Assess whether a referral to counsel is warranted (88b432)

Situation

A whistleblower email to the hotline put quarter-end revenue reversal cluster in front of FCPA investigation lead in a construction contractor on percentage-of-completion. This Forensic Accounting / Related-Party and Corruption Risk close is a referral to counsel is warranted from quarter-end revenue reversal cluster, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

FCPA investigation lead in a construction contractor on percentage-of-completion must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using quarter-end revenue reversal cluster after a whistleblower email to the hotline.

Hypotheses to test

• A whistleblower email to the hotline is noise around an already-controlled Related-Party and Corruption Risk process in a construction contractor on percentage-of-completion, given quarter-end revenue reversal cluster.
• A whistleblower email to the hotline is the event in quarter-end revenue reversal cluster that forces Remove access or reverse the item for FCPA investigation lead under Forensic Accounting.
• Quarter-end revenue reversal cluster shows a one-file miss after a whistleblower email to the hotline, not a Related-Party and Corruption Risk program failure.
• Quarter-end revenue reversal cluster cannot decide a referral to counsel is warranted yet after a whistleblower email to the hotline; hold is the only Forensic Accounting close a construction contractor on percentage-of-completion can defend.

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 construction contractor on percentage-of-completion.
• Reconstruct vendor, journal, or inventory lines in quarter-end revenue reversal cluster through the window opened by a whistleblower email to the hotline.
• For this Forensic Accounting Related-Party and Corruption Risk file, read quarter-end revenue reversal cluster against a whistleblower email to the hotline 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 / Related-Party and Corruption Risk packet (quarter-end revenue reversal cluster after a whistleblower email to the hotline). Lead with the Forensic Accounting option quarter-end revenue reversal cluster can support after a whistleblower email to the hotline, then the two facts that force it, then the Monday action for FCPA investigation lead in a construction contractor on percentage-of-completion.