FCPA investigation lead must resolve whether cash ever economically changed

Situation

Revenue Integrity work in a pre-IPO SaaS company drafting an S-1 now turns on cash ever economically changed because an FCPA agent-payment spike in one country put intercompany elimination mismatch report in play. FCPA investigation lead should say what intercompany elimination mismatch report proves.

Decision

FCPA investigation lead in a pre-IPO SaaS company drafting an S-1 must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using intercompany elimination mismatch report after an FCPA agent-payment spike in one country.

Hypotheses to test

• Intercompany elimination mismatch report reads as Remove access or reverse the item once an FCPA agent-payment spike in one country is lined up to the same Forensic Accounting population.
• Intercompany elimination mismatch report is closer to Temporary compensating control after an FCPA agent-payment spike in one country; Remove access or reverse the item would over-claim this Revenue Integrity extract.
• Approve a documented exception is still live in intercompany elimination mismatch report for FCPA investigation lead in a pre-IPO SaaS company drafting an S-1.
• Intercompany elimination mismatch report is missing the fact FCPA investigation lead needs after an FCPA agent-payment spike in one country; stop this Forensic Accounting close.

Analysis required

• Reconstruct vendor, journal, or inventory lines in intercompany elimination mismatch report through the window opened by an FCPA agent-payment spike in one country.
• Trace approval, SoD, and related-party links that intercompany elimination mismatch report actually shows.
• Test cutoff, reversals, and system-of-record ties for materiality on cash ever economically changed.
• For this Forensic Accounting Revenue Integrity file, read intercompany elimination mismatch report against an FCPA agent-payment spike in one country and write the one fact that would move cash ever economically changed for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Revenue Integrity packet (intercompany elimination mismatch report after an FCPA agent-payment spike in one country). The follow-on Revenue Integrity action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.