Blogs

Internal audit teams at companies preparing to go public face a tricky balancing act in their journey toward Sarbanes-Oxely readiness. Namely, how do you keep sight of the risk assessment forest through the documentation trees?  That is, documenting your internal controls is always going to be an important part of SOX readiness — but it’s not necessarily the most important part. The most important part is the risk assessment that management should undertake, to understand what its most material risks are.  And yet, far too often, internal audit teams get bogged down in the minutiae of cross-walking frameworks and documenting controls at the expense ...
Good data governance is the cornerstone of any successful GRC program, so today let’s talk about something that can often be a mortal threat to good data governance — unstructured data. Unstructured data is just what the name suggests: data that exists somewhere within your enterprise, but lacks any specific structure to help you understand the information it contains. Examples include…  Text-based data , such as emails on an employee’s laptop, AI-generated marketing materials, or customer reviews left on your corporate website Multimedia data including audio recordings, training videos, security camera footage, or photos posted to a departmental ...
On August 13, 2025, the SEC announced a new “ statistics and data visualization page ” that provides a wealth of capital market statistics including information about public offerings, exempt offerings and number and categories of reporting issuers. According to the SEC’s Press Release , the new webpage provides: “Data Visualizations: interactive graphics based on statistics Statistics Table: fundamental statistics regularly updated with the most recently available data Statistics Guide: description, calculation method, and data source for each metric Statistics Download: all available statistics in the table ...
DISCLAIMER: This blog post is no longer current or valid as of July 16. The COSO draft corporate governance framework referenced in this post has been removed and is no longer available for public comment.  Global businesses need a system of internal controls that can withstand scrutiny from any direction. So today let’s turn our eyes to the United Kingdom, where a new “Failure to Prevent Fraud” offense could pose some significant challenges for compliance and internal audit teams later this year.  Good corporate governance is about getting your organization to pursue its business objectives — financial targets, market expansion, ethical business ...
By Matt Kelly Global businesses need a system of internal controls that can withstand scrutiny from any direction. So today let’s turn our eyes to the United Kingdom, where a new “Failure to Prevent Fraud” offense could pose some significant challenges for compliance and internal audit teams later this year.  As the name implies, the law (going into effect Sept. 1) exposes companies doing business in the U.K. to criminal liability if they fail to prevent fraud that happens within their enterprise — but companies can avoid that liability if they have implemented “reasonable procedures” meant to prevent fraud from happening. The question for internal ...
By Matt Kelly Artificial intelligence is transforming all parts of the corporate enterprise — including, unfortunately, frauds launched against your enterprise. Which means your anti-fraud controls must transform too, or else you’ll never keep pace with the threat that AI-enhanced fraud poses.  That’s not likely to be an easy task. Fraudsters are hatching ingenious ways to use AI in furtherance of their schemes, with the potential for severe financial or data losses to your company. Moreover, most laws and regulations imposing a duty of care to prevent fraud are “technology agnostic,” in the sense that it doesn’t matter what specific tricks fraudsters ...
By Matt Kelly, Radical Compliance For more than 20 years now, internal audit and corporate accounting teams have strived to build effective internal accounting controls — necessary for strong financial reporting, Sarbanes-Oxley compliance, anti-fraud programs, and more.    Along the way, however, a pattern cropped up that hasn’t yet received the attention it deserves: internal  accounting  controls have converged with internal  cybersecurity  controls.  For example, recall the CrowdStrike disaster from 2024, when businesses around the world came to a screeching halt thanks to a  flawed software update that cybersecurity firm CrowdStrike ...
The days of a cybersecurity breach being only “an IT issue” are over. During his years as an internal audit leader, Grant Ostler, Executive Advisor of Pro Groups, survived two cybersecurity incidents. And while he can confidently say it is never fun, it’s much more painful to go through one without a dry run first. Pro Groups, the community for accounting & finance, sustainability, and audit & risk professionals, invited a few members from the Las Vegas chapter to run through a simulated cybersecurity incident to share how they would respond.    Historically, auditors, controllers, and sustainability professionals haven’t been involved in ...
As companies prepare for their next proxy statement, the SEC Enforcement Division has sent a reminder to focus carefully on perks disclosures. In the latest of its on-going series of perks related enforcement actions, on December 17, 2024, Express, Inc . was charged with failure to disclose $979,269 worth of perks paid to its CEO. (You can read about earlier cases in this blog post .)   A majority of the undisclosed perks were related to the CEO’s authorized personal use of chartered aircraft. The company did not use the appropriate definition of perks when analyzing these costs, which resulted in the disclosure failure.   In ...
Company:  Morton Salt Role:   Senior Lease Analyst  Location: Overland Park, KS  Job Posting : (7) Senior Lease Analyst | Morton Salt | LinkedIn Job Description The Senior Lease Analyst will be responsible for all aspects of the Company’s lease accounting and reporting in accordance with US GAAP, including lease identification and classification, the preparation of journal entries, reconciliation of rollforwards to the general ledger, and preparation of the annual lease footnote disclosures. In addition, this role will work directly with plant controllers and operations personnel to maintain the completeness and accuracy of ...
Company:  Morton Salt Role:  Manager of Financial Reporting Location: Overland Park, KS  Job Posting : (7) Manager of Financial Reporting | Morton Salt | LinkedIn Job Description The Manager of Financial Reporting will be responsible for preparing all aspects of the Company’s monthly and quarterly consolidated financial statements in accordance with US GAAP, which will be delivered to senior management and the Board of Directors. Annually, this role will be responsible for preparing the audited consolidated financial statements and footnote disclosures. In addition, this role will prepare the monthly reporting package delivered ...
Company: e.l.f. Beauty. Inc Role:  Director, SEC Reporting Location:  Remote Job Posting : https://www.linkedin.com/ jobs/view/3897776744 The Director, SEC Reporting will partner with various teams across the company to ensure accuracy and completeness of disclosures in the Company’s SEC filings, including the Forms 10Q, 10K, 8K and proxy statements. Our new Dircector will be responsible for drafting and processing changes to e.l.f.’s 10Q, 10K and 8K through filing with the SEC while partnering with legal on S-8 and other filings, as necessary. In this role you will monitor current activity of the FASB, SEC and other relevant authoritative ...
Company: BOK Financial Corporation Role:   Senior Accountant II, Financial Reporting Location:   Tulsa, OK Job Posting : https://jobs.bokf.com/job/Tulsa-Sr-Accountant-II%2C-Financial-Reporting-OK-74101/1135207200/  The Senior Accountant II, Financial Reporting position is primarily responsible for the preparation and filing of financial reports for various regulatory agencies including, but not limited to OCC, FDIC, FRB, SEC and FINRA. This position performs detailed data analytics, monitors and assists in developing and maintaining internal controls and policies and procedures over financial reporting. Performs assessments and technical ...
This content has been provided by Equity Methods, a Community and Chapter Sponsor of the SEC Professionals Group. Equity Methods provides valuation, financial reporting, and human resources advisory services related to equity compensation and other complex securities. On March 8, Equity Methods is hosting its annual state of the union in equity and executive compensation webcast. Now in its 11th year, the webcast provides a panoramic look across the top issues facing both the office of the CFO and CHRO.  The stock compensation landscape has taken on new complexity and risk in the wake of recent SEC rule-making, FASB standard-setting, and a host ...
By George Wilson As we discussed in this blog post , one of the challenges in the SEC’s July 2023 cybersecurity disclosure rules is determining when an Item 1.05 Form 8-K to disclose a material cybersecurity incident will be required.  The Instructions for the 1.05 Form 8-K state: Item 1.05 Material Cybersecurity Incidents.  (a) If the registrant experiences a cybersecurity incident that is determined by the registrant to be material, describe the material aspects of the nature, scope, and timing of the incident, and the material impact or reasonably likely material impact on the registrant, including its financial condition and results ...
By George Wilson On November 14, 2023, the Division of Enforcement announced its 2023 results in this Press Release and  related Addendum .  According to the Press Release, the Division of Enforcement: Brought 784 enforcement actions, an increase of 3%; Levied financial remedies totaling $4.949 billion, down from $6.439 billion the year before; Obtained officer and director bars against 133 individuals, the highest number in more than a decade; and Continued to focus on gatekeepers. The Press Release highlights that 2023 was a record year for the Whistleblower Program with awards of ...
With artificial intelligence (AI) at the forefront of most company discussions about innovation, this updated report looks at how U.S. public companies are discussing the opportunities and risks that it provides and poses for disrupting business models. MyLogIQ’s key findings from the report were that: 1% of directors have AI experience. 5% of companies have directors with AI experience. 8% of companies discussed AI in the MD&A section of their 10-K filings. 15% of companies listed AI in the Risk Factors section of their 10-K filings. The top 3 AI risk factors were: Government Regulation of AI Ability to Cost Effectively and Competitively ...
By George Wilson, On November 22, 2023, the SEC postponed the effective date of its  Share Repurchase Disclosure Modernization rule .  The postponement was in the wake of an opinion by the U.S. Court of Appeals for the Fifth District in Chamber of Com. of the USA v SEC .  You can read more in the SEC’s Announcement .  The rule has been stayed pending further Commission action.  Companies do not need to comply with the new rule at this time.  It would have required daily share repurchase disclosures for the first full fiscal quarter that began on or after October 1, 2023. As always, your thoughts and comments are welcome. #Blog #CommunitySponsor ...
By George Wilson On November 7, 2023, the Division of Corporation Finance announced a new online system for submitting shareholder proposals under the Division’s process to provide informal, non-binding staff views regarding companies’ intentions to exclude proposals from proxy statements.  Companies must use this new online form.  Emailed submissions will not be accepted.  You can read more and find a link to the online form here .     This announcement does not change the Division’s process for providing informal, non-binding views, which is described on this webpage .   As always, your thoughts and comments are welcome! ...
As segment reporting continues to be an ongoing area of concern for the SEC, we compiled a report reviews segment reporting comment letter trends. With the expected adoption of a significant update to segment reporting requirements before the end of calendar year 2023 or Q1 2024, knowing what the SEC is focusing on can help public companies like yours stay ahead of possible areas of risk. Here are some highlights we found among other key findings contained in the report: There are nine main segment reporting topics that the SEC is focused on in comment letters. Companies should be prepared to ensure segment consistency within filings ...