Assess whether a referral to counsel is warranted (f6cca0)

Situation

A public filer facing a whistleblower memo cannot treat a warehouse count that came in 11% light as color commentary on intercompany elimination mismatch report. FCPA investigation lead must close a referral to counsel is warranted from that extract under Forensic Accounting / Occupational Fraud.

Decision

FCPA investigation lead in a public filer facing a whistleblower memo must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using intercompany elimination mismatch report after a warehouse count that came in 11% light.

Hypotheses to test

• Authorize Remove access or reverse the item now; intercompany elimination mismatch report already has the discriminator after a warehouse count that came in 11% light.
• Keep Temporary compensating control in force until intercompany elimination mismatch report is completed after a warehouse count that came in 11% light for FCPA investigation lead.
• Treat intercompany elimination mismatch report as Approve a documented exception because both readings appear after a warehouse count that came in 11% light.
• Refuse a Forensic Accounting close: FCPA investigation lead does not have the page a referral to counsel is warranted turns on in intercompany elimination mismatch report.

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 public filer facing a whistleblower memo.
• Reconstruct vendor, journal, or inventory lines in intercompany elimination mismatch report through the window opened by a warehouse count that came in 11% light.
• For this Forensic Accounting Occupational Fraud file, read intercompany elimination mismatch report against a warehouse count that came in 11% light 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 / Occupational Fraud packet (intercompany elimination mismatch report after a warehouse count that came in 11% light). If intercompany elimination mismatch report cannot force a Forensic Accounting label under Occupational Fraud, stop. If intercompany elimination mismatch report after a warehouse count that came in 11% light cannot support Remove access or reverse the item versus Temporary compensating control on this Forensic Accounting Occupational Fraud close, FCPA investigation lead must do not infer a control or scheme beyond the transaction and entitlement evidence.