How should you assess your internal controls regime for international operations? It is incumbent that you need to review as much information as you can to understand an entity’s financial and operational structure and how it is integrated with the corporate headquarters or the U.S. business unit’s financial and operational structure if the foreign operation is part of a U.S. business unit.
You could begin with the TI-CPI to garner a sense of the reputation of the country in which your business unit is located, as well as the CPI for all other countries in which the location either markets business or has current customers. Another area for inquiry or review is the scope of your foreign operations. Other areas of inquiry should include whether your company’s finance and accounting staff produce financial statements that are integrated into the parent’s financial statements, whether your international business locations utilize a local bank account for local sales receipts as well as funds transfers from the U.S. and whether the account has local check signers and whether dual signatures are required on the checks. You may also want to consider the extent to which disbursements are made in the local currency and whether there is a local petty cash fund.
As with many other areas around internal controls, it is important to consider the local DOA and whether it is consistent with your corporate DOA. Some of the considerations regarding the local DOA should extend to which corporate or U.S. business unit approvals are required for transactions initiated locally, such as 1) approval of vendor invoices; 2) disbursements of funds, including wire transfers; 3) execution of facilities leases; 4) execution of contracts with agents; and 5) approval of pricing and credit terms to customers and distributors. You should also review whether the local DOA provides appropriate SODs at the local business unit level.
These reviews, questions, inquiries, and analyses are designed to locate the pressure points involved in any company’s sales processes. This is because pressure is a key element of occupational fraud, and the risk of fraud, including corruption, increases as the pressure increases. Since corruption is viewed as a subset of fraud, it might be a good time to review the “fraud triangle,” which lays out a breeding ground for fraud in the corruption context.
Three key takeaways:
1. You must understand your company’s financial and operational structure and how that structure outside the U.S. is integrated with the corporate headquarters.
2. Are your financial statements and reporting systems integrated?
3. Always consider the fraud triangle.
