Case Study: SOX/JSOX
Overview
Started developing ICFR compliance programs in 2003 before definitive SOX guidance had been issued, and since then have led ICFR programs under JSOX and CSOX guidance as well.
Objective
- No Material Weaknesses
- Strengthen control environment through education
- Compliance with SOX/JSOX/CSOX regulations
- Optimization of ICFR program
Approach
- Pragmatic approach to risk assessment and scoping
- Focusing on key controls and risks that could result in material misstatements
- Creating secondary analytic controls that limit potential exposure of primary control failures
- Educating control users and management on the significance of internal controls
Results
- I have implemented over 10 SOX, Japanese SOX (JSOX) and China SOX (CSOX) programs during my career
- Led and executed SOX/JSOX/CSOX testing at dozens of companies
Value
- Non-compliance or material weaknesses often cost financial executives their jobs
- Optimizing the ICFR program while remaining compliant reduces professional service fees, and minimizes the use of company resources