Control Chatter
November 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.
The Impact of the Foreign Corrupt Practices Act on Corporate Boards
By Michael Marquardt
“Tone at the top” now includes ensuring business dealings are ethical and bribe-free. 
The impact of the Foreign Corrupt Practices Act (FCPA) on corporations and their boards of directors has been enormous and wide-ranging, and not just on corporations based in the United States. Companies all over the world have modified their business practices to avoid violating the FCPA and becoming ensnared in legal enforcement by the Securities and Exchange Commission (SEC) or the Department of Justice (DOJ). 
An investigation by the SEC in the early 1970s found that more than 400 U.S. corporations admitted to making questionable payments totaling more than $300 million to foreign government officials, foreign political parties or foreign politicians (often running for office). This was not illegal at the time, so the legislature set out to make it illegal. At its core, the FCPA prohibits individuals and entities from bribing foreign government officials anywhere in the world to benefit their own business interests.
McKinsey affiliate agrees to pay $18 mln to U.S. regulator over compliance failures
November 19, 2021
The U.S. Securities and Exchange Commission (SEC) on Friday said an affiliate of consulting firm McKinsey & Co has agreed to pay $18 million for compliance failures in handling nonpublic information. McKinsey's affiliate MIO Partners, which handles investments for current and former McKinsey employees, maintained inadequate policies and procedures to prevent partners from misusing material nonpublic information they obtained as consultants to public companies and other clients while they were simultaneously overseeing the MIO's investment decisions, the SEC said in a statement.
China: New challenges ahead for corporate compliance investigations under China’s new Personal Information Protection Law
NOVEMBER 19, 2021
China has strengthened its commitment to protect personal information by adopting the new Personal Information Protection Law (PIPL 《中华人民共和国个人信息保护法》) which gives data subjects the power to control and determine how, with whom and for what purposes their personal information can be shared, analyzed or handled. Our Firm has previously released a more detailed discussion on the PIPL, which took effect on 1 November 2021. In the context of compliance investigations, typical activities can include accessing and analyzing employees’ personal information. The investigation team may also want to engage external professional assistance or share such information with head offices located outside China. Under the PIPL, these activities require general or specific consent from the data subject, which may not be feasible in light of the sensitive and confidential nature of an investigation.
Diving deeper into smaller frauds due to COVID-19
By Dave Arman, CPA, CGMA, and Carl Mayes, CPA
November 19, 2021
By looking at the fraud triangle, we would expect that the possibility of fraudulent behavior would increase due to the COVID-19 pandemic. We know that management personnel, more so today than prior to the pandemic, likely have more pressure, opportunity, and ability to rationalize fraud, but nonmanagement employees are also experiencing stressors due to the pandemic that may nudge them toward fraud. The opportunities nonmanagement employees have for fraud may be different, but the impacts of any fraud they commit can be just as severe. The importance of an auditor's professional skepticism is heightened in this environment, and that includes having a questioning mind regarding the possibilities of fraud by nonmanagement personnel.
SEC Announces Enforcement Results For FY2021-Agency Brought Significant Actions In Traditional And Emerging Areas-Whistleblower Program Surpassed $1Billion In Awards
November 18, 2021

The Securities and Exchange Commission today announced that it filed 434 new enforcement actions in fiscal year 2021, representing a 7 percent increase over the prior year. Seventy percent of these new or "stand-alone" actions involved at least one individual defendant or respondent. The new actions spanned the entire securities waterfront, including against emerging threats in the crypto and SPAC spaces. For example, the SEC charged a company for operating an unregistered online digital asset exchange, charged a crypto lending platform and top executives alleging a $2 billion fraud, and brought an action against a special purpose acquisition company, its merger target, top executives, and others for alleged misconduct in a SPAC transaction. The SEC’s whistleblower program was critical to these efforts and had a record-breaking year.
4 Hard Truths About Ethics and Compliance Training
NOVEMBER 10, 2021
Most employees receive some kind of ethics and compliance training at work. Many of these training sessions are mandatory for legal reasons. Others, like those regarding workplace ethics, go beyond mere compliance to address the standards of behavior that an organization wants to uphold. The problem is that much of compliance training is uninspiring and ultimately ineffective at educating and changing employee behavior. Gallup data suggest that simply "checking the box" on compliance training for employees doesn't work. If corporate leaders want to get ethics and compliance initiatives right, they need to take a serious look at the effectiveness of their training. Here are a few hard truths Gallup has discovered about the effectiveness of compliance training.
Compliance Under Pressure
By Sepideh Rowland, CAFP
November 15, 2021
Compliance processes at financial institutions of all sizes are complex, and they consume seemingly ever-expanding amounts of time, money, and human resources. Yet compliance processes are essential to preventing financial crimes. With the pressures of managing financial crimes risk steadily increasing, institutions large and small must implement and maintain effective internal controls to remain compliant. In the past, these pressures largely stemmed from ensuring compliance with laws and regulations. Today, with financial institutions shifting to remote work, consumer expectations changing, and digital payments reducing in-person transactions, there are also new internal challenges, and stresses keep mounting. To prevent compliance failures, institutions need to understand the pressures they and their compliance teams are facing and take steps to cope with them. Not taking action to mitigate stress in a financial institution’s daily operations can have serious consequences—not just in the engagement and productivity of staff, but also in the effectiveness of the compliance program. 
The SEC Joins DOJ's War on Corporate Offenders
November 9, 2021
Last week we wrote about the three-pronged attack that the Department of Justice (DOJ) will use to get more aggressive in prosecuting cases and how they punish corporate offenders. Now, the U.S. Securities and Exchange Commission (SEC) has announced its own intention to conduct faster investigations, bring bigger cases, and to seek harsher penalties. In his first speech on enforcement, SEC Chairman Gary Gensler quoted the agency’s first Chair, Joseph Kennedy, to summarize his own agenda: “The Commission will make war without quarter on any who sell securities by fraud or misrepresentation.”
Chairman Gensler announced four principles that he’s asking that the Enforcement Division utilize to guide their investigations and recommendations to the Commission.

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:
I never blame myself when I'm not hitting. I just blame the bat and if it keeps up, I change bats. After all, if I know it isn't my fault that I'm not hitting, how can I get mad at myself?
Yogi Berra
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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