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