Control Chatter
December 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.
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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.
Time to Fall on Your Sword: Will DOJ’s Focus on Individuals Stem the Flow of Misconduct?
DOJ Words and Actions Signal a Shift to Individual Accountability
DOJ says it plans to target more individuals in cases of wrongdoing. With a flurry of recent indictments, that promise appears to have already materialized. The more the enforcement stings, the more it will discourage businesses from repeat wrongdoing.
One of the most frustrating things about working in compliance is when you see people get away with illegitimate actions.
The U.S. Department of Justice, Deputy Attorney General (Lisa Monaco), delivered remarks earlier this year, indicating that DOJ was going to pursue more individuals. During the announcement of an indictment against nine individuals for various offenses related to firearms trafficking, she indicated that the department’s top priority regarding corporate crime is to prosecute the people who commit and benefit from misconduct. It’s about time!
There were a few key messages in what she had to say.
2021 FCPA Enforcement Actions And Highlights
16 December 2021
So far, 2021 has seen less activity in terms of enforcement actions under the Foreign Corrupt Practices Act ("FCPA"), compared to 2020. In 2021, the United States Department of Justice ("DOJ") took a total of 19 enforcement actions,1 and the Securities and Exchange Commission2 ("SEC") took a total of 4 enforcement actions. Therefore we observe that the DOJ has been a lot more active than the SEC in terms of the number of enforcement actions this year. Of the 19 enforcement actions taken by the DOJ, 16 of them were related to real persons, which appear to be related to bribery schemes involving state owned energy or petro-chemical companies in Brazil and Venezuela. In terms of sectoral concentration of FCPA enforcement actions of 2021 concerning corporations, we observe a wide array of sectors including energy, advertising, consultancy and engineering services, with a condensation in banking and financial services sector.
U.S. Strategy on Countering Corruption Signals Focus on Enforcement
December 13, 2021
On Monday, December 6, 2021, the Biden-Harris Administration released the United States Strategy on Countering Corruption (the “Strategy”),[1] the first of its kind. The Strategy culminates a months-long process set in motion when President Biden declared that the U.S. Government’s efforts against corruption represent a “core United States national security interest.” As the Administration explained in a June 3, 2021 National Security Study Memorandum, “corruption threatens United States national security, economic equity, global anti-poverty and development efforts, and democracy itself.”
The Strategy seeks to broaden and energize the Government’s anti-corruption efforts by focusing on a range of policy and enforcement strategies coordinated across executive branch agencies.
13 Cybersecurity Predictions for 2022
Dec 3, 2021
Cybersecurity will continue to be a grave concern in 2022. Malicious and accidental threats from outside and within organizations, coupled with increasingly stringent data regulations, are putting the onus on companies to step up their security and data use precautions. Here, data security leaders share their thoughts on what's ahead in terms of new dangers to data and the ways to thwart them.
  1. Record-level security will become a C-suite issue: Record-level data security will become a hot topic and key priority in 2022 after a wave of high-profile data breaches that makes it impossible to ignore. We may even see an entirely new open-standard file format emerge with record-level data security already baked into it. ?
SEC Commissioner Crenshaw Focuses on Internal Controls Concerning ESG Risks
December 3, 2021
In a recent speech, SEC Commissioner Crenshaw, one of the Democratic appointees to the Commission, focused on the role internal controls play in assessing and monitoring ESG risks. Specifically, after noting that the SEC received "[a]n overwhelming number of comment letters stat[ing] that investors view ESG information as material to financial performance and that investors need consistent and reliable disclosures of ESG information to inform their investment decisions," Commissioner Crenshaw noted that she "encourage[d]" her audience to "think about" "ESG risks" "in the context of your internal accounting controls and audit functions." In other words, Commissioner Crenshaw emphasized that companies should begin developing internal procedures to generate the information necessary to properly respond to the regulatory disclosures the SEC will promulgate concerning ESG risks, and to implement policy changes to adapt to such risks. 
The winds of change in board governance
DEC 10, 2021
Corporate governance is about the set of systems, rules and processes that ensure the interests of stakeholders are aligned in a transparent way. Within the corporate ecosystem, the board of directors is primarily responsible for the governance of the company. Board governance can, however, change under three potential circumstances.
Responses to scandals First, external events, such as major corporate scandals or market upheavals, can lead to strengthening of governance rules to avert future occurrences. For example, the collapse of oil giant Enron prompted the Sarbanes-Oxley Act of 2002, leading US regulators to mandate strict reforms to existing securities regulations. Likewise, tougher penalties were imposed by regulators across the region, in the aftermath of the Asian Financial Crisis in 1997.
Why Voluntary Approaches To Federal Cybersecurity Mandates Threaten Compliance
Dec 7, 2021

On May 12, in the immediate aftermath of the Colonial Pipeline hack, President Biden issued an Executive Order addressing the U.S.'s cybersecurity posture, with one section requiring federal agencies adopt multi-factor authentication (MFA) and encryption.
The order set a deadline of 180 days for federal agencies to comply, and this deadline recently passed. While we've seen noteworthy progress in the transition to MFA, encryption and other operational technology (OT) security measures, it remains to be seen whether the president's executive order will lead to lasting change for the federal government and American businesses. Since the May announcement of the executive order, our division at Thales has seen a massive increase in the number of queries regarding the discovery and protection of data at rest, data in motion and MFA. We're also seeing a ripple effect, as related entities — educational institutions, commercial businesses and state and local governments — are also reevaluating their cybersecurity measures. 
How auditor-general exposed multi-billion naira fraud in national assembly – Report
December 18, 2021
The office of the Auditor-General for the Federation (AuGF) in its 2019 Annual Audit Report has indicted the management of the National Assembly over how the spending of funds runs into billions of naira.
The AuGF, Aghughu Adolphus, in the audit noted that over N8.5 billion from the funds released to the National Assembly were expended within the period under review without evidence, Daily Trust reports.
The report said the monies under scrutiny were not backed by vouchers and retirement documents. The report, submitted to the Clerk of the National Assembly in August this year, uncovered various infractions by the Senate, House of Representatives, and the National Assembly Service Commission. The audit report is usually submitted to the National Assembly Public Accounts committees for investigation.

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 program scheduled for 2021. For more details on the CICS Training programs 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: Soulémane BABA DAMAGUI
Tel: +0022997492600
Contact: Mr Humphrey Chawafambira
Tel: +267 75618647
Contact: Mr Eduardo Person Pardini
Tel: +55 11 2599 8360
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
Contact: Mr. Yves Dupont
Tel: 0032 2 305 35 25
Contact: Mr Summit Goyal
Tel: +91 9810 575 613
Contact: Mr Nereo Guzman Mendoza
Tel: +52 811 181 3514
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 Jesus Salazar Ras
Tel: +58 426 737 8096 or + 58 416 291 3788
Contact: Mr Nguyen Thanh Tung
Tel: 848 3803 5020
Contact: Dr Proctor Nyemba
Tel: +263 4 443124
Control Quotes:
Halloween is the beginning of the holiday shopping season. That’s for women. The beginning of the holiday shopping season for men is Christmas Eve.”
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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