Posts Tagged ‘internal control’

Food Company Cooks the Books


The SEC settled charges with an organic foods company on Tuesday over internal control failures that led to several years of revenue manipulation, in a case with multiple lessons for the internal control community. We don’t see an internal controls case this large come along every day, so let’s digest. First, the background. The accused…

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Automation & Control Lessons in Latest SEC Enforcement


We have an interesting enforcement action from the Securities and Exchange Commission this week, where the agency dinged a telecom company and its former executives $1.9 million for misleading statements on revenue projections. The kicker: it looks like the company’s own sales automation software created the audit trail that painted the company into an enforcement…

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Why ‘Michael Cohen Risk’ Still Matters


Over the weekend an ethics and compliance leader emailed me. This person has long, substantive experience in the field, and speaks about corporate compliance often; you would recognize the name immediately. The person had a question. Other than Radical Compliance, is anyone else talking about Corporate America’s suspicious payments to Michael Cohen, personal lawyer to…

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SEC on Current Accounting Issues


Spring is here, and that means one thing for financial reporting: the annual financial reporting conference at Baruch College in New York, where SEC chief accountant Wes Bricker shows up and tells us what issues are on his team’s mind as they read all your SEC filings. This year was no exception. The conference happened…

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Compliance 101: Manual vs. Automated Controls

Here at the Radical Compliance home office, every morning my job is to rouse my toddler son from bed, make him breakfast, and take him to preschool. As winter approaches here in New England, that also means ensuring that he’s properly dressed for cold weather. Little did I know that such a simple exercise is…

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TEC 2017: Importance of Reliable Data


Workiva’s TEC 2017 conference opened on Tuesday with a group of CFOs fretting about data—and, when you think about it, who can blame them? Companies are drowning in data. CFOs, CEOs, and other senior leaders spend far more time than they should simply confirming the authenticity and accuracy of it. The morning session even featured…

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Intelligence Leaks & Internal Control

On Monday the Justice Department charged a 25-year-old woman with leaking classified intelligence to the media. Say what you will about the woman’s patriotism, brains, or motivation. Compliance and audit executives have plenty of lessons to learn in this case-study of security controls in the modern era. The woman is Reality Leigh Winner. As you…

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And the Oscar for Control Failures Goes to…

Control failures

Internal control enthusiasts everywhere are performing a root cause analysis of what went wrong at the Oscars this weekend, so Radical Compliance might as well get a piece of that action too. After all, when was the last time a control failure was household news? The debacle, for those last few who haven’t yet heard…

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Of Contract Labor and Your Control Environment

The KPMG Audit Committee Institute recently published its annual survey of audit committee worries—and don’t die of shock, but maintaining high ethical rigor across the extended enterprise was a big concern. KPMG phrased the issue as “maintaining the control environment in the company’s extended organization.” It ranked third among audit committee worries, tied with cybersecurity and…

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This Weird United Airlines Case Just Happened


Fasten your seatbelts, compliance officers—we may just have flown into a vast, uncharted territory of corruption and internal control risk nobody expected. I speak of the SEC’s recent sanction against United Airlines, where the agency applied the spirit of the Foreign Corrupt Practices Act to a bribe United gave to a domestic government official here…

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