Preparing for UK SOX

Back in 2002 when the Sarbanes-Oxley (SOX) Act came into force I was working in the global corporate audit department at State Street in Boston.Although the title of the Act refers to public accounting reform, I remember having to explain to our internal clients around the world what the purpose of the legislation was, and how it affected them.  I had to explain the key elements of sections 302 and 404, which assigned senior manager accountability and called for robust testing of the framework of internal controls over financial reporting.  At State Street, and at major financial services organisations since, I had to help senior stakeholders to articulate what the SOX control framework was, and to identify specific SOX controls.  Further, I had to assess the gaps in the framework once it was documented and design internal audit testing for those controls such that external auditors could rely on internal audit work.


Culture, Conduct and Value(s)

Prior to reading Mark Carney’s new book Value(s), Building a Better World for All I was involved in researching a response to the crisis of corporate culture and failures in ethical conduct in financial services.  Solely focusing on assigning more direct accountability and punishing more senior individuals did not seem fit for effectiveness, in that it did not seem to truly address the root cause.  Also, from within


Comply or Explain: Expectations for an internal audit function

For over two decades the UK Corporate Governance Code (‘the Code’) has set the expectations and provided guidelines for corporate governance for UK listed companies. The Financial Conduct Authority (FCA) listing rules require companies to state clearly in their annual reports how the Principles of the Code have been applied.  The listing rules allow companies to explain any apparent deviations from the Principles in their annual reports so interested parties can evaluate the application of the Principles.  This ‘comply or explain’ basis allows companies flexibility in organising and administering their governance frameworks, ostensibly making them more fit for purpose by aligning them with their organisation’s particular circumstance.


Climate Risk: What should SMEs be doing now?

The earth’s climate is changing, and in response the governments of the world agreed to take significant measures to eliminate carbon emissions.

By 2030, in just nine years’ time, the world is scheduled to reduce carbon emissions by half and then by 2050 carbon emissions are intended to be effectively eliminated, with a ‘net zero’ carbon emission target. Achieving this will require systemic transformation of the world economy and of the businesses that operate within it.


Mind the GAAP (part 1)

This blog will provide information and opinions on matters of interest to corporate entities on the treatment of blockchains and digital currencies for accounting, tax, audit and regulatory purposes.


Mind the GAAP (part 2)

The second part of the article will explore the options for accounting treatment of digital currencies. It is not possible to reach a unified solution on the matter because the cryptocurrencies are a new economic phenomenon.

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