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Compliance Initiative. Mohan Iyer FSCP Solutions Inc. mohan@fscpsolutions.com. ? Compliance ?. Sarbanes Oxley (SoX) – Act of 2002 Mostly due to the Enron and MCI fiasco Has crept into every task – manual and system related
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Compliance Initiative Mohan Iyer FSCPSolutions Inc. mohan@fscpsolutions.com OAUG Multi-National SIG Group
? Compliance ? • Sarbanes Oxley (SoX) – Act of 2002 • Mostly due to the Enron and MCI fiasco • Has crept into every task – manual and system related • Systems are not yet upto mark for adapting and managing compliance requirements
? Compliance ? • Main features • Segregation of duties • System controls • Manual compensating controls • Process narratives • Spot audits • CFO and CEO accountabilty
? Compliance ? • Directed at addressing needs for SoX • Mainly US centric • International Standards (IASB) • Europe • Asia • Australia • Specific fiscal reporting and other concerns
? Compliance ? • Typical Implementation • Corporate HQ in US • US centric processes • Overseas subsidiary offices • Smaller headcount in overseas offices • Segregation of duties issues • Process driven issues with differences in narratives and practicality • Specific fiscal reporting • Other regional requirement concerns
? Compliance ? • Solutions (?) • Many software companies in the US market products to monitor changes • Some of these packages also perform additional tasks to manage segregation of duties needs • Copious documentation is needed to track changes (depending upon your narrative) • Change management is time consuming and laborious – in most cases
? Compliance ? • Lessons Learnt (?) • Impact • Time and resource intensive • Process changes needed in most cases • Understanding the risk matrix is important • Understanding the solutions • All need not be systematic, many can be compensating or manual controls • Frustration with auditors who are not knowledgeable about the system