Assess whether a referral to counsel is warranted (2edc25)

Situation

A referral to counsel is warranted sits with FCPA investigation lead because an FCPA agent-payment spike in one country 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 an FCPA agent-payment spike in one country.

Hypotheses to test

• Ghost-employee payroll extract 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.
• Ghost-employee payroll extract 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 Related-Party and Corruption Risk extract.
• Approve a documented exception is still live in ghost-employee payroll extract for FCPA investigation lead in a construction contractor on percentage-of-completion.
• Ghost-employee payroll extract is missing the fact FCPA investigation lead needs after an FCPA agent-payment spike in one country; stop this Forensic Accounting close.

Analysis required

• 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.
• Separate a close-process miss from a qualitative SAB 99 issue in a construction contractor on percentage-of-completion.
• For this Forensic Accounting Related-Party and Corruption Risk file, read ghost-employee payroll extract against an FCPA agent-payment spike in one country 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 an FCPA agent-payment spike in one country). Lead with the Forensic Accounting option ghost-employee payroll extract can support after an FCPA agent-payment spike in one country, then the two facts that force it, then the Monday action for FCPA investigation lead in a construction contractor on percentage-of-completion.