Enabling Sarbanes Oxley Compliance
Sarbanes Oxley compliance is not a one-day, a one-month, or even
a one-year project; instead, Sarbanes Oxley compliance should be
built into your corporate infrastructure as early as possible
when you begin making changes. The more quickly you transition
your business into long-term strategy change, the better you're
going to be able to control Sarbanes Oxley compliance issues.
There are a number of issues you can expect to impede this
process:
Project mindset - Your managers will probably look at Sarbanes
Oxley compliance as a project with a clearly definable endpoint.
This is not at all the case. The more quickly you can move to
change their attitude, the more likely you'll have a clear and
simple transition into the new way of doing business. You can
use such items as continual education and newsletter updates as
ways to show your managers that you expect Sarbanes Oxley to
change the way they do business forever.
Manpower issues - Sarbanes Oxley compliance is not friendly to
businesses who are trying to streamline their workforce. Though
you may have to increase the size of your employee pool at the
beginning of your Sarbanes Oxley compliance process, you can
expect this pool to decrease as you gradually fold Sarbanes
Oxley compliance methodologies into your normal way of doing
business.
Poorly-defined roles in internal control - if you don't clearly
lay out responsibilities such as auditing, accountability, and
project management, your Sarbanes Oxley compliance]tasks are
going to be needlessly complicated. You should also make it very
clear whose roles it will be to see to the Sarbanes Oxley
rollout and to whom these people will be ultimately answerable.
Improvisational approaches - Jumping into Sarbanes Oxley
compliance will simply not work. You need to step back and plan
how you're going to be incorporating the structures and
requirements of Sarbanes Oxley into your daily work routines.
And once a plan has been defined, you must follow the plan, and
ensure everyone else is also following it.
Underestimating the Impact to Technology - Sarbanes Oxley would
simply not have been possible twenty years ago. Technology is
critical for your compliance with this act. You can expect to
make significant technology investments as you procede to
implement Sarbanes Oxley compliance. Investments will cover such
things as sustainable compliance with repository, work flow, and
audit trail functionality. In addition, your internal control
monitoring and reporting will depend heavily on technology. At
some large corporations, it might be worth looking into hiring
another full-time IT person who has been specifically trained in
implementing and maintaining Sarbanes Oxley technological
infrastructure.
Ignored Risks - Risk assessment is vital in Sarbanes Oxley
compliance. One of the first meetings you should have as you
implement Sarbanes Oxley compliance is one on risk management.
Inadequately assessing risk can lead to serious financial
reporting errors that can render your investment in training and
compliance useless.
Successful Sarbanes Oxley compliance
Your framework for sustained Sarbanes Oxley compliance should
include the following:
* Effective, efficent evaluation of testing, remediating,
monitoring, and reporting controls * Integration of financial
and internal control processes * Proper use of technology to
comply with Sarbanes Oxley requirements * Clear roles and
responsibilities, a solid chain of command, and assigned
accountability * Continual education and training in Sarbanes
Oxley compliance * Adaptability and flexibility to respond to
Sarbanes Oxley compliance-induced changes