Assess whether bonus triggers were gamed by cutoff (11b987)

Situation

After a whistleblower email to the hotline, AP vendor-master change log is what FCPA investigation lead can touch in a construction contractor on percentage-of-completion. Forensic Accounting will live with Remove access or reverse the item versus Temporary compensating control on this Related-Party and Corruption Risk file.

Decision

FCPA investigation lead in a construction contractor on percentage-of-completion must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using AP vendor-master change log after a whistleblower email to the hotline.

Hypotheses to test

• Authorize Remove access or reverse the item now; AP vendor-master change log already has the discriminator after a whistleblower email to the hotline.
• Keep Temporary compensating control in force until AP vendor-master change log is completed after a whistleblower email to the hotline for FCPA investigation lead.
• Treat AP vendor-master change log as Approve a documented exception because both readings appear after a whistleblower email to the hotline.
• Refuse a Forensic Accounting close: FCPA investigation lead does not have the page bonus triggers were gamed turns on in AP vendor-master change log.

Analysis required

• Separate a close-process miss from a qualitative SAB 99 issue in a construction contractor on percentage-of-completion.
• Reconstruct vendor, journal, or inventory lines in AP vendor-master change log through the window opened by a whistleblower email to the hotline.
• Trace approval, SoD, and related-party links that AP vendor-master change log actually shows.
• For this Forensic Accounting Related-Party and Corruption Risk file, read AP vendor-master change log against a whistleblower email to the hotline and write the one fact that would move bonus triggers were gamed for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Related-Party and Corruption Risk packet (AP vendor-master change log after a whistleblower email to the hotline). The follow-on Related-Party and Corruption Risk action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.