Sometimes the importance of internal accounting controls can be a little hard for compliance professionals to grasp, but fear not! A crazy tale from Hollywood this week gives us a great example of why internal controls matter and what can go wrong when they’re not working properly.
The tale comes from Tom Hollander, the fairly successful British character actor in his mid-50s who has appeared in The White Lotus, Pride and Prejudice, a few Pirates of the Caribbean sequels, and lots of other stuff. He’s one of those actors where even if you don’t recognize his name, you recognize his face as soon as you see him. “Oh yeah, that guy.”
Hollander is not, however, Tom Holland, the 27-year-old star of Marvel Entertainment’s Spider-Man and Avengers movies. The two actors just have very similar names — and for a brief while several years ago, they also relied on the same talent agency to disburse payments to them from their respective Hollywood studios.
That brings us to this week. Hollander appeared on Late Night With Seth Myers to promote his latest TV venture. Toward the end of the interview, he told the story of how his talent agency sent him one of Holland’s bonus payments for The Avengers: Infinity War by mistake.
“It was an astonishing amount of money,” Hollander said. “And it was not his salary, it was his first box office bonus. Not the whole box office, the first one. And it was more money than I’ve ever — it was a seven-figure sum.”
Hollander laughed off the mistake with Myers, and presumably sent the payment back to Holland. For corporate compliance professionals, however, the goody-two-shoes lesson to be learned here is that this is why internal accounting controls matter.
Imagine that your company had a client named Vladimir Puton, and the accounting team sent a seven-figure payment to Vladimir Putin by mistake. Would you be laughing then? Of course not. The CFO would be firing half the accounts payable department while you’re on a conference call with the Treasury and Justice departments begging for mercy.
It may seem like I’m being nit-picky with Hollander’s talent agency — but picking nits is the accounting function’s job. Companies are supposed to have processes in place to prevent payments from going to the wrong recipient. The consequences of screwing that up can be quite serious, from publicity black eyes to enforcement actions from federal regulators.
Let’s speculate about some of the ways this Holland-Hollander fiasco might have happened. Did the talent agency have a misfire in its technical controls, where the system failed to recognize that the name “Holland” on the payment order didn’t match the name “Hollander” on the bank account? Did the talent agency use a flawed manual process, where some A/P clerk couldn’t be bothered to double-check his or her work?
The first error sounds like a SOX violation, because we don’t know how many other misdirected payments might have happened. The second sounds like a fraud or compliance risk, since the A/P clerk might be sending payments to all sorts of unsavory characters. Neither one is a good thing — and at large, publicly traded companies, either one could be a very bad thing.
That’s the true lesson here. Hollander gave us a funny example of what happens when internal accounting controls go haywire. With a moment’s more thought, however, you can see that weak accounting controls are no laughing matter at all.