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Compliance and Internal Audit Services

I have successfully lead the design and development and oversight of Compliance, Internal Controls, Internal Audit and Sarbanes-Oxley compliance programs for multi-national corporations and emerging business' alike. Expert in IT controls and security, compliance with COSO and COBIT risk based methodologies and establishing policies and procedures, I have continuing experience in leading large direct and indirect cross-functional teams in industries that include high tech manufacturing, retail, software, financial services and startups. 

Sarbanes Oxley

The Sarbanes-Oxley Act requires that the management of public companies assess the effectiveness of the internal control of issuers for financial reporting.  Section 404(b) requires a publicly-held company’s auditor to attest to, and report on, management’s assessment of its internal controls.  Learn more from the Management Guide for SOX §404 produced by the Institute of Internal Auditors.

In April 2012, The Jumpstart our Business Startups Act (JOBS Act) was signed into law.  It would generally exempt a new public company from compliance with section 404(b) for the first 5 years it is a public company as long as it does not exceed certain market capitalization or revenue thresholds (called an Emerging Growth Company, or EGC). This Act extends an existing two-year regulatory delay in the implementation of section 404(b) for companies who have had an initial public offering. Importantly, it does not contain an exemption. The Act also contains two provisions urged by the AICPA.  The first allows an EGC to opt-out from being treated as an EGC.  The second makes it clear that existing public companies cannot take advantage of the EGC exemptions even if they otherwise meet the criteria (not exceeding the market capitalization or revenue thresholds and less than 5 years since the IPO).


The COSO framework used to assess internal controls for compliance with the Sarbanes Oxley Act was updated in May 2013 and will require companies to use the new framework by December 2014. Learn more here.


The Committee of Sponsoring Organizations of the Treadway Commission (COSO) is a joint initiative of five private sector organizations, established in the United States, dedicated to providing thought leadership to executive management and governance entities on critical aspects of organizational governance, business ethics, internal control, enterprise risk management, fraud, and financial reporting. COSO has established a common internal control model against which companies and organizations may assess their control systems.


Internal Audit

Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization's operations.


An internal audit function helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluating and improving the effectiveness of risk management, control, and governance processes.



Foreign Corrupt Practices Act

The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. ("FCPA"), was enacted for the purpose of making it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. ​


Click here for the Department of Justice and Security & Exchange Commission Resource Guide to the U.S. Foreign Corrupt Practices Act.


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