“Mueller Accuses Paul Manafort of Lying to FBI After Plea Agreement, The Wall Street Journal, November 26, 2018 (online). Did Manafort lie after he reached a plea deal?
Information is not limited to what you write in a document or an email. It includes verbal utterances. How do you control your “verbal utterances” when the penalty for lying to the FBI can result in 20 years in prison, regardless of what happened prior to your plea deal?
So, this involves Information (verbal statements are information), Compliance (lying to the FBI exposes you to 20 years’ in prison for each offense), and Governance (how do you avoid making an untrue utterance?). Do your policies and controls address verbal information, and, generally, not lying to the FBI? Need they?