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Control Chatter                                                   April 2020
News that Control Professionals Need to Know

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In This Issue
The Cost of a Business Plan
The Road Back To Business As Usual: 12 Steps For Cos
Oversight Is More Important Than Ever During Covid-19
Organizations lose 5 percent of revenue to fraud every year.
$19.6m fine on BOCOM International Securities for internal control
Uncovering the Indicia of Fraud in Complex Cases with Incomplete Forensic Data
COVID-19: Considerations for Internal Controls Over Financial Reporting
Keeping SOX on track when pandemic strikes
JP Morgan Seoul office punished for poor internal control system

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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. 
Test your Knowledge of Internal Control
The Internal Control Institute has developed a CICS Common Body of Knowledge Mini-Assessment that helps an individual determine their knowledge as it relates to governance and control practices. Results point out areas of knowledge that may require additional training and experience. The assessment also provides a measurement to the individual's readiness for CICS certification. The assessment measures core knowledge in eight critical areas including: Internal Control - Principles, Terms and Concepts, Internal Control Environment, Risk Management, Assessing Application Controls, Business System Control Assessment, Risk Assessment, Internal Control Measurement and Reporting, and Governance Practices
 Internal Control online courses
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Start becoming an Internal Control professional today!
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 here: ICI Course Catalog
To register for one or all of the online training programs click here:  
Online course pricing has been reduced by over 70% 
The Cost of a Business Plan
By Michael Pregmon, Jr., Ph.D., CICP
COO and Managing Director
Dr. Michael Pregmon, Jr.
COO and Managing Director 
To continue on the business planning program we started a few issues ago, we will briefly cover the cost issue of a business plan that must be addressed. But, let's recap the seven sections of a plan that involve thoroughly answering the questions:
            1. Where are we?
            2. Where do we want to go?
            3. How are we going to get there?
            4. Who is responsible?
            5. How much will it cost?
            6. When will it be done?
            7. Completing the feedback loop
In this edition we will address the fifth section of a business plan.
How Much Will It Cost?
This is the section of the plan where a financial determination must be made whether we can afford the goals we would like to accomplish. In this part of the plan, we refer back to sections #2 and #3.
Typically, we must determine the cost for each goal and the related strategy required to accomplish that goal. Once each goal is "costed out," a decision must be made. Is the goal financially realistic? Is it something that must be accomplished now or just "nice" to have completed? Can it be reasonably deferred to a future planning period? Remember if it is deferred, it likely will be more costly to implement or it may possibly impact the company's overall market strategy. The latter occurs usually and only if the plan is an overall business plan.    
It is important to note that with each plan, we are concentrating on specifically completing the goal during the next fiscal period. For most companies, this involves a period of 12 months. However, a total planning horizon may extend beyond that time-frame . That is, we may want to identify additional goals that are identified for completion in subsequent years. In this respect, it is not unusual to identify goals that are planned for completion two, three, or even four years out. Nevertheless, the farther we go out, the less certainty we can expect.
But remember: if we can't afford it, it "won't" happen!

And, Stay Safe!
ICI Affiliate News :

The Internal Control Institute is conducting certification training in a classroom format for the internationally recognized CICS (Certified Internal Control Specialist) certification in internal control. Information on these programs regarding dates and schedules can be found on the Events tab on our Website or directed to the affiliate named below:

ICI has entered into an agreement with Internal Control Institute of Botswana (ICI Botswana":) as its representative for Products, Services and Internal Control Certifications (CICS/CICP) in this territory. ICI Botswana will be responsible for all development activities in this area, including professional training and Certification.  Individuals or companies interested in internal control training or Certification should contact:
Contact: Humphrey Chawafambira

Training Plans :
Rio de Janeiro - 4 to 8 of May
Brasília - 25 to 29 of May
Porto Alegre - 15 to 19 of June
Curitiba - 29 of June to 03 of July

For more details on planned training please on the website below, or send a message to Mr. Eduardo Person Pardini. Email:

The CICS training courses originally scheduled to be held in Hangzhou and Beijing in March this year a re postponed to 18-21 June, 2020.   Online CICS training and exams will still be conducted.

Individuals or companies interested in inter nal control training and Certification should contact:  
Mr. Qiu Jianting
Room 1039, Block A, Jinmao Building, No. 18, 
Xizhimenwai Street,
Xicheng District, Beijing, China
Zip Code: 100044
Mobile phone: 13810588109


Training Plans :

ICI Belgium has  started the CICS session in French with 22 participants.
Next sessions are planned in Brussels:
  • Dutch: October 2nd 2020
  • French : January 2021
For more information on scheduled training and exams please contact Mr.Yves Dupont of ICI Belgium at: 
For more information on upcoming activities in this area please contact Mr. Summit Goyal of  ICI India at :
Phone: +91 9810575613

Myanmar and Cambodia:
Better Business Governance - APAC PTE LTD (BBG) has become a representative for Products, Services and Internal Control Certifications (CICS/CICP) in Myanmar and Cambodia.  Better Business Governance will be responsible for all development activities, including professional training and Certification.  For more information on upcoming activities in this area please contact:
Better Business Governance
Mr. Sanjeev Gathani
1 Claymore Drive
#08-14, Orchard Towers (Rear Block)
Singapore 229594
For more information on upcoming activities in this area please contact the following:
Antonio Salas Hernandez CICP,  Email: 
Joaquin Prendes Herrera, Email: 

Middle East:
The CICS exam is now being  provided in Arabic.  Osool Training and Consulting has courses and testing available in Egypt, Jordan, Libya, Muscat, Sudan, Qatar, the United Arab Emirates, Kuwait and Palestine. 

Training Plans: 
7 - 10 June 2020 - Ramallah, Palestine
21 - 24 June 2020 - Cairo, Egypt

Interested applicants in the region should contact Osool for scheduling for future programs.  For additional information on scheduled ICI Certification and program sessions, please contact:
Lina Salameh
Assistant General Manager
O SOOL for Training & Consulting
Mob Oman:  +968 95 98 98 20
Mob Jordan: +962 7 99589666
Tel:   +962 6 5927171 Ext. 107
Fax:  +962 6 5927172

Leadway Consulting conducts CICS training sessions and examinations in Nigeria. For more information on upcoming activities in Nigeria  please contact:
Mr.  Joel Aluko


For more information on activities in Pakistan individuals or companies should contact : Muhammad Farooq Hammodi


ICI Romania is planning a CICS course session on October 5 - 7, 2020 and an examination on November 9, 2020.

For more information on activities in Romania contact : 
Cosmin Serbanescu at the National Institute for Internal Control in Romania.
Tel:  + 40 752 525 525


Singapore, Malaysia, Indonesia and Taiwan China:
ICI has entered into an agreement with GRC Consultancy Pte Ltd. (ICI Singapore, Malaysia, Indonesia and Taiwan) as its representative for Products, Services and Internal Control Certifications (CICS/CICP) in those territories.  

Individuals or companies interested in internal control training or Certification should contact:
General enquiries for all 4 markets -
Singapore - Mr. Bob Seetoh -
MalaysiaMr. Melvin
IndonesiaMr. Melvin Beh -
Taiwan China - Mr. Bob Seetoh -


ICI has entered into an agreement with  Business and Financial Consulting  company in  the Republic of Tunisia  (hereinafter referred to as "ICI BFC"  as its representative for Products, Services and Internal Control Certifications (CICS/CICP) in the Republic of Tunisia ICI BFC will be responsible for all development activities in this area, including professional training and Certification.  Individuals or companies interested in internal control training or Certification should contact:
Contact: Nadia Yaich


For more information on activities being planned please contact:

Ms. Ilknur Tunc,  VP -
Dr. Bertan Kaya -
GOP Mahallesi, İran Caddesi, Karum İs Merkezi
No:21, D Blok, 4. Kat, D:398-399
+90 (312) 4425015 T
+90 (533) 4474444 D
Training Plan:
Course name
start day

4 days
On Saturday and Sunday
am - 12:00 am
pm - 17:00 pm
For more information on upcoming activities in Vietnam please contact: NGUYEN THANH TUNG (MBA. M.Eng, PhD.) Director, FMIT Institute of Financial Management & Information Technology,  Level 5 , 126 Nguyen Thi Minh Khai Street, Ward 6, District 3, HCMC, Viet Nam
Office: 848 3803 5020 - 848 3512 9371 - 848 3512 7652

The Internal Control Institute Of Zimbabwe will be running CICS Classes on the following dates:    
         23-26 June     2020
         27-30 October 2020
                                  8-11   December 2020

For more information on activities being planned please contact:
Dr. Proctor Nyemba at:
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 Road Back To Business As Usual: 12 Steps For Cos.
The impact and duration of the COVID-19 pandemic - and government responses to it - might be impossible to fully assess now. But an easy prediction is that the return to business as usual or even a new normal will occur more quickly for some sectors and may not occur at all for others. The new normal also might permanently alter some business and educational processes (e.g., higher remote internet usage) and health practices (e.g., distancing and stricter stay-at-home policies for the sick).  But it is not too early for boards of directors, senior management, and in-house counsel and compliance personnel who advise them to start planning how best to return to as much business as usual as possible or even better business as usual in the future. For quick, initial guidance, we turn to the lessons learned from other commercial crises.
INSIGHT: E-Oversight Is More Important Than Ever During Covid-19
By Thomas A. Sporkin and Meredith Leeson
April 22, 2020
Organizations lose 5 percent of revenue to fraud every year
Organizations lose 5 percent of their revenue to fraud each year, according to a new report from the Association of Certified Fraud Examiners.  The percentage has remained relatively constant over the years, according to the  ACFE's 2020 Report to the Nations . The biannual report analyzes 2,504 cases of real fraud from 125 countries that totaled over $3.6 billion in losses. The typical case of fraud costs $8,300 per month, and the median duration of each fraud case was 14 months. The median loss per case was $125,000 total, but the overall average loss per case was $1.509 million. The use of anti-fraud controls - including hotlines, anti-fraud policies and training - have increased significantly over the past decade (up to a 13 percent increase for each control). Forty-three percent of the schemes have been detected by tips, and half of those tips came from employees. 
HK regulator imposes$19.6m fine on BOCOM International Securities for internal control
April 20, 2020
Hong Kong's Securities and Futures Commission (SFC) today announces that it has reprimanded and  fined  BOCOM International Securities Limited (BISL) a total of $19.6 million for a series of regulatory breaches, including failures concerning the handling of third party fund deposits and the maintenance and implementation of a margin lending and margin call policy. The company was also found to have failed to put in place adequate and effective controls to identify deposits made into client accounts by third parties, hence failed to ensure compliance with the Guideline on Anti-Money Laundering and Counter-Terrorist Financing and various provisions in the Internal Control Guidelines and the Code of Conduct.
Uncovering the Indicia of Fraud in Complex Cases with Incomplete Forensic Data
By Eric A. Kreuter

 April 2020
Deception is the main tool of fraudsters and the hallmark of many types of fraud. When used skillfully, deception often leads to not one incident of embezzlement, but a pattern of acts over time as recurring opportunities surface. Fraudsters discover weaknesses in internal controls and engineer ways to defeat the system, thereby siphoning funds. When this strategy pays off, there can be a narcotic effect, encouraging the fraudster to continue the behavior as an easy means of satisfying hidden financial needs or, worse, a simple appetite for greed. This article outlines some of the steps of an investigation into embezzlement before discussing in detail several cases where incomplete forensic data was ultimately not as great a hindrance to finding the truth as those who withheld that data might have hoped.
COVID-19: Considerations for Internal Controls Over Financial Reporting
by Scott H. Kimpel
April 14, 2020
With many public companies recently completing the first fiscal quarter of 2020, the quarterly financial statement close and reporting process is in full swing for a large percentage of issuers. The COVID-19 pandemic poses unique and novel challenges to those companies during this process, particularly with respect to design and testing of both internal controls over financial reporting and disclosure controls and procedures. With public companies now under increasing scrutiny, we recommend that companies take stock of what has changed in the current financial reporting environment, consider whether existing controls are sufficient to prepare financial statements and disclosure documents at the reasonable assurance level, and determine what new controls (if any) are necessary to reduce the risk of errors and fraud. Regulators, congressional oversight committees, the press and the plaintiffs' bar are gearing up to pursue all those who stumble.
Keeping SOX on track when pandemic strikes
April 28, 2020

It's been several weeks since COVID-19 entered our vocabulary and made working from home the new normal. I've spoken with many SOX professionals over the last month about the challenges of adapting to remote work and how they are responding to the impact of the COVID-19 pandemic.In the forefront, SOX professionals are thinking about how to revise their risk management playbook for the year in response to the pandemic. Many SOX teams are also talking about the tools they need to collaborate with each other and stakeholders to execute SOX compliance effectively and comprehensively while working remotely.

JP Morgan Seoul office punished for poor internal control system
By Kim Bo-eun
April 27, 2020 
The Financial Supervisory Service (FSS) has directed J.P. Morgan's Korean brokerage unit to improve its internal control systemThe authority's action came a week ago, after it determined in an inspection conducted last year that the brokerage unit did not have a proper control system monitoring exchanges among affiliates.The FSS concluded that the brokerage unit intervened in the sales process of structured deposits of J.P. Morgan Chase Bank's Seoul branch.
Control Quotes
"I'm not really a control freak, but... can I show the right way to do that?"  

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ici logo 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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