Control Chatter
June 2022
News that Control Professionals need to know
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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" 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
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CICS preparation program held during the month of June, 2022
Digital Transformation in Internal Audit
Workshop held in cooperation with ICI June, 2022.
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.
Why internal controls are so critical for organisations
JUNE 19, 2022
Robust internal controls form the foundation of good governance in an organisation. Within environmental, social and governance (ESG) frameworks, the governance pillar relates to how businesses are administered, including risk, oversight and ethics. Unfortunately, this is overlooked by many organisations. The systems and processes designed to support effective business outcomes and ensure operational efficiency and compliance are either ineffective, overlooked or simply not up-to-date. This could negatively impact business processes in an organisation. As the 14th century nursery rhyme and proverb ‘For want of a nail’ illustrates, you are only as strong as your weakest link. The failure to correct a minor issue can snowball into an issue of great magnitude. Therefore, organisations must evaluate internal controls as fundamental to enhance trust in business and improve reporting quality.
Redefining The Three Lines Of Defence (3LoD) Model During A Time Of Prolonged Pandemic Preparedness And Location-independent Working
17 June 2022
Traditionally financial services firms designed their 3LoD models including how and where their control functions carry out their duties when interacting with business and operational units very much on the basis of an office-centric working environment. COVID-19 has changed all of this. Financial services firms generally and their risk models specifically have had to evolve out of necessity and also respond to new operating models, new ways of working (remotely/hybrid) and ultimately the role of technology. As various (often rolling) lockdowns took hold, financial services firms and their staff (but equally supervisors) swapped office space for an assortment of living or spare rooms and remote working spaces. Financial services firms have had to extend their 3LoD models into those private spaces. Both remote working and location-independent working arrangements have taken hold across various types of financial services firms.
Restoring trust in audit and corporate governance: the UK roadmap for reform
June 22, 2022
The government has published its roadmap for an extensive package of reforms to improve the UK’s audit, corporate reporting and corporate governance systems. The planned reforms are outlined in the government's recently published response paper (the Response Paper) which sets out how the government will take forward the proposals in its 2021 consultation White Paper, Restoring Trust in Audit and Corporate Governance (the White Paper). That in turn built on three government-commissioned reviews: Sir John Kingman's Independent Review of the Financial Reporting Council (the FRC Review), the Competition and Market Authority’s Statutory Audit Services Market Study and Sir Donald Brydon’s Independent Review of the Quality and Effectiveness of Audit (the Brydon Review). The focus of the reforms will be oversight and scrutiny of the UK's largest companies, public and private.
All-time FCPA settlements top $24 billion
So far in 2022, there have been four FCPA enforcement actions totaling $865 million in penalties and disgorgement. That pushes all-time FCPA resolutions over $24 billion. Since the FCPA was enacted in 1977, there have been 259 FCPA corporate enforcement actions with an average value of $95.4 million. From 1977 to 2010, total FCPA settlements amounted to $3.6 billion. From 2011 to 2022 (June), total FCPA settlements climbed to $21.2 billion. In the past eleven years, the monetary value of settlements was six times more than in the first 33 years of the FCPA.
A New Policy Is Making Corporate Compliance Chiefs Uneasy
June 16, 2022
Compliance officers are worried that a new Justice Department policy, aimed at raising their stature within companies, will actually make their jobs harder—and even leave them open to criminal prosecution. The policy, previewed by a senior Justice Department official in March, is meant to give compliance officers a voice and provide them with access to information and resources needed to guarantee that their company’s compliance program is effective. It was applied for the first time last month in a settlement agreement with commodities giant Glencore PLC. But lawyers say the policy could have unintended consequences, and that it gives compliance officers leverage only by handing them the equivalent of a nuclear option.
Sorry, CCO certifications are a rotten idea
Glencore’s FCPA resolution last month included a plea agreement requiring the parent company’s Chief Compliance Officer to certify its compliance program and reports to the DOJ. The CCO’s certification is subject to the false statements statute, punishable by up to five years in prison, and the federal obstruction law, which carries a potential prison sentence of up to 20 years. Assistant Attorney General Kenneth Polite, head of the DOJ’s criminal division, announced the requirement for CCO certifications in March. He said the new policy is “not punitive in nature” but intended to ensure “Chief Compliance Officers receive all relevant compliance-related information and can voice any concerns they may have prior to certification.” Maybe the DOJ doesn’t intend the new CCO certification requirement to be “punitive in nature,” but that doesn’t mean it’s a good idea.
As Details of $1B Glencore FCPA Settlement Show, Cooperation Pays
Swiss mining company promises to clean up its act after decade-long bribery scheme, but only time will tell
by Thomas Fox
As detailed in a DOJ news release, “Glencore, acting through its employees and agents, engaged in a conspiracy for over a decade to pay more than $100 million to third-party intermediaries, while intending that a significant portion of these payments would be used to pay bribes to officials in several countries, including Nigeria, Cameroon, Ivory Coast, Equatorial Guinea, Brazil, Venezuela and the Democratic Republic of the Congo.” The resolution with the DOJ imposed $429 million in criminal penalties and forfeiture of $272 million. According to the FCPA Blog, which broke the story for the compliance community, “as part of the U.S. resolution, a subsidiary of Glencore also agreed to plead guilty and pay $485.6 million to resolve market manipulation investigations by the DOJ and the Commodity Futures Trading Commission. After crediting about $166 million of that payment to amounts to be paid in the UK and possibly other countries, penalties assessed in the United States will be just over $1 billion.”
USAA whistleblowers want to be heard—and now
Jun 16, 2022
Since Compliance Week published its three-part series on USAA’s “catastrophically mismanaged” compliance culture, more current and former USAA employees (nearly two dozen, to date) have shared with me their own experiences about reporting alleged violations of law internally to USAA’s management—some on numerous occasions and in documented emails—only to be retaliated against or let go in response. For the sake of this specific column, Compliance Week has chosen to leave all names anonymous, including the allegedly culpable management. But what I will share is all the employees who came forward to me either worked or currently work in various departments at various levels of the organization—from the lower ranks to upper management. In any organization, that’s typically a sign of a systemically unhealthy culture.

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
2022 Certification Training Program & Exams

ICI and affiliates around the world have a busy training program scheduled for 2022. 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:
You just can't beat the person who never gives up.
Babe Ruth
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