Digging Into Your Internal Controls

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2 Responses

  1. Pete Viksnins says:

    Michael, while in general I agree with the spirit of the post, I would offer a couple thoughts – first, the SEC famously modified the concept of materiality by talkng about quantitative vs qualitative materiality (google Harvey Pitt’s 1998 speech). Second, it’s not always simply about controlling disbursements – consider, for example, the Schnitzer Steel settlement, where cash from scrap metal sales were the source of the value allegedly transferred to officials. People are creative, and the methodologies of corruption evolve daily!

  1. February 4, 2016

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