Monthly Archives: July 2015

Follow the money

“Soccer Probe’s Latest Target: Banks,” The Wall Street Journal, July 24, 2015 C1. Banks asked to explain how they failed to detect the large payments of bribes in the FIFA soccer/football scandal.

Did the banks know, or should they have known, that there was illegal activity going on?  Were their controls effective?  Or reasonable?  And did they follow their own procedures?

It’s not a banking issue.  It’s a control issue.

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Filed under Board, Business Case, Compliance, Compliance Verification, Controls, Governance, Internal controls, Oversight, Oversight, Risk, Third parties

Can you be too secure?

“Bank Cop Pulls Over Messaging Platform,” The Wall Street Journal, July 23, 2015 C1.  The new entrant to the Wall Street market for secure instant messaging may be too secure.  Regulators wonder whether the information retention and encryption offerings may be used to cloak bad behavior.

Don’t you have to wait for bad behavior before raising a complaint?  Nothing this service offers is illegal; it’s just different.  Is this just one of the challenges of new technology?

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The cobbler’s children have no shoes

It’s like a fat doctor telling you to go on a diet.

“Hacking Software Firm Hacked,” The Wall Street Journal, July 7, 2015 B1.  Records show that firm sold its software to customers in countries with restrictive regimes, perhaps in violation of law.  Software allows law enforcement to read encrypted emails.

If you’re in this business, should you expect such an attack.  It’s not like you’re Sony or the US government.

 

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Filed under Board, Business Case, Controls, Governance, Internal controls, IT, Management, Oversight, Oversight, Protect, Protect assets, Protect information assets, Risk, Security, Third parties

Mandated Clawback

The SEC has proposed forcing top executives to pay back their bonuses if financial statements have errors.  And not just the CFO.

Executives Could Pay for Accounting Errors,”  The Wall Street Journal, July 2, 2015 C2.  Proposal pending public comment.

Now, we can all be for taking steps to make sure a company’s financial statements are correct, but is it useful to penalize executives who have no control over the financials?  And is it proper for the government to mandate this, rather than leaving it to the shareholders and the boards to work this out?  And should executives get bonuses for results they do not control?

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Filed under Board, Business Case, Controls, Duty of Care, Governance, Internal controls, Oversight, Oversight, Risk