Sarbanes-Oxley Ongoing Compliance Guide: Key Processes and Summary Checklists

Future State Opportunity: Compliance Optimization

Companies need to optimize their ongoing compliance programs in the future to improve control effectiveness, realize cost savings, and provide tangible benefits to the organization. This entails defining the organizational structure, roles and responsibilities, ongoing compliance process, training and communication (including the audit committee and board of directors), reporting, and incorporating the use of technology within the ongoing compliance process. Specifically, a comprehensive, long-term program should be structured as shown in Exhibit 2.1.

Exhibit 2.1. Comprehensive Compliance Program Pyramid

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Governance

A good governance approach requires that the tone at the top be established and continuously reinforced. The organization should develop an integrated compliance strategy, and objectives should be clearly outlined and communicated. Senior executives should seek to establish and foster a culture of integrity and high ethical standards. Ultimately, developed governance policies as well as adherence to these established guidelines should be continuously monitored, and ownership, responsibility, and accountability for good governance and internal controls should be embedded throughout the culture of the organization.

Enterprise Risk Management

The creation of a comprehensive ERM program requires the ...