Control Chatter
July 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.
Compliance Checklist: What a Company Needs to Do to Be AML Compliant
July 21 2021 
Global penalties for AML regulation non-compliance are increasing year after year. Overall, the number of fines in 2020 was $10.4 billion. Major banks like Deutsche Bank (USA) and Commerzbank (UK) were fined millions of dollars for non-compliance. In this article, I will try to review what is necessary for any company to stay compliant.
The Rise Of Risk Silos: How To Unify Risk And Compliance Management
Jul 21, 2021
As enterprises work to break down silos to integrate data for better decision-making, another set of silos is being overlooked: risk silos. These silos exist across the typical enterprise, with various departments (legal, sales, finance, compliance) handling risks differently and often in isolation. 
Normal business activities— such as from an aggressive new sales campaign — may create major risks, but would your compliance team know? The disconnect creates massive compliance blind spots. 
Slammed for bribery, Siemens continued to ignore red flags
July 20, 2021
German engineering giant Siemens ignored some of its own red flags for foreign bribery in the aftermath of a major corruption scandal in 2008, according to newly released reports by an independent monitor and other confidential documents. The warnings involved the company’s use of third-party resellers, who have often served as conduits for bribing foreign officials, according to former company insiders and company internal assessments. Evidence from public records in China suggests that problems with resellers have continued during the pandemic, and resulted in the sale of medical equipment to Chinese state-owned hospitals at vastly inflated prices. The monitoring reports, which Siemens was obliged to commission from 2009 to 2012, stem from a $1.6 billion landmark settlement of bribery charges by the US Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) in 2008. During their investigation, US and German authorities found over $1 billion of bribes paid to foreign government officials in return for business, in what the SEC called a “systematic practice” spanning decades and virtually every region in which Siemens operated, violating the Foreign Corrupt Practices Act (FCPA). Siemens admitted to failures of internal controls and record-keeping.
Benchmarking Alert: Here’s Coca-Cola’s full anti-bribery policy
The Coca-Cola Company, incorporated in 1892, is one of the world’s oldest, most well-known, and widely consumed brands. How does it’s anti-bribery policy compare?
1. It takes daily effort.
It is therefore vital that you not only understand and appreciate the importance of this Policy, but also comply with it in your daily work.
2. Don’t pay bribes, or you might end up in jail.
Company employees that violate these laws can also face severe civil and criminal penalties, including jail time.
3. No facilitating payments (except sometimes).
DOJ Orders $230 Million Fine for FirstEnergy
Deferred Prosecution Agreement Implicates Former PUCO Chair in Alleged Bribery Scheme
Jul 22, 2021
FirstEnergy (NYSE:FE) has agreed to pay a $230 million fine for its role in the Ohio House Bill 6 scandal, in what federal officials described as the largest bribery scandal in state history.
Federal attorneys on Thursday filed a 49-page deferred prosecution agreement against the company in U.S. District Court in Cincinnati. FirstEnergy is charged with conspiracy to commit honest services fraud but could eventually have the charge expunged from its record with continued cooperation in the case.
FirstEnergy allegedly spent $61 million in bribes and “dark money” campaign contributions and advertising to elect the speaker of the Ohio House of Representatives and allies, who won $1.5 billion in subsidies for the company’s struggling nuclear plants under H.B. 6, passed in 2019.
We are moving to the place where every Board of Directors will have a Compliance Committee, separate and apart from its Audit Committee. With the speed of change we witnessed in the pandemic, compliance and greater risk management has become even more important. The Delaware decision in Blue Bell also mandated more and greater Board involvement in compliance and risk management.
In an area of inquiry entitled Oversight, the 2020 Update to the Evaluation of Corporate Compliance Programs asks three basic questions:
  1. What compliance expertise has been available on the Board of Directors?
  2. Have the Board of Directors held executive or private sessions with the compliance function?
  3. What types of information has the Board of Directors examined in their exercise of oversight in the area in which the misconduct occurred?
To facilitate the answers to these questions, consider this list of 20 questions to reflect the oversight role of directors. These are questions the Board should ask of both senior management and the Board should ask itself in the form of its Compliance Committee.
UK SOX: much is unknown – but the time to prepare is now
by Marc Jackson
July 13, 2021
Following the recent completion of the consultation period for the Sarbanes-Oxley Act (SOX) in the UK, Marc Jackson, practice director – integrated risk management at Turnkey Consulting, discusses how UK companies can prepare There is much to be considered about this aspect of audit reforms.
It is almost 20 years since the Sarbanes-Oxley Act (SOX) was passed in the US. Following a slew of corporate scandals – with Enron and WorldCom arguably the most high-profile – its purpose is to protect all stakeholders from the effects of publicly traded (US) companies failing as a result of financial mis-reporting, whether intentional or not. At the time, SOX was not introduced in the UK, although through the need for compliance by any US-listed foreign private issuers, its reach spread out to some UK companies. But that all looks set to change.
Fighting workplace fraud
By Jennifer Lynch and Margot Mary Davis
July 07, 2021
It is every business’ worst nightmare, being a victim of occupational fraud. Unfortunately, it is a common reality. Each year, organizations, on average, lose five per cent of their revenue to occupational (employee) fraud. Generally, employee fraud continues for 14 months until being detected and results in median losses of $125,000. For business of less than 100 employees, occupational fraud’s impact is especially severe. Small businesses generally report median losses of $200 000. The three major types of occupational fraud are asset misappropriation, financial statement fraud and corruption, with asset misappropriation accounting for an overwhelming 86 per cent of occupational fraud. Business owners want to know how to combat employee fraud. While occupational fraud can never be eliminated, businesses can take proactive steps to reduce their chances of being a fraud victim.

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

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 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:

I don't get upset over things I can control, because if I can control them there's no sense in getting upset. And I don't get upset over things I can't control, because if I can't control them there's no sense in getting upset.
Mickey Rivers
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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