Over the past few months we have seen an unprecedented level of disruption to our normal lives and day-to-day processes as result of COVID-19. With remote work, workforce disruptions, and a diverted focus to customer and employee safety, commercial viability, and the possibility of a global recession – there are numerous opportunities for internal controls to be shortcut or circumvented.
As organizations revisit their priorities, compliance with Sarbanes-Oxley 404 (SOX) and an appropriate internal control environment are not areas that can be deferred or ignored. While the situation continues to be extremely fluid, and there are many unanswered questions, there are a number of items to consider related to your SOX program. We believe that being proactive is critical to your organization’s control environment and that early action will minimize possible future cost and control implications.
An opportunity for the SOX function to add value by providing guidance to the organization on practical ways to modify control procedures
Often a SOX function is seen purely as a compliance program mandated by a regulation, and more specifically, a testing function. In these turbulent times where decisions are being made rapidly, this is an opportunity for the SOX function to be a controls advisor, providing practical, realtime input on ways to modify controls to address a rapidly changing environment. As organizations struggle to move to a virtual workforce, with absent or reduced workforces, and in some cases finding that certain third parties are not able to provide support, there is an opportunity for the SOX function to show value. As control experts, the SOX function should be proactive in their involvement in redesigning and modifying control activities to be reactive to the fluid business situations, offering guidance on the specific risks that controls are intended to mitigate and practical ways in which the design or execution of those controls can be modified to accommodate these unprecedented changes.
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