Assess whether bonus triggers were gamed by cutoff (dfcb73)

Situation

Bonus triggers were gamed sits with FCPA investigation lead because a new counterparty formed 19 days before quarter-end hit a public filer facing a whistleblower memo. Evidence is related-party customer map; write the Forensic Accounting Occupational Fraud option that extract can carry.

Decision

FCPA investigation lead in a public filer facing a whistleblower memo must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using related-party customer map after a new counterparty formed 19 days before quarter-end.

Hypotheses to test

• The population in related-party customer map is the one a new counterparty formed 19 days before quarter-end named, so Remove access or reverse the item follows for this Occupational Fraud file.
• The population in related-party customer map is adjacent only to a new counterparty formed 19 days before quarter-end; Temporary compensating control is the honest Forensic Accounting call.
• A public filer facing a whistleblower memo already contained a new counterparty formed 19 days before quarter-end before related-party customer map arrived; no new Occupational Fraud path.
• Provenance on related-party customer map after a new counterparty formed 19 days before quarter-end is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Trace approval, SoD, and related-party links that related-party customer map actually shows.
• Test cutoff, reversals, and system-of-record ties for materiality on bonus triggers were gamed.
• Quantify the entry if FCPA investigation lead has to reverse it.
• For this Forensic Accounting Occupational Fraud file, read related-party customer map against a new counterparty formed 19 days before quarter-end and write the one fact that would move bonus triggers were gamed for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Occupational Fraud packet (related-party customer map after a new counterparty formed 19 days before quarter-end). The follow-on Occupational Fraud action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.