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Control Chatter                                                   December 2018
News that Control Professionals Need to Know

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 *All New* Internal Control online courses
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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 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%, so get started today! 
****Limited Time Only****
Test your Knowledge of Internal Control
*** Take the  Internal Control Knowledge Mini-Assessment ***
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
In This Issue
All New Internal Control online courses
Risk Appetite - What is your Threshold?
ICI Announcements
SOX 404(b) Provides Investor Value After All
You've seen something improper. What's next?
SEC accounting fellows address evaluation of internal control over financial reporting
The Malaysia Scandal Is Starting to Look Dire for Goldman Sachs
Setting the 2019 Audit Committee Agenda
How the feds have abused the Sarbanes-Oxley law
Keys to fraud risk oversight
Can business behave better?
Are You One of These?
By Michael Pregmon, Jr., Ph.D., CICP
COO and Managing Director
Dr. Michael Pregmon, Jr.
COO and Managing Director 
It is alarming the number of supposed professional individuals who fail to keep up with their profession. I was absolutely dumbfounded when I received a response from a person who declared: "Certification - why?   I know all I need to know about the internal control profession!"
Recently, the Institute completed a brief review of active certificate holders Certified Internal Control Specialists (CICS) and Certified Internal Control Professionals (CICP). We learned that a surprising number of those certified had not reported their continuing education and renewed their certificates. Hopefully, the professionals with expired certificates are keeping up with their "trade" and perhaps are just late in updating their certificates.
The Internal Control Institute, as with any certifying organization, often receives inquiries about individuals who report being actively certified. This occurs most often during the job application and verification process. So it is important to keep your certification updated. But even more important is the need to keep abreast of the latest developments in your area of expertise.
Because of advances in technology we seem to be moving at "breakneck" speed in all professions. Certainly, the medical profession provides a good example, with significant advances occurring almost daily. I recall a conversation I had some time ago with my personal family physician. She lamented that, as a General Practice physician, she was preparing for her recertification exam. As a result, she had to become proficient on the latest childbirth techniques, even though she hadn't delivered a baby in years, and didn't expect to do so in her practice.
Assuredly, internal control is not a "life or death" profession as in the medical field or a few other professions. But, as an employer, your organization is certainly counting on your expertise.
With internal control, we continue to experience changes and new processes for improving control activities, such as the recently revised COSO ERM framework.  Nevertheless, process improvement in other business activities serves to improve overall control activities for the organization. Remember - continuous improvement is a quality initiative and continuous improvement starts with continual education.

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. 

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.

Training Plans :

São Paulo  - February 11 to 15, 2019
Brasília - March 11 to 15, 2019
Rio de Janeiro - April 1 to 5, 2019
Fortaleza - April 22 to 26, 2019
Belo Horizonte - May 13 to 17, 2019
Porto Alegre - June 3 to 7, 2019

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


Congratulations to all who participated in the CICS Training Class held in Beijing November 2018
Training Plans:

Hangzhou - January 10 - 13, 2019
Beijing - March 20 -23, 2019

Individuals or companies interested in internal 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 :

Brussels - January 22, 2019 (in French)
Luxembourg - February 28, 2019 (in French)

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:
ICI is proud to announce it has entered into an agreement with Better Business Governance - APAC PTE LTD (BBG) as its 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:

CICS Training Class Amman Jordan November 2018

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

Training Plan 2019
Certified Internal Control Specialist (CICS) Certification Preparation Programs are scheduled as follows:

Dubai, UAE February 24 - 28, 2019
Tripoli, Libya - February 24 - 28, 2019
Doha, Qatar - March 3 - 7, 2019
Amman, Jordan - March 10 - 18, 2019
Ramallah, Palestine - March 10 - 14, 2019
Kuwait City, Kuwait - March 17 - 21, 2019
Muscat, Oman - April 7 - 11, 2019
Tunis, Tunisia - April 7 - 11, 2019
Cairo, Egypt - June 30 - 4 July, 2019

Interested applicants in that 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

Singapore, Malaysia, Indonesia and Taiwan:
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. Barry Dingga -
Taiwan - Ms. Mickey Tai -


For information on scheduled ICI Certification and program sessions, please contact ICI Turkey  below:

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
CICS examinations to be held in Vietnam: 

11 April 2019

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

For more information on activities being planned please contact:
Mr. 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.
SOX 404(b) Provides Investor Value After All
Study results contradict critics who are trying to water down the Sarbanes-Oxley requirement for auditing internal controls over financial reporting.
Since the 2002 enactment of the  Sarbanes-Oxley  Act, no provision of the law has provoked more animus than Section 404(b), which requires public companies to have external auditors annually assess the adequacy of their  internal controls  over financial reporting.  Scorned recently  by a prominent economist as "one of the most costly and counterproductive regulations ever introduced," SOX 404(b) may be trimmed, many observers believe. Whereas the provision currently applies to companies with public floats of at least $75 million, that threshold may soon be raised to $250 million or even $500 million.  Yet in the longstanding controversy over 404(b), the voice of one constituency has been conspicuous by its absence - and ironically, it's the very group the regulation supposedly protects: namely the investment community. Whether the provision actually holds value to investors has remained unclear. Now, the January issue of the The Accounting Review, an American Accounting Association journal, includes the first study whose primary purpose is gauging investor demand for internal controls (IC) audits.
You've seen something improper. What's next?
These expert tips can help finance professionals have courageous conversations in the workplace.
By John Lehmann-Haupt
December 1, 2018
The workplace can be fraught with uncomfortable situations. Even in the best managed companies, problems can arise. Co-workers can behave unethically, criminally, or recklessly. A workplace transgression creates a dilemma for witnesses. Do you speak up and damage your position, the company, or a co-worker? Or do you stay silent and let the problem persist? Research has shown that amongst employees who observe workplace misconduct, about 56% remain silent, whether for fear of reprisal or through reluctance to go against the group. "It's clear that over time, whistle-blowers have been perceived and characterised very negatively," said Sandy Boucher, a fraud and corruption investigator and whistle-blower systems practitioner at Grant Thornton LLP in Canada. "That's beginning to change. With high-profile cases like the Panama Papers, people are seeing that when you blow the whistle on something bad, that's a good thing."
SEC accounting fellows address evaluation of internal control over financial reporting
December 10, 2018
A number of members of the SEC accounting staff addressed the 2018 AICPA Conference on Current SEC and PCAOB Developments.  Some of the remarks provided helpful guidance for evaluating internal control over financial reporting.
Operating effectiveness. An accounting fellow,  Emily Fitts, addressed internal control over financial reporting, focusing on the evaluation of operating effectiveness of controls and preparation of material weakness disclosures. Each year, she noted, management is required to evaluate the effectiveness of these controls, i.e., whether they "have been implemented and actually operate in a manner consistent with their design," an exercise that is especially important this year in light of the implementation of new accounting standards. The first step is "to determine if the control is operating as designed." To that end, she suggests the following questions:
The Malaysia Scandal Is Starting to Look Dire for Goldman Sachs
December 28, 2018
Malaysia has filed criminal charges against Goldman Sachs and two former executives over their alleged role in the ransacking of a multibillion-dollar state investment fund. Goldman Sachs, which has survived and thrived despite countless scandals over the years, may have finally stepped in a pile of trouble too deep to escape. There's even a Donald Trump angle to this latest great financial mess, but the outlines of that subplot - in a case that has countless - remains vague. The bank itself is in the most immediate danger. The company's stock rallied Thursday to close at 165, stopping a five-day slide in which the firm lost almost 12 percent of its market value. The company is down 35 percent for the year, most of that coming in the past three months as Goldman has been battered by headlines about the infamous 1MDB scandal.Just before Christmas, Malaysian authorities filed criminal charges against Goldman, seeking a stunning $7.5 billion in reparations for the bank's role in the scandal. Singapore authorities also announced they were expanding their own 1MDB probe to include Goldman.In the 1MDB scheme, actors tied to former Malaysian Prime Minister Najib Razak allegedly siphoned mountains of cash out of a state investment fund. The misrouted money went to lavish parties with celebrity guests like Alicia Keysa $35 million jet, works by Monet and Van Gogh, property in New York, Los Angeles and London, and (ironically) the funding of the movie The Wolf of Wall Street.
Setting the 2019 Audit Committee Agenda
Protiviti Insights
With change on the horizon, 2019 offers an opportunity for directors to self-assess committee composition and scope with an eye toward improving the control environment, the financial reporting process, and disclosure controls and procedures related to non-financial disclosures. In this issue of  The Bulletin , we have identified several agenda items for audit committees to consider in the year ahead. In formulating the agenda items for 2019, we considered input from our interactions with client audit committees, roundtables and surveys we conducted during 2018, as well as discussions with directors in numerous forums.
How the feds have abused the Sarbanes-Oxley law
December 15, 2018
In 2016, three staffers on Ron Paul's 2012 presidential campaign, including campaign manager John Tate, were  convicted of helping  arrange for money to be funneled through a vendor to former Iowa State Sen. Kent Sorenson. They did this in exchange for Sorensen's endorsement of Paul in the 2012 Republican presidential primary, and then hid the transaction by reporting it to the Federal Election Commission as something else.  Earlier this year, the U.S. Court of Appeals for the Eighth Circuit in St. Louis  upheld Tate's felony conviction , and he has now asked the Supreme Court to take up his appeal.  This week, the Coolidge Reagan Foundation  filed an amicus brief  urging the high court to take the case. Why? Because in the government's pugnacious prosecution of Tate lies a profound threat to the free speech and due process rights of all Americans.  
Keys to fraud risk oversight
Organisations seeking to optimise their fraud management efforts could benefit from establishing a fraud risk appetite statement and developing a set of key risk indicators, or KRIs.
By Dalit Stern
December 1, 2018
M onitoring the risk of fraud through measurement and reporting is a key component in fraud risk management. It allows management to focus limited resources on the areas of highest risk to the organisation.
A quantitative approach to fraud management through the use of fraud risk appetite and key risk indicators (KRIs) is a natural step in the evolution of fraud management programmes.  KRIs have become an indispensable tool used in many operational risk management frameworks. Developing KRIs is crucial to the success of any risk management programme, as KRIs enable organisations to predict potential risk events. When properly designed and effectively communicated, KRIs are useful in identifying areas where additional controls or other mitigation is needed. Alternatively, KRIs may drive risk acceptance decisions.  While the development of a fraud risk appetite statement and fraud KRIs is not a legal requirement, for most financial institutions around the world the use of KRIs as a management tool is common. For example, the use of KRIs is a requirement associated with the calculation of a bank's operational risk capital charge in the banking industry.
Can business behave better?
DECEMBER 16, 2018 
It's time to try a market-led approach to corporate governance.  Hardly a week passes nowadays without a new corporate governance-related issue roiling the markets. The ripples created by IL&FS and ICICI Bank had hardly begun to die down when news broke of Jet Airways' principal lender, State Bank of India, ordering a forensic audit of the troubled airline's accounts for the past few years. Even the august Reserve Bank of India's board of directors, which met last week under new Governor Shaktikanta Das after the sudden and tumultuous exit of Urjit Patel, reportedly felt that governance standards at India's central bank, which also doubles up as the banking regulator, needed some improvement. The trouble is, most of the solutions tried earlier appear to be not working quite as expected. Over the years, India has taken a number of steps to improve corporate governance and protect the interests of investors, lenders and other stakeholders. The Companies Act, one of the most massive pieces of legislation in the world, has been comprehensively reworked. When it comes to accounting and financial reporting, the Indian standard, IndAS, has been vastly tightened and brought more in line with global best practices, making assessments of corporate assets and liabilities much fairer and more transparent than they were under the previous Indian Generally Accepted Accounting Principles (IGAAP) regime.
Control Quotes
Being the best at whatever talent you have, that's what stimulates life. 
Tom Landry
Help Keep Everyone Informed...
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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
Control Chatter is a monthly news summary of the top stories concerning internal control and corporate governance.  Control Chatter is prepared by the staff of Internal Control Institute for the benefit of their members and associates. Please consider it for your personal use or pass it on to associates who may have an interest in one or more of the topics by clicking on the Forward email button below.