FCPA investigation lead must resolve whether related-party revenue

Situation

A new counterparty formed 19 days before quarter-end put bill-and-hold side-letter folder in front of FCPA investigation lead in a pre-IPO SaaS company drafting an S-1. This Forensic Accounting / Revenue Integrity close is related-party revenue is arm's-length from bill-and-hold side-letter folder, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

FCPA investigation lead in a pre-IPO SaaS company drafting an S-1 must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using bill-and-hold side-letter folder after a new counterparty formed 19 days before quarter-end.

Hypotheses to test

• The population in bill-and-hold side-letter folder is the one a new counterparty formed 19 days before quarter-end named, so Remove access or reverse the item follows for this Revenue Integrity file.
• The population in bill-and-hold side-letter folder is adjacent only to a new counterparty formed 19 days before quarter-end; Temporary compensating control is the honest Forensic Accounting call.
• A pre-IPO SaaS company drafting an S-1 already contained a new counterparty formed 19 days before quarter-end before bill-and-hold side-letter folder arrived; no new Revenue Integrity path.
• Provenance on bill-and-hold side-letter folder 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

• Separate a close-process miss from a qualitative SAB 99 issue in a pre-IPO SaaS company drafting an S-1.
• Reconstruct vendor, journal, or inventory lines in bill-and-hold side-letter folder through the window opened by a new counterparty formed 19 days before quarter-end.
• Trace approval, SoD, and related-party links that bill-and-hold side-letter folder actually shows.
• For this Forensic Accounting Revenue Integrity file, read bill-and-hold side-letter folder against a new counterparty formed 19 days before quarter-end and write the one fact that would move related-party revenue is arm's-length for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Revenue Integrity packet (bill-and-hold side-letter folder after a new counterparty formed 19 days before quarter-end). The follow-on Revenue Integrity action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.