Assess whether a referral to counsel is warranted (1ffef6)

Situation

A referral to counsel is warranted sits with FCPA investigation lead because an SEC comment letter on revenue hit a county government payroll environment. Evidence is intercompany elimination mismatch report; write the Forensic Accounting Inventory and Cash Schemes option that extract can carry.

Decision

FCPA investigation lead in a county government payroll environment must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using intercompany elimination mismatch report after an SEC comment letter on revenue.

Hypotheses to test

• The population in intercompany elimination mismatch report is the one an SEC comment letter on revenue named, so Remove access or reverse the item follows for this Inventory and Cash Schemes file.
• The population in intercompany elimination mismatch report is adjacent only to an SEC comment letter on revenue; Temporary compensating control is the honest Forensic Accounting call.
• A county government payroll environment already contained an SEC comment letter on revenue before intercompany elimination mismatch report arrived; no new Inventory and Cash Schemes path.
• Provenance on intercompany elimination mismatch report after an SEC comment letter on revenue 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 intercompany elimination mismatch report 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 Inventory and Cash Schemes file, read intercompany elimination mismatch report against an SEC comment letter on revenue 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 / Inventory and Cash Schemes packet (intercompany elimination mismatch report after an SEC comment letter on revenue). The follow-on Inventory and Cash Schemes action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.