Whether a referral to counsel is warranted from intercompany elimination

Situation

Revenue Integrity work in a public filer facing a whistleblower memo now turns on a referral to counsel is warranted because an FCPA agent-payment spike in one country put intercompany elimination mismatch report in play. External counsel's accounting expert should say what intercompany elimination mismatch report proves.

Decision

External counsel's accounting expert in a public filer facing a whistleblower memo must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using intercompany elimination mismatch report after an FCPA agent-payment spike in one country.

Hypotheses to test

• Intercompany elimination mismatch report reads as Remove access or reverse the item once an FCPA agent-payment spike in one country is lined up to the same Forensic Accounting population.
• Intercompany elimination mismatch report is closer to Temporary compensating control after an FCPA agent-payment spike in one country; Remove access or reverse the item would over-claim this Revenue Integrity extract.
• Approve a documented exception is still live in intercompany elimination mismatch report for external counsel's accounting expert in a public filer facing a whistleblower memo.
• Intercompany elimination mismatch report is missing the fact external counsel's accounting expert needs after an FCPA agent-payment spike in one country; stop this Forensic Accounting close.

Analysis required

• Reconstruct vendor, journal, or inventory lines in intercompany elimination mismatch report through the window opened by an FCPA agent-payment spike in one country.
• Trace approval, SoD, and related-party links that intercompany elimination mismatch report actually shows.
• Test cutoff, reversals, and system-of-record ties for materiality on a referral to counsel is warranted.
• For this Forensic Accounting Revenue Integrity file, read intercompany elimination mismatch report against an FCPA agent-payment spike in one country and write the one fact that would move a referral to counsel is warranted for external counsel's accounting expert.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Revenue Integrity packet (intercompany elimination mismatch report after an FCPA agent-payment spike in one country). The follow-on Revenue Integrity action is what external counsel's accounting expert does next: implement the option, assign an owner, and log the missing fact.