Assess whether a referral to counsel is warranted (1f38c5)

Situation

A referral to counsel is warranted sits with FCPA investigation lead because a controller resignation with no documented handoff hit a construction contractor on percentage-of-completion. Evidence is ghost-employee payroll extract; write the Forensic Accounting Related-Party and Corruption Risk option that extract can carry.

Decision

FCPA investigation lead in a construction contractor on percentage-of-completion must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using ghost-employee payroll extract after a controller resignation with no documented handoff.

Hypotheses to test

• FCPA investigation lead can defend Remove access or reverse the item from ghost-employee payroll extract after a controller resignation with no documented handoff in a Forensic Accounting challenge.
• FCPA investigation lead cannot defend Remove access or reverse the item from ghost-employee payroll extract; Temporary compensating control is what the extract actually supports after a controller resignation with no documented handoff.
• A controller resignation with no documented handoff never reached the population in ghost-employee payroll extract — reopen intake, do not close a referral to counsel is warranted.
• Two facts in ghost-employee payroll extract after a controller resignation with no documented handoff conflict for FCPA investigation lead; hold this Related-Party and Corruption Risk file.

Analysis required

• Trace approval, SoD, and related-party links that ghost-employee payroll extract actually shows.
• Test cutoff, reversals, and system-of-record ties for materiality on a referral to counsel is warranted.
• Quantify the entry if FCPA investigation lead has to reverse it.
• For this Forensic Accounting Related-Party and Corruption Risk file, read ghost-employee payroll extract against a controller resignation with no documented handoff and write the one fact that would move a referral to counsel is warranted for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Related-Party and Corruption Risk packet (ghost-employee payroll extract after a controller resignation with no documented handoff). Lead with the Forensic Accounting option ghost-employee payroll extract can support after a controller resignation with no documented handoff, then the two facts that force it, then the Monday action for FCPA investigation lead in a construction contractor on percentage-of-completion.