Assess whether a referral to counsel is warranted (34f99b)

Situation

A controller resignation with no documented handoff put round-trip cash circularization file in front of revenue-integrity director in a multi-entity PE roll-up after a bolt-on. This Forensic Accounting / Occupational Fraud close is a referral to counsel is warranted from round-trip cash circularization file, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Revenue-integrity director in a multi-entity PE roll-up after a bolt-on must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using round-trip cash circularization file after a controller resignation with no documented handoff.

Hypotheses to test

• A controller resignation with no documented handoff is noise around an already-controlled Occupational Fraud process in a multi-entity PE roll-up after a bolt-on, given round-trip cash circularization file.
• A controller resignation with no documented handoff is the event in round-trip cash circularization file that forces Remove access or reverse the item for revenue-integrity director under Forensic Accounting.
• Round-trip cash circularization file shows a one-file miss after a controller resignation with no documented handoff, not a Occupational Fraud program failure.
• Round-trip cash circularization file cannot decide a referral to counsel is warranted yet after a controller resignation with no documented handoff; hold is the only Forensic Accounting close a multi-entity PE roll-up after a bolt-on can defend.

Analysis required

• Separate a close-process miss from a qualitative SAB 99 issue in a multi-entity PE roll-up after a bolt-on.
• Reconstruct vendor, journal, or inventory lines in round-trip cash circularization file through the window opened by a controller resignation with no documented handoff.
• Trace approval, SoD, and related-party links that round-trip cash circularization file actually shows.
• For this Forensic Accounting Occupational Fraud file, read round-trip cash circularization file against a controller resignation with no documented handoff and write the one fact that would move a referral to counsel is warranted for revenue-integrity director.

Recommendation