Assess whether a referral to counsel is warranted after a PE

Situation

In a pre-IPO SaaS company drafting an S-1, ghost-employee payroll extract is the evidence after a PE quality-of-earnings request arriving Friday. FCPA investigation lead has to pick Remove access or reverse the item or Temporary compensating control for this Forensic Accounting Revenue Integrity close using ghost-employee payroll extract.

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 ghost-employee payroll extract after a PE quality-of-earnings request arriving Friday.

Hypotheses to test

• The population in ghost-employee payroll extract is the one a PE quality-of-earnings request arriving Friday named, so Remove access or reverse the item follows for this Revenue Integrity file.
• The population in ghost-employee payroll extract is adjacent only to a PE quality-of-earnings request arriving Friday; Temporary compensating control is the honest Forensic Accounting call.
• A pre-IPO SaaS company drafting an S-1 already contained a PE quality-of-earnings request arriving Friday before ghost-employee payroll extract arrived; no new Revenue Integrity path.
• Provenance on ghost-employee payroll extract after a PE quality-of-earnings request arriving Friday is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Quantify the entry if FCPA investigation lead has to reverse it.
• Separate a close-process miss from a qualitative SAB 99 issue in a pre-IPO SaaS company drafting an S-1.
• Reconstruct vendor, journal, or inventory lines in ghost-employee payroll extract through the window opened by a PE quality-of-earnings request arriving Friday.
• For this Forensic Accounting Revenue Integrity file, read ghost-employee payroll extract against a PE quality-of-earnings request arriving Friday 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 / Revenue Integrity packet (ghost-employee payroll extract after a PE quality-of-earnings request arriving Friday). Lead with the Forensic Accounting option ghost-employee payroll extract can support after a PE quality-of-earnings request arriving Friday, then the two facts that force it, then the Monday action for FCPA investigation lead in a pre-IPO SaaS company drafting an S-1.