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

Generating Value from Compliance

The resultant changes from the Sarbanes-Oxley Act, specifically SEC requirements and regulations, have forced businesses to reevaluate their organizational structures and systems of internal control and to create and/or modify the roles of individuals involved in the financial reporting process. Executive management is now explicitly responsible for establishing and maintaining a system of internal control over financial reporting and conducting an annual assessment of the same. The CEO and CFO must certify the accuracy of financial reports filed with the SEC under the risk of criminal penalties and fines. Other members of the executive management team are responsible for the new requirements relating to codes of ethics, record retention, insider trading, whistleblower policies, as well as other legal and human resource issues. While the Act does not specifically mention any requirements of managers and supporting staff, these individuals generally have been directly responsible for most of the additional work that is required for initial and subsequent ongoing compliance, and they must adhere to the same ethical standards of executive management.

Companies have experienced significant increases in costs and time necessary to achieve and maintain compliance with the provisions of the Act and the related regulatory changes. Unequivocally, the most significant cost increases have been related to the external auditor attestation of internal control ...