Assess whether a referral to counsel is warranted (66231d)

Situation

A county government payroll environment cannot treat a PE quality-of-earnings request arriving Friday as color commentary on round-trip cash circularization file. FCPA investigation lead must close a referral to counsel is warranted from that extract under Forensic Accounting / Inventory and Cash Schemes.

Decision

FCPA investigation lead in a county government payroll environment must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using round-trip cash circularization file after a PE quality-of-earnings request arriving Friday.

Hypotheses to test

• Round-trip cash circularization file reads as Remove access or reverse the item once a PE quality-of-earnings request arriving Friday is lined up to the same Forensic Accounting population.
• Round-trip cash circularization file is closer to Temporary compensating control after a PE quality-of-earnings request arriving Friday; Remove access or reverse the item would over-claim this Inventory and Cash Schemes extract.
• Approve a documented exception is still live in round-trip cash circularization file for FCPA investigation lead in a county government payroll environment.
• Round-trip cash circularization file is missing the fact FCPA investigation lead needs after a PE quality-of-earnings request arriving Friday; stop this Forensic Accounting close.

Analysis required

• Test cutoff, reversals, and system-of-record ties for materiality on a referral to counsel is warranted.
• Quantify the entry if FCPA investigation lead has to reverse it.
• Separate a close-process miss from a qualitative SAB 99 issue in a county government payroll environment.
• For this Forensic Accounting Inventory and Cash Schemes file, read round-trip cash circularization file against a PE quality-of-earnings request arriving Friday 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 / Inventory and Cash Schemes packet (round-trip cash circularization file after a PE quality-of-earnings request arriving Friday). The follow-on Inventory and Cash Schemes action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.