Control Chatter
September 2021
News that Control Professionals need to know
Quick Links
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.
Amazon Opens Investigation into Alleged Bribes Paid by its Legal Counsel to Indian Govt Officials
The developments come after a whistleblower complaint alleged that legal fees being paid by Amazon were being "funnelled" by its legal counsel to officials of the Indian government.
New Delhi: Online retail giant Amazon on Monday, September 20, announced that it would be conducting an internal investigation into whistleblower allegations that the company’s legal council bribed officials of the Indian government, the Indian Express reported. The whistleblower complaint alleged that an amount of the “legal fees” paid by Amazon had been funnelled into bribes paid by one or more of its legal representatives, a report by news platform the Morning Context claimed. The report also quoted Indian government officials as saying that there is “zero tolerance” towards any form of corruption as far as the government is concerned. The officials noted that the e-commerce company had spent Rs 8,500 crore in legal fees over the past two years and that “it is time to think where it is all going.”The reports also noted that the company’s senior legal counsel has been sent on leave while the internal investigation takes place.
Red flags ignored in WPP $19M FCPA settlement
Sep 24, 2021
Global advertising giant WPP on Friday reached a more than $19 million settlement with the Securities and Exchange Commission (SEC) to resolve charges of violating the Foreign Corrupt Practices Act (FCPA).
WPP must pay $10.1 million in disgorgement, an $8 million penalty, and $1.1 million in prejudgment interest as part of the agreement. The company, considered the world’s largest advertising group, also agreed to cease and desist from violating the anti-bribery, books and records, and internal accounting controls provisions of the FCPA. It neither admitted nor denied the SEC’s findings. WPP’s alleged violations relate to its “aggressive” acquisition of controlling interest of advertising agencies in high-risk markets, including India, China, and South America. “WPP failed to ensure that these subsidiaries implemented WPP’s internal accounting controls and compliance policies, instead allowing the founders and CEOs of the acquired entities to exercise wide autonomy and outsized influence,” the SEC stated.
How Assuring Tech Can Overcome Data And Process Risks
By Russ Banham
Sep 21, 2021
By now, most companies have taken long strides toward automating their business processes with the goals of making their operations more efficient, saving money and generating the analytical insights that can inform decision making. But what if the underlying data is incorrect? Or if the processes it’s being put through, the way it’s being manipulated or the attracting a lot of attention in C-suites, since so much of business today relies on the integrity of both financial and nonfinancial data. 
There are numerous ways in which inaccurate data can be produced, from sloppy data entry and inconsistencies in data formats to careless data migration or processing. More than half of the respondents (55%) to the 2021 Global data management research survey of business leaders on data quality say they lack trust in their data assets. They believe that a third of their customer and prospect data alone is inaccurate. 
Company internal control systems are intended to identify and mitigate data integrity and security risks—but what if an error slips through the cracks?
How much compliance training is enough?
We know a lot about what the feds expect from compliance training. For example, from the Evaluation of Corporate Compliance Programs and the FCPA Resource Guide, we know training is a hallmark of a well-designed compliance program. We know directors, officers, employees, and maybe even third parties should receive periodic training, with a special focus on gatekeepers. And we know training needs to be appropriately tailored to fit the company’s operations and workforce. What we don’t know, however, is how much training is enough. I’ve struggled over the years to figure this one out. Maybe you have, too. The end game of compliance training is to prevent bribery and, if bribery happens, for the company to be ready and able to demonstrate that it appropriately tailored its compliance training to prevent and detect bribery. That sounds fairly simple. But how much training is enough? Does appropriately tailored equate to five hours of training a year? Or ten hours? And who says so? On what authority can a chief compliance officer say, “Our compliance training is enough”?
World Bank Riddled with Major Flaws: Doing Business Report is Just the Tip of the Iceberg
By News Ghana
Sep 24, 2021
The World Bank has announced that it will discontinue the publication of its flagship Doing Business Reports (DBR). The decision came after a series of internal audits and the publication of a damning investigation that revealed serious ethical improprieties, conflict of interest within the Bank’s advisory services and data manipulation in the development of the Doing Business rankings. The termination of the Doing Business Report marks a major victory for over 360 civil society organisations, academics and trade unions from 80 countries who demanded the World Bank to stop publishing its Doing Business Rankings earlier this year and for all those who have advocated the same since the report’s inception.
How can enterprises support remote working without opening the door to occupational fraud?
By Simon Marchand
September 27, 2021
Economists who surveyed thousands of Americans found that, after the pandemic, the average employee would like to spend nearly half their time working from home. Employer attitudes have shifted too: most expect that employees will work from home one day a week. Indeed, PwC has found that only 19% of companies are planning to operate a completely in-person working environment in fall 2021. But this shift creates new security threats. As organizations move to formalize “work from home” and “work from anywhere” policies, they need to understand — and mitigate — the increased risk of fraud that comes with allowing remote access to their systems.
“Internal control must also ensure that management adheres to laid down rules, regulations and policies.”
September 27, 2021
The guest speaker and Managing Director of Neimeth International Pharmaceuticals Plc, Mr. Matthew Azoji, called on Nigerians to firmly resolve to not be a giver nor a receiver of bribe and corruption will die.
He said that internal auditors should report to the board committees of companies to fight against administrative corruption from management.
Quoting from the World Bank definition of corruption, Azoji said corruption is the wrong use of public office for personal gain. The Neimeth boss stressed that corruption had devastating impact on the society by hampering human, infrastructural and economic development and called on the National Assembly to enact internal auditing law to check and prevent occurrence of fraud. “As Nigeria continues to fight corruption in both private and public sectors, it is imperative that stakeholders would continue to support efforts like SWAIAP to ensure that corruption is exterminated in the country.
New COSO guide aims to help organizations align risk management with AI initiatives
September 17, 2021
Recognizing the accelerating need to identify and manage the risks of artificial intelligence effectively, the Committee of Sponsoring Organizations of the Treadway Commission (COSO), in collaboration with Deloitte, has issued guidance to help organizations align risk management with AI initiatives. Realize the Full Potential of Artificial Intelligence’ leverages the principles from COSO’s 'Enterprise Risk Management (ERM) – Integrating with Strategy and Performance Framework' and focuses on the need for organizations to design and implement governance, risk management, and oversight strategies and structures to realize the potential of humans collaborating with AI.
“AI-related risks need to be top of mind and a key priority for organizations to adopt and scale AI applications and to fully realize the potential of AI,” said Paul Sobel, COSO Chairman. “Applying ERM principles to AI initiatives can help organizations improve governance of AI, manage risks, and drive performance to maximize achievement of strategic goals.”

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:
People who think they know everything are a great annoyance to those of us who do.
Isaac Asimov
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
Facebook Join My List Logo