and regulations regularly in the following areas, construction, maritime, agriculture, and recordkeeping.[41]

The United States Department of Transportation also has various laws and regulations requiring that prime contractors when bidding on federally funded projects engage in good faith effort compliance, meaning they must document their outreach to certified disadvantaged business enterprises.[42]

See also

[edit]
  • Business Motivation Model - A standard for recording governance and compliance activities
  • Chief compliance officer
  • Corporate social responsibility
  • Environmental compliance
  • Governance, risk management, and compliance
  • International regulation
  • Professional ethics
  • Regulatory technology

References

[edit]
  1. ^ a b Compliance, Technology, and Modern Finance, 11 Journal of Corporate, Financial & Commercial Law 159 (2016)
  2. ^ Silveira, P.; Rodriguez, C.; Birukou, A.; Casati, F.; Daniel, F.; D'Andrea, V.; Worledge, C.; Zouhair, T. (2012), "Aiding Compliance Governance in Service-Based Business Processes", Handbook of Research on Service-Oriented Systems and Non-Functional Properties (PDF), IGI Global, pp. 524–548, doi:10.4018/978-1-61350-432-1.ch022, hdl:11311/1029233, ISBN 9781613504321
  3. ^ Norris-Montanari, J. (27 February 2017). "Compliance – Where does it fit in a data strategy?". SAS Blogs. SAS Institute, Inc. Retrieved 31 July 2018.
  4. ^ Monica, A.D.; Shilt, C.; Rimmerman, R.; et al. (2015). "Chapter 4: Monitoring software updates". Microsoft System Center Software Update Management Field Experience. Microsoft Press. pp. 57–82. ISBN 9780735695894.
  5. ^ Calder, A.; Watkins, S. (2015). IT Governance: An International Guide to Data Security and ISO 27001/ISO 27002. Kogan Page Publishers. pp. 39–40. ISBN 9780749474065.
  6. ^ Boiler and Pressure Vessel Inspection According to ASME
  7. ^ Malyshev, N. (2008). "The Evolution of Regulatory Policy in OECD Countries" (PDF). OECD. Retrieved 27 July 2018.
  8. ^ a b Pearson, G. (2009). "Chapter 2: The regulatory structure". Financial Services Law and Compliance in Australia. Cambridge University Press. pp. 20–68. ISBN 9780521617840.
  9. ^ "Regulatory Responsibility". ACMA. 17 December 2012. Retrieved 31 July 2018.
  10. ^ "What we do". Clean Energy Regulator. 14 December 2016. Retrieved 31 July 2018.
  11. ^ Weinberg, S. (2011). "Chapter 13: International Regulation". Cost-Contained Regulatory Compliance: For the Pharmaceutical, Biologics, and Medical Device Industries. John Wiley & Sons. pp. 227–258. ISBN 9781118002278.
  12. ^ CompliSpace (14 April 2016). "Compliance Standards ISO 19600 and AS 3806 – Differences explained". Retrieved 31 July 2018.
  13. ^ "AS ISO 19600:2015". Standards Catalogue. Standards Australia. Retrieved 31 July 2018.
  14. ^ a b International Monetary Fund; Financial Action Task Force (December 2008). Canada: Report on Observance of Standards and Codes - FATF Recommendations for Anti-Money Laundering and Combating the Financing of Terrorism.cite book: CS1 maint: multiple names: authors list (link)
  15. ^ a b International Monetary Fund (August 2016). Canada: Detailed Assessment Report on Anti-Money Laundering and Combating the Financing of Terrorism. International Monetary Fund. ISBN 9781475536188.
  16. ^ Lee, R. (2003). "Chapter 6: Promoting Regional Capital Market Integration". In Dowers, K.; Msci, P. (eds.). Focus on Capital: New Approaches to Developing Latin American Capital Markets. Inter-American Development Bank. p. 168. ISBN 9781931003490.
  17. ^ Smyth, S.J.; McHughen, A. (2012). "Chapter 2: Regulation of Genetically Modified Crops in USA and Canada: Canadian Overview". In Wozniak, C.A.; McHughen, A. (eds.). Regulation of Agricultural Biotechnology: The United States and Canada. Springer Science & Business Media. pp. 15–34. ISBN 9789400721562.
  18. ^ International Organization for Standardization (December 2014). "ISO 19600:2014". Standards Catalogue. Retrieved 31 July 2018.
  19. ^ Office of the Superintendent of Financial Institutions (14 November 2014). "Revised Guideline E-13 – Regulatory Compliance Management (RCM)". Government of Canada. Retrieved 31 July 2018.
  20. ^ The Handbook of Compliance & Integrity Management. Theory & Practice, Prof. S.C. Bleker-van Eyk & R.A.M. Houben (Eds.), 2017 Kluwer Law International.
  21. ^ "Regulatory Management and Reform in India" (PDF). OECD.
  22. ^ "India Inc has poor record in regulatory compliance | Latest News & Updates at Daily News & Analysis". 2014-10-12. Retrieved 2016-09-18.
  23. ^ "Who We Are". www.mas.gov.sg. Retrieved 2024-08-19.
  24. ^ "Do you need to be FCA authorsied? | FCA application process". Harper James. Retrieved 2024-08-19.
  25. ^ "Check if you need an environmental permit". GOV.UK. 2020-10-23. Retrieved 2024-08-19.
  26. ^ "Waste management licence (Scotland) - GOV.UK". www.gov.uk. Retrieved 2024-08-19.
  27. ^ "Information Commissioner's Office". GOV.UK. 2021-06-28. Retrieved 2024-08-19.
  28. ^ "Care Quality Commission". GOV.UK. 2024-06-25. Retrieved 2024-08-19.
  29. ^ "Data Protection Act 2018". August 19, 2024.
  30. ^ "Freedom of Information Act 2000". August 19, 2024.
  31. ^ "UK Corporate Governance Code". Financial Reporting Council. Retrieved 31 July 2018.
  32. ^ "LR 1.5 Standard and Premium Listing". FCA Handbook. Financial Conduct Authority. Retrieved 31 July 2018.
  33. ^ "LR 9.8 Annual financial report". FCA Handbook. Financial Conduct Authority. Retrieved 31 July 2018.
  34. ^ "FCA Handbook". Financial Conduct Authority. Retrieved 31 July 2018.
  35. ^ "Compliance Challenge: Privacy vs. Security". Dell.com. Archived from the original on 2011-02-26. Retrieved 2012-06-19.
  36. ^ Francis, L.P.; Francis, J.G. (2017). Privacy: What Everyone Needs to Know. Oxford University Press. p. PT102. ISBN 9780190612283.
  37. ^ Dale, N.; Lewis, J. (2015). Computer Science Illuminated. Jones & Bartlett Publishers. p. 388. ISBN 9781284055924.
  38. ^ "Special Reports and Discussions on Chapter Eight". USSC.gov. Archived from the original on November 23, 2010.
  39. ^ The Ethics and Compliance Initiative (ECI). "Principles and Practices of High Quality Ethics & Compliance Programs". pp. 12–13. Retrieved 31 August 2016.
  40. ^ "Explore Business Tools & Resources". Business.USA.gov.
  41. ^ "OSHA Law & Regulations | Occupational Safety and Health Administration". www.osha.gov. Retrieved 2017-04-07.
  42. ^ "Compliance with Diversity Goals Remain Lacking". Archived from the original on June 3, 2024.