Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode, Matt Kelly (the coolest guy in compliance) and I go into the weeds to explore recent SEC enforcement actions which Matt characterized as an “internal control Palooza”. We explore what went askance, how to learn from it and how to prevent it going forward.
Some of the highlights include:
- The SEC recently had an “Internal Controls Palooza” of enforcement actions.
- Microsoft demonstrated poor controls over third parties.
- Why do does units need a ‘second set of eyes’ for non-standard discounts?
- What is earnings management and why is it so risky?
- Why do you need robust internal controls when engaging in earnings management?
- Why must internal controls have an auditable trail?
For further reading on Conn’s see Matt’s blog posts:
Conn’s Lessons on Management Estimatesand
More on Embedding, Automating Controls
For further reading on Microsoft see Matt’s blog post:
FCPA Issues Nick Microsoft $25 Million
Finally see Tom’s blog posts
Part 1-Microsoft FCPA Enforcement Actionand
Part 2-the Bribery Schemes