Control Chatter
March 2021
News that Control Professionals need to know
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Test your Knowledge of Internal Control
The Internal Control Institute has developed two mini assessments to test your knowledge. A CICS Common Body of Knowledge Mini Assessment that helps an individual determine their knowledge as it relates to organizational governance and control practices. Results point out areas of knowledge that may require additional training and experience. The assessments also provides a measurement to the individual's readiness for CICS certification.
Start becoming an Internal Control professional today!
The ICI "Certification Series" of online courses
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
To register for one or all of the online training programs click here:
Online course pricing has been reduced by over 70%
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.
Benchmarking Alert: Here’s the full Microsoft anti-corruption policy
Microsoft has one of the most interesting anti-corruption policies we’ve reviewed and the only one to cover two rarely acknowledged topics: extortion and threats. As described in our Standards of Business Conduct, Microsoft’s business relies on the trust we build with our customers, partners and suppliers. Offering or paying bribes or kickbacks breaks that trust. Bribery influences the decisions made by our customers and is inconsistent with Microsoft’s mission to empower every individual and organization on the planet to achieve more.
LexisNexis Risk Solutions Study Reveals Financial Crime Compliance Costs Across Asia-Pacific Region Increased 20.6% Year Over Year
Risk Professionals Expect COVID-19 Will Continue to Drive Higher Costs in 2021
Mar 23, 2021
 LexisNexis® Risk Solutions today released the findings of its latest True Cost of Financial Crime Compliance Study – APAC edition. The survey of compliance professionals identifies the drivers affecting financial crime compliance and highlights spending trends. The study also explores the business impacts of changes in the financial crime compliance environment particularly regarding new regulations and identifies challenges and impacts associated with the COVID-19 pandemic.
Here’s How to Win Business by Turning Compliance Burdens into Competitive Insights
By Michael Post
March 26, 2021
Between amendments to Rule 606 and the implementation of the Consolidated Audit Trail in the U.S., as well as the implementation of MiFID II in Europe, achieving compliance is now a daily focus for firms of all sizes, ramping up cost pressures. All of us desire fairness and transparency in the markets, but the fact is that achieving this through regulatory means often means significant disruption to established workflows. That said, there is no alternative. Whether it’s a censure or a debilitating fine, the cost of non-compliance is high, and rightfully so. No firm wants to deal with the imposed penalties, which may have a far-reaching impact on the business due to reputation loss, suspensions and revocations of licenses – plus, playing by the same rules as everyone else is just the right thing to do.
Top Three FCPA Compliance Mistakes by Newly Public Tech Companies
By Jeffrey A. Lehtman & Marcus A.R. Childress
March 25, 2021 at 07:00 AM
Over the past few years, an extraordinary number of technology companies have gone public or filed paperwork to become public companies. Often times, many of these companies have experienced remarkable growth in their businesses. In the rush to “go public,” however, many of these companies pay little attention to implementing robust anti-corruption compliance programs tailored to the company’s business risks internationally. Instead, companies dedicate resources to readying the business and implementing basic corporate governance standards using “off-the-shelf” policies and procedures sufficient to satisfy requirements imposed by the securities laws and underwriters. While that approach reflects a level of pragmatism often necessary for companies still building out their legal and compliance infrastructures, technology companies that do not revisit their Foreign Corrupt Practices Act (FCPA) compliance program within a reasonable period of time following IPO run significant compliance risks.
Transforming organisations: Assess capacity for change
By R Gopalakrishnan
26th March 2021
Every organisation has a finite capacity for change. Every leader has a vision for change. There must be a match between the capacity for change and the vision for change if a transformation initiative is to be successful. In recent columns on transforming organisations, I had reviewed two transformation risks—avoiding the demyelination risk and missing the subsonic sounds. In this column, I emphasise that a leader needs both discipline and process to execute a change program. There is a delicate balance between the organisation’s capacity for change and the leader’s vision for it.
In France, bribery isn’t needed to violate the anti-bribery law

The French Anti-Corruption Agency (AFA) has just published the English version of its revised anti-corruption compliance Guidelines. Reflecting three years of experience in implementing France’s landmark Sapin II law, the Guidelines lay out the agency’s recommendations for both the public and private sectors.
The private company guide to effective internal controls
Deloitte's three-part series explores the potential benefits your company can derive from risk assessment, effective internal control design, and regular monitoring.
March 22, 2021 05:00 AM
Public and private companies are subject to different regulatory requirements relating to their financial and operational disclosures, including to whom the disclosures are provided and the level of detail they should contain. Nevertheless, any business can benefit from having transparent financial and operational information available for decision-making and reporting to stakeholders. As the owner, executives, or investor of a private company, what can you do to increase your certainty about the information coming to you from across the enterprise? Whether your company is venture-backed, funded by private-equity investors or a family business, internal controls are an important part of the answer as you grow. They can be an integral part of operations that can help mitigate risks and add business value.
FCPA Year in Review 2020
By Cuneyt A. Akay
March 15, 2021
2020 was another record-setting year in U.S. Foreign Corrupt Practices Act (FCPA) enforcement. In 2019, corporate FCPA enforcement set an all-time high with over $2.65 billion in fines and penalties. Additionally, that year, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) imposed the two largest FCPA corporate penalties, including the first billion-dollar settlement in FCPA history. In 2020, corporate FCPA enforcement eclipsed the 2019 record with $2.78 billion in total fines and penalties and set the record for the largest single FCPA penalty, which was a $1.6 billion settlement. 2020 also saw an increase in multi-jurisdictional cases, with foreign governments receiving over $5 billion in global anti-corruption settlements related to FCPA cases. In addition, the government charged 36 individuals for FCPA and FCPA-related conduct, representing one of the highest numbers of individual prosecutions ever pursued in a year.

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 or by phone at 727-538-4113 in the USA.

Below is a list of WorldWide Affiliates currently serving the profession. If your area is not represented please consider partnering with ICI
2021 Certification Training Program & Exams

ICI and affiliates around the world have a busy training programme scheduled for 2021. For more details on the CICS Training programmes on offer,visit the Events page on our website by clicking on the link below.

ICI World Wide Affiliates
Contact: Mr Aminur Rahman
Tel: +88 01749 400600
Contact: Mr Humphrey Chawafambira
Tel: +267 75618647
Contact: Mr Eduardo Person Pardini
Tel: +55 51 3533 8566
Contact: Mr Eric Kamegne
Tel: +237 658 292 978
The website of ICI Cameroon is now operational

Our first CICS session in April is online only
Contact: Mr Qiu Jianting
Tel: 400-098-1119 or 010 68004176

The next CICS on-line training course, the Hangzhou Partner has planned to start the course on March, 8, and hold the CICS exam on April 11, 2021. During this period, CCSIT will provide 4 (8-hour)live broadcast courses for on-line students.
Contact: Mr Yves Dupont
Tel: 0032 2 305 35 25

Scheduled Events
Contact: Mr Summit Goyal
Tel: +91 9810 575 613
Middle East
Contact: Mr Belal Abdul Jabbar
Tel: +962 6 5927171
Myanmar & Cambodia
Contact: Mr Sanjeev Gathani
Tel: +65 9655 4633
Contact: Mr Joel Aluko
Contact: Mr Muhammad Farooq Hammodi
Contact: Mr Cosmin Serbanescu
Tel: +40 752 525 525
Singapore, Malaysia, Indonesia & Taiwan China
Contact: Mr Bob Seetoh
South Africa
Contact: Ms Sedie Jane Masite
Email: or
Contact: Ms Nadia Yaich
Contact: Ms Ilknur Tunc
Tel: +90 312 442 50 15
Contact: Mr Nguyen Thanh Tung
Tel: 848 3803 5020
Contact: Dr Proctor Nyemba
Tel: +263 4 443124
Control Quotes:

“If you don’t have time to do it right, when will you have time to do it over?”
John Wooden
About ICI
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
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