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Control Chatter                                                   July 2020
News that Control Professionals Need to Know


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In This Issue
Internal Control and the Pandemic
Bitcoin scam shows Twitter needs better internal controlsticle Headline
A CEO's Guide to FCPA Compliance
Goldman to pay Malaysia $3.9 billion
2020 has been a crazy year for the FCPA too
Brazilian airline Gol fires auditor weeks after it raised red flags
Three Lines Model for risk management gets major update
Novartis' FCPA Settlement and New Compliance Guidance
Weak Internal Control Systems As Doorway to Corruption
 
HELP US IMPROVE INTERNAL CONTROL SYSTEMS WORLDWIDE
PARTNERS WANTED: 

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The Internal Control Institute™ (ICI) improves organizational Internal Control worldwide by providing training, products and services and individual Professional Certifications recognized internationally. The Institute's Board of Advisors has determined it would like to further expand into areas where it is not directly represented. ICI provides world-class programs and its intellectual property to affiliates free of charge and shares all program revenue with them. If your organization is interested in partnering with ICI to earn revenue while you contribute to the development of the internal control profession worldwide please contact Dr. Michael Pregmon, Jr., Chief Operations Officer, by email at:  [email protected]  or by phone at  727-538-4113   in the USA. 
Test your Knowledge of Internal Control
The Internal Control Institute has developed a CICS Common Body of Knowledge Mini-Assessment that helps an individual determine their knowledge as it relates to governance and control practices. Results point out areas of knowledge that may require additional training and experience. The assessment also provides a measurement to the individual's readiness for CICS certification. The assessment measures core knowledge in eight critical areas including: Internal Control - Principles, Terms and Concepts, Internal Control Environment, Risk Management, Assessing Application Controls, Business System Control Assessment, Risk Assessment, Internal Control Measurement and Reporting, and Governance Practices
 Internal Control online courses
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Start becoming an Internal Control professional today!
The ICI "Certification Series" has been completely updated and is available online to everyone around the world!  Course content prepares individuals to design and/or assess internal control and to assist management in installing internal control processes. In addition, the series prepares candidates for the Certified Internal Control Specialist (CICS) Examination.
To review the course catalog click here: ICI Course Catalog
To register for one or all of the online training programs click here:  
Online course pricing has been reduced by over 70% 
Internal Control and the Pandemic
By Michael Pregmon, Jr., Ph.D., CICP
COO and Managing Director
Dr. Michael Pregmon, Jr.
COO and Managing Director 
Much has been already written about the Covid19 Coronavirus Pandemic and will continue to capture our headlines. This has markedly changed our lives. Few challenges are so far-reaching as this. This is an excellent example of a gross failure of control in all aspects. I suppose we can really say that whenever most problems occur, the underlining reason is typically poor internal control practices in some fashion.
 
Supposedly, the origin of the pandemic occurred from the sale of tainted products at a "wet market" in Asia. A wet market is described as a marketplace where products for consumption are sold that are not guaranteed to have been checked for safety, purity, and wholesomeness.   In this case, there was no guarantee before sale as having been inspected for quality and safety. Essentially, no product safety inspection and control prevailed in this distribution channel. So, the problem began since this is a highly contagious virus.
 
As we "fast-forward" this challenge worldwide, we learned that the virus can be controlled, and infections reduced by limiting personal contact between individuals. This led to lockdowns and social distancing. There were additional control mechanisms installed. And, a reduction of viral incidences occurred. However, once the Lockdown posture was relaxed, the severity of the pandemic continued to increase. It appears the challenge will continue until we come upon a vaccine or cure to specifically halt the virus.
 
How does this relate to our daily challenges in internal control in business?
Obviously, most business challenges requiring controls are not life threatening as is the Covid19. But in essence, the challenge is similar. If we don't have controls, chaos often results, as has occurred with the wet market described above. When controls are relaxed, the problem often reoccurs as has resulted with the pandemic lockdown relaxation.
 
This a lesson worth remembering!
ICI ANNOUNCEMENTS
ICI Affiliate News :

ICI WELCOMES NEW PARTNER


ICI has entered into an agreement with Internal Control Institute of Cameroon ("ICI Cameroon") as its representative for Products, Services and Internal Control Certifications (CICS/CICP) in this territory. ICI Cameroon will be responsible for all development activities in this area, including professional training and Certification.  Individuals or companies interested in internal control training or Certification should contact:
Contact: Eric Kamegne

***************

The Internal Control Institute is conducting certification training in a classroom and online formats for the internationally recognized CICS (Certified Internal Control Specialist) certification in internal control. Information on these programs regarding dates and schedules can be found on the Events tab on our Website (Events) or directed to the affiliate named below:

Botswana:
ICI has entered into an agreement with Internal Control Institute of Botswana (ICI Botswana":) as its representative for Products, Services and Internal Control Certifications (CICS/CICP) in this territory. ICI Botswana will be responsible for all development activities in this area, including professional training and Certification.  Individuals or companies interested in internal control training or Certification should contact:
Humphrey Chawafambira
E-Mail:  [email protected]


Brazil:
Training Plans :

Sao Paulo - 24 to 28 of August
Belo Horizonte - 21 to 25 September
Rio de Janeiro - 5 to 8 October

For more details on planned training please visit the website below, or send a message to Mr. Eduardo Person Pardini. 

China:  
Online CICS training and exams are being conducted due to COVID-19.  The next course runs from
12 August to 6 September 2020.

Individuals or companies interested in inter nal control training and Certification should contact:  
Mr. Qiu Jianting of  CCSIT
Room 1039, Block A, Jinmao Building, No. 18, 
Xizhimenwai Street,
Xicheng District, Beijing, China
Zip Code: 100044
Mobile phone: 13810588109
Email:  
Website:  http://neikong.com/

Europe: 


Training Plans :

ICI Belgium has  started the CICS session in French with 22 participants.
Next sessions are planned in Brussels:
  • Dutch: October 2nd 2020
  • French : January 2021
For more information on scheduled training and exams please contact Mr.Yves Dupont of ICI Belgium at: 
  
India
For more information on upcoming activities in this area please contact Mr. Summit Goyal of  ICI India at :
E-mail:  [email protected]
Phone: +91 9810575613


Myanmar and Cambodia:
Better Business Governance - APAC PTE LTD (BBG) has become a representative for Products, Services and Internal Control Certifications (CICS/CICP) in Myanmar and Cambodia.  Better Business Governance will be responsible for all development activities, including professional training and Certification.  For more information on upcoming activities in this area please contact:
Better Business Governance
Mr. Sanjeev Gathani
1 Claymore Drive
#08-14, Orchard Towers (Rear Block)
Singapore 229594
E-mail:  [email protected]
  
Mexico:
For more information on upcoming activities in this area please contact the following:
Antonio Salas Hernandez CICP,  Email:  [email protected] 
Joaquin Prendes Herrera, Email:  [email protected] 

Middle East:
The CICS exam is now being  provided in Arabic.  Osool Training and Consulting has courses and testing available in Egypt, Jordan, Libya, Muscat, Sudan, Qatar, the United Arab Emirates, Kuwait and Palestine. 

Training Plans: 

30 August - 3 September 2020 - Amman, Jordan
13 - 17 September 2020 - Muscat, Oman
18 - 22 October 2020 - Amman, Jordan

Interested applicants in the region should contact Osool for scheduling for future programs.  For additional information on scheduled ICI Certification and program sessions, please contact:
Lina Salameh
Assistant General Manager
O SOOL for Training & Consulting
Mob Oman:  +968 95 98 98 20
Mob Jordan: +962 7 99589666
Tel:   +962 6 5927171 Ext. 107
Fax:  +962 6 5927172

Nigeria:  
Leadway Consulting conducts CICS training sessions and examinations in Nigeria. For more information on upcoming activities in Nigeria  please contact:
Mr.  Joel Aluko  [email protected]


Pakistan:

For more information on activities in Pakistan individuals or companies should contact : Muhammad Farooq Hammodi
E-Mail: nardac_k@yahoo.com


Romania:

ICI Romania is planning a CICS course session on October 5 - 7, 2020 and an examination on November 9, 2020.



For more information on activities in Romania contact : 
Cosmin Serbanescu at the National Institute for Internal Control in Romania.
Tel:  + 40 752 525 525

 

Singapore, Malaysia, Indonesia and Taiwan China:
ICI has entered into an agreement with GRC Consultancy Pte Ltd. (ICI Singapore, Malaysia, Indonesia and Taiwan) as its representative for Products, Services and Internal Control Certifications (CICS/CICP) in those territories.  

Individuals or companies interested in internal control training or Certification should contact:
General enquiries for all 4 markets - [email protected]
Singapore - Mr. Bob Seetoh - [email protected]
MalaysiaMr. Melvin Beh[email protected]
IndonesiaMr. Melvin Beh -  [email protected]
Taiwan China - Mr. Bob Seetoh - [email protected]


Tunisia

ICI has entered into an agreement with  Business and Financial Consulting  company in  the Republic of Tunisia  (hereinafter referred to as "ICI BFC"  as its representative for Products, Services and Internal Control Certifications (CICS/CICP) in the Republic of Tunisia ICI BFC will be responsible for all development activities in this area, including professional training and Certification.  Individuals or companies interested in internal control training or Certification should contact:
Contact: Nadia Yaich
E-Mail:   [email protected]

Turkey:

For more information on activities being planned please contact:



Ms. Ilknur Tunc,  VP - [email protected]
Dr. Bertan Kaya -  [email protected]
GOP Mahallesi, İran Caddesi, Karum İs Merkezi
No:21, D Blok, 4. Kat, D:398-399
06700
Kavaklıdere/Çankaya/Ankara
+90 (312) 4425015 T
+90 (533) 4474444 D
 
Vietnam:
Training Plan:
Course name
start day
duration
CICS®
preparation

4 days
On Saturday and Sunday
08:30
am - 12:00 am
13:30
pm - 17:00 pm
10/10/2020
 
For more information on upcoming activities in Vietnam please contact: NGUYEN THANH TUNG (MBA. M.Eng, PhD.) Director, FMIT Institute of Financial Management & Information Technology,  Level 5 , 126 Nguyen Thi Minh Khai Street, Ward 6, District 3, HCMC, Viet Nam
Office: 848 3803 5020 - 848 3512 9371 - 848 3512 7652
Website: www.fmit.edu.vn

Zimbabwe:
The Internal Control Institute Of Zimbabwe will be running CICS Classes on the following dates:    
           27-30 October 2020
          8-11   December 2020

For more information on activities being planned please contact:
Dr. Proctor Nyemba at:  [email protected]
Internal Control Chatter  
Each month the staff of The Internal Control Institute reviews hundreds of articles related to Internal Control and Corporate Governance. Here are brief summaries of some of the top articles (along with links to the original article) that may be of interest to you.
Bitcoin scam shows Twitter needs better internal controls, expert says
by Mike Chapple
techxplore.com
JULY 17, 2020
In what appears to be a "coordinated social engineering attack," Bitcoin hackers July 15 took control of dozens of high-profile Twitter accounts, including those of Joe Biden, Barack Obama, Bill Gates, Mike Bloomberg, Jeff Bezos, Elon Musk, and Kanye West, and used them to post messages urging people to send thousands of dollars in cryptocurrency.
The compromised accounts of the politicians, tech executives, major companies and celebrities posted fake tweets offering to send $2,000 for every $1,000 contributed to an anonymous Bitcoin address. Twitter temporarily disabled the accounts and announced "what we believe to be a coordinated attack by people who successfully targeted some of our employees with access to internal systems and tools."
A CEO's Guide to FCPA Compliance
If you have questions regarding your company's Foreign Corrupt Practices Act ("FCPA") compliance policy or are worried about an impending federal investigation, you cannot afford to make uninformed decisions. Companies that lack adequate FCPA compliance policies are often targeted by federal authorities due to the increased risk and occurrences of bribery and corruption. Charges under the FCPA can result in significant civil and criminal penalties - including federal imprisonment - and damage to your company's (and your personal) reputation. As a result, FCPA compliance is the crucial for establishing a business environment in which corruption is not tolerated.  CEOs Play a Critical Role in Implementing and Executing Their Companies' FCPA Compliance Programs.  Many CEOs underestimate the positive impact that they personally can have on their companies' FCPA compliance efforts. However, a tone-at-the-top business culture punctuated with strong CEO leadership is critical to effectively implementing anti-corruption and anti-bribery policies and procedures on a company-wide scale.
Read The Article
Goldman to pay Malaysia $3.9 billion over 1MBD scandal, U.S. settlement seen close
Goldman Sachs will pay $3.9 billion to settle Malaysia's criminal probe over the U.S. investment bank's role in the multibillion-dollar 1MDB scandal, closing a key front in the multi-jurisdictional investigation that has hung over Goldman.  Goldman Sachs shares rose 0.68% in New York morning trading on the Malaysia news and signals the U.S. Department of Justice could be near closing a similar probe. A spokesman for the Justice Department declined to comment. "We view this as positive as GS is closer to removing a key overhang for investors, and this provides added comfort that the total settlement amount should be manageable," wrote Steven Chubak, an analyst at New York-based Wolfe Research.
Read The Article
2020 has been a crazy year for the FCPA too
by Bill Steinman
While we have understandably been distracted by the challenges of 2020 - from serious concerns about our health and the well-being of our loved ones to not-so-serious concerns of how we look on video conferences - things in the FCPA world have been humming along. In fact, this year has seen some remarkable FCPA developments that will put it in the record books. We've seen several court cases interpreting the FCPA, major enforcement actions, and new policy pronouncements from the enforcement agencies. All while we've been working in our PJs at our dining room tables. Let's start with the biggest buzz of 2020 - the  second edition  of the official FCPA Resource Guide, released by the DOJ and the SEC on July 3rd. 
Brazilian airline Gol fires auditor weeks after it raised red flags
Brazil's Gol Linhas Aereas Inteligentes said late on Wednesday that it had fired KPMG as its external auditor, weeks after it raised red flags about the airline's internal controls and ability to survive the coronavirus crisis.  Gol said "there were no disagreements" with KPMG relating to the airline's accounting processes, internal controls or financial statements.
 In mid-June, KPMG raised two significant concerns about Gol during the accounting firm's first annual audit of the company after being hired in 2019. The concerns prompted Gol to carry out a review of its financial reporting procedures that lasted a couple of weeks before being finalized.  KPMG said it had an "adverse opinion" on the strength of Gol's internal controls regarding the preparation of financial statements, adding that there was "substantial doubt" about the airline's ability to exist a year from now.  Ultimately, KPMG reaffirmed its concerns and included the red flags on June 29 as part of Gol's annual report for the year 2019.
Three Lines Model for risk management gets major update
By Ken Tysiac
July 20, 2020
A new model for governance and risk management issued Monday by the Institute of Internal Auditors (IIA) makes major updates to the Three Lines of Defense model that has been popular for years. Called " The Three Lines Model ," the new approach is designed to help organizations identify structures and processes that best assist the achievement of objectives and facilitate strong governance and risk management.
Novartis' FCPA Settlement and New Compliance Guidance
jdsupra.com
July 21, 2020
In late June, the U.S. Department of Justice ("DOJ") and Securities and Exchange Commission ("SEC") announced that Novartis AG and Alcon Pte Ltd, a former subsidiary of the Swiss drug maker, agreed to pay a combined $347 million to resolve allegations that the companies engaged in corrupt conspiracies to bribe public hospitals and clinics in Greece, Vietnam, and South Korea. This settlement was the result of an investigation jointly performed by the DOJ and SEC into alleged criminal and civil violations of the Foreign Corrupt Practices Act ("FCPA"), and takes place against the backdrop of updated FCPA compliance guidance recently issued by DOJ.  The corrupt scheme by Novartis' Greek subsidiary, Novartis Hellas S.A.C.I., to bribe employees of Greek state-owned and state-controlled hospitals and clinics involved sponsoring travel to international medical conferences, including events held in the U.S.
 Read The Article
Weak Internal Control Systems As Doorway to Corruption
By Uche Uwaleke
21 JULY 2020
Nigeria:
The disturbing revelations emanating from the current trial of Ibrahim Magu, the former acting Chairman of the EFCC, speak volumes about the weak internal control system in an agency established to fight financial and money laundering crimes in the country.
Internal control system is simply the system of controls put in place by the management of an organisation to safeguard its assets and ensure it is run in an efficient and effective manner.  A key element of internal control system is segregation of duties such that no one individual initiates and executes a transaction to the end regardless of the position in the organisation.  If this were in place in EFCC, then Magu would not allegedly get the opportunity to initiate recoveries, receive the money and decide where such money is kept.
Control Quotes
"Happiness is inside job. Don't assign anyone else that much power over your life."
Mandy Hale

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ici logo The Internal Control Institute™ (ICI) is a worldwide organization  devoted exclusively to internal control and corporate governance. The Institute is dedicated to the development of world-class educational programs and best practice guidelines on internal control and corporate governance, based on the Sarbanes-Oxley Act and the COSO internal control framework.  Visit us on the web at the Internal Control Institute
Control Chatter is a monthly news summary of the top stories concerning internal control and corporate governance.  Control Chatter is prepared by the staff of Internal Control Institute for the benefit of their members and associates. Please consider it for your personal use or pass it on to associates who may have an interest in one or more of the topics by clicking on the Forward email button below.