Control Chatter
Febuary 2022
News that Control Professionals need to know
Quick Links
ICI digital credentials and badges
We are committed to providing you with the tools necessary to achieve your professional goals and we understand that communicating your credentials in an ever-expanding online marketplace can be challenging. That is why we will be partnering with Credly to provide you with a digital version of your credentials. Digital badges can be used in email signatures or digital resumes, and on social media sites such as LinkedIn, Facebook, and Twitter. This digital image contains verified metadata that describes your qualifications and the process required to earn them. Credentials you can earn will include our certifications, training courses and ICI membership. Watch for upcoming announcements as we get closer to implementing our credentials and badges program.
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.
ICC Whistleblowing Guidelines to scale up business integrity
ICC has unveiled the newest contribution to its tools to help business stamp out corruption: the 2022 edition of the ICC Whistleblowing Guidelines. Providing practical guidance to help enterprises establish and implement a Whistleblowing Management System, the guidelines are an update of the ICC Guidelines on Whistleblowing published in 2008, incorporating current experience and practice of ICC member enterprises across a wide range of sectors and jurisdictions worldwide. The 2022 edition also aligns with key international legal instruments as well as global standards and best practice such as the 2021 ISO 37002 Guidelines on Whistleblowing Management Systems and the 2019 European Directive on Whistleblower Protection, which is now being implemented by governments across Europe.
7 Trends to Help You Create an Effective Compliance Program in 2022
Wednesday, February 23, 2022
It’s a lesson that bears repeating – you can’t find what you don’t look for. To know what to look for and thereby achieve peak performance and tackle key risks, compliance programs must identify and incorporate the trends in government enforcement. To help identify those trends, we recommend reviewing the enforcement priorities announced by the government in 2021, recently announced resolutions, and significant advisory opinions from the Office of the Inspector General. The change in the presidential administration brought renewed energy to the Department of Justice’s (“DOJ”) health care fraud enforcement programs and will likely bring additional and more sophisticated resources to the government’s enforcement activities. While fraud and abuse cases can be in the investigative pipeline for years before coming into the public eye, certain trends can be detected from public and other pronouncements from the DOJ over the past year. We highlight those notable trends so that they can inform your compliance program.
DOJ Issues Expedited FCPA Opinion, Shows Willingness to Communicate With Requestors
by George E. Horn, Jr.and Eric H. Sussman
February 7, 2022
The U.S. Department of Justice (DOJ) recently released an opinion relating to extortion and duress under Foreign Corrupt Practices Act (FCPA) that offers a unique perspective into the DOJ's FCPA opinion procedure. While the opinion does not break any new substantive legal ground, it does demonstrate that in certain exigent circumstances (including where there is a risk to individuals), the DOJ may expedite its commonly lengthy opinion procedure. The opinion was delivered in response to a request from a U.S.-based company after it received an extortion demand. This is the first FCPA opinion from DOJ in almost two years. The opinion reaffirmed the DOJ’s long-standing policy that it will not bring FCPA enforcement actions against companies for illicit payments made in response to extortion demands by government officials when there is an imminent threat of physical harm made against the company’s employees.
SPACs and IPOs pose challenges for SOX compliance
By  Michael Cohn
February 22, 2022
The record number of companies going public through special purpose acquisition companies and initial public offerings last year could be facing some extra hurdles when it comes to Sarbanes-Oxley rules. A recent POV report from Deloitte aims to help public company CFOs and management teams become SOX ready. Section 404 of the Sarbanes-Oxley Act of 2002 requires public companies to set up an internal control structure and evaluate it. Their annual reports need to include the company’s own assessment of internal control over financial reporting, along with an auditor’s attestation. However, the SPAC process has allowed many companies to fast-track the process of going public by setting up shell companies, and the Securities and Exchange Commission is starting to call them out for neglecting some of the accounting requirements. Section 302 of SOX covers the disclosure controls and procedures, while Section 906 requires certification by the CEO and CFO of periodic reports containing financial statements.
World Bank debars consultant and managing director for bribery, mandates compliance training
The World Bank debarred a Nigerian consulting company and its managing director Wednesday for two years and ten months for improper payments connected to a project in Nigeria. AIM Consultants Limited and its managing director, Amin Moussalli, are ineligible to participate in projects and operations financed by the World Bank Group during the 34-month debarment. According to the World Bank, AIM Consultants made improper payments totaling around $45,500 (Nigerian naira 12,954,400) to project officials during the implementation of two World Bank-financed consultancy services contracts. After receiving payments from the project, AIM Consultants transferred money to the personal accounts of the two “resident engineers.” The money was then transmitted to various project officials. Amin Moussalli authorized all the payments. This constitutes a corrupt practice under the World Bank’s Consultant Guidelines. 
Accounting and Auditing Enforcement Activity—2021 Review and Analysis
Wednesday, February 16, 2022
In 2021, a year characterized by the continued challenges of the COVID-19 pandemic and changes in leadership at both the SEC and the PCAOB, accounting and auditing enforcement activity decreased and monetary settlements fell sharply. Together, the SEC and PCAOB publicly disclosed 52 accounting and auditing enforcement actions in 2021, nearly two-thirds of which were SEC actions. Monetary settlements totaled approximately $159 million, almost all of which were imposed by the SEC, a decline of nearly 90% from $1.4 billion in 2020.
Separation of Chairman and CEO decree: SEBI buckles under heavy corporate firepower
In opposition, some of the big companies see this provision as undue interference in a company’s internal affairs.
February 20, 2022
SEBI has blinked once again. In the face of a sustained campaign by family-run corporates, it has thrown in the towel and decreed the separation of the posts of chairman and CEO/MD — due to kick in from 1st April, this year — will now be ‘voluntary’. Market regulator Securities & Exchange Board of India (SEBI), in a rather unabashed ‘reasoning’ for its pull-back, cites “unsatisfactory levels of compliance achieved so far with respect to this governance reform” and “constraints posed by the prevailing pandemic”. There couldn’t be a more specious argument. To justify bad compliance as a reason for the withdrawal of the provision, SEBI says just 54% of the 500 top companies have complied so far. If laws and rules are made based on who is willing to comply with them ‘voluntarily’, then we are signalling the law of the jungle is near. 
KT Corporation Agrees to Pay $6.3M Fine to SEC Over FCPA Charges
The Securities and Exchange Commission (SEC) announced that KT Corporation agreed to resolve allegations that it violated the Foreign Corrupt Practices Act (FCPA) in a cease and desist order. The order says that KT paid nearly $400,000 to almost 100 lawmakers and candidates and created a “slush fund” of about $900,000 from which it paid improper bonuses in violation of the FCPA.
The law bars companies that issue stock in the U.S. from bribing foreign officials for government contracts and other business and also imposes accounting and internal oversight mandates. Seoul-based KT, South Korea’s largest telecommunications provider, engaged in multiple schemes over the last nine years to make improper payments in Korea and Vietnam, the SEC’s order explains.

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:
"The pessimist complains about the wind; the optimist expects it to change; the realist adjusts the sails."
William Arthur Ward
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