Assess whether a referral to counsel is warranted (430792)

Situation

An FCPA agent-payment spike in one country put quarter-end revenue reversal cluster in front of litigation-support partner in a construction contractor on percentage-of-completion. This Forensic Accounting / Inventory and Cash Schemes close is a referral to counsel is warranted from quarter-end revenue reversal cluster, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Litigation-support partner 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 quarter-end revenue reversal cluster after an FCPA agent-payment spike in one country.

Hypotheses to test

• Authorize Remove access or reverse the item now; quarter-end revenue reversal cluster already has the discriminator after an FCPA agent-payment spike in one country.
• Keep Temporary compensating control in force until quarter-end revenue reversal cluster is completed after an FCPA agent-payment spike in one country for litigation-support partner.
• Treat quarter-end revenue reversal cluster as Approve a documented exception because both readings appear after an FCPA agent-payment spike in one country.
• Refuse a Forensic Accounting close: litigation-support partner does not have the page a referral to counsel is warranted turns on in quarter-end revenue reversal cluster.

Analysis required

• Quantify the entry if litigation-support partner has to reverse it.
• 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 quarter-end revenue reversal cluster through the window opened by an FCPA agent-payment spike in one country.
• For this Forensic Accounting Inventory and Cash Schemes file, read quarter-end revenue reversal cluster against an FCPA agent-payment spike in one country and write the one fact that would move a referral to counsel is warranted for litigation-support partner.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Inventory and Cash Schemes packet (quarter-end revenue reversal cluster after an FCPA agent-payment spike in one country). The follow-on Inventory and Cash Schemes action is what litigation-support partner does next: implement the option, assign an owner, and log the missing fact.