Assess whether a referral to counsel is warranted (4b9ac0)

Situation

The desk packet is quarter-end revenue reversal cluster after an SEC comment letter on revenue. FCPA investigation lead in a public filer facing a whistleblower memo has to name Remove access or reverse the item or Temporary compensating control for this Forensic Accounting Occupational Fraud file.

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 quarter-end revenue reversal cluster after an SEC comment letter on revenue.

Hypotheses to test

• Authorize Remove access or reverse the item now; quarter-end revenue reversal cluster already has the discriminator after an SEC comment letter on revenue.
• Keep Temporary compensating control in force until quarter-end revenue reversal cluster is completed after an SEC comment letter on revenue for FCPA investigation lead.
• Treat quarter-end revenue reversal cluster as Approve a documented exception because both readings appear after an SEC comment letter on revenue.
• Refuse a Forensic Accounting close: FCPA investigation lead does not have the page a referral to counsel is warranted turns on in quarter-end revenue reversal cluster.

Analysis required

• Reconstruct vendor, journal, or inventory lines in quarter-end revenue reversal cluster through the window opened by an SEC comment letter on revenue.
• Trace approval, SoD, and related-party links that quarter-end revenue reversal cluster actually shows.
• Test cutoff, reversals, and system-of-record ties for materiality on a referral to counsel is warranted.
• For this Forensic Accounting Occupational Fraud file, read quarter-end revenue reversal cluster 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 / Occupational Fraud packet (quarter-end revenue reversal cluster after an SEC comment letter on revenue). The follow-on Occupational Fraud action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.