SOX 404 Compliance
While completing their first SOX attestation, one of the world’s largest biopharmaceutical outsourcing organizations with operations throughout 43 countries in 56 locations and approximately 6,200 employees, knew that building and maintaining a Sarbanes-Oxley compliance program presented challenges — unearthing and solving the issues that stood in the way of compliance and managing the myriad of spreadsheets and documents that are needed for the task.
In 2005, the Company completed its first year of SOX primarily by performing the tasks in shared services centers in the United States, the United Kingdom and Germany. The Company identified over 1,000 key business controls; remediate and re-tested several hundred key controls and implemented a document control process; tracked remediation; and then tested and re-tested its program.
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Organizations identifying and testing a large number of Key Controls is usually the result of two mistakes:
1. Inclusion of operational controls as Key financial controls – i.e. the control cannot be mapped to an account/assertion intersection.
2. Over-reliance on detailed, transaction level process controls when Entity Level Controls, which occur less frequently and closer the external financial reporting cycle, can often provide the required degree of precsion for identifying material misstatements.