Assess whether a referral to counsel is warranted (898d5e)

Situation

Management-bonus accrual workbook arrived with a new counterparty formed 19 days before quarter-end for FCPA investigation lead. That is a Forensic Accounting Occupational Fraud decision on a referral to counsel is warranted in a public filer facing a whistleblower memo.

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 management-bonus accrual workbook after a new counterparty formed 19 days before quarter-end.

Hypotheses to test

• The population in management-bonus accrual workbook is the one a new counterparty formed 19 days before quarter-end named, so Remove access or reverse the item follows for this Occupational Fraud file.
• The population in management-bonus accrual workbook is adjacent only to a new counterparty formed 19 days before quarter-end; Temporary compensating control is the honest Forensic Accounting call.
• A public filer facing a whistleblower memo already contained a new counterparty formed 19 days before quarter-end before management-bonus accrual workbook arrived; no new Occupational Fraud path.
• Provenance on management-bonus accrual workbook after a new counterparty formed 19 days before quarter-end 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 public filer facing a whistleblower memo.
• Reconstruct vendor, journal, or inventory lines in management-bonus accrual workbook through the window opened by a new counterparty formed 19 days before quarter-end.
• For this Forensic Accounting Occupational Fraud file, read management-bonus accrual workbook against a new counterparty formed 19 days before quarter-end 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 (management-bonus accrual workbook after a new counterparty formed 19 days before quarter-end). The follow-on Occupational Fraud action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.