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In addition to the logistical and global communications challenges, risk management must be carefully considered Risk identification, on the local level as well as on a global basis, comprises three basic variables: known risks, known unknowns, and unknown unknowns The difference is that, on a global basis, the risks from unknown unknowns are much greater, because of logistical issues and cultural issues Of the two, cultural issues can present the greatest challenge and the greatest amount of unknown unknowns Risk identification and mitigation of unknowns in a localized Sarbanes-Oxley compliance effort can come to seem fairly tame once you have completed one or two engagements In contrast, the unknowns in a global Sarbanes-Oxley compliance project can really be, well, unknown! Consider the difference in local customs in the United States when going from east to west, or north to south, or urban to rural Imagine what differences there are from global region to global region, or country to country Aside from local customs,
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there are language differences, religious differences, and more The point is that unless you have a management team that is intimately familiar with the culture, ethnicity, religious customs, and language of the specific locale, the only tool you have to identify the unknown risks is your imagination a truly scary thought! In situations like this, communication can be the key factor in successfully completing a Sarbanes-Oxley compliance project The team in the field must be relied on to identify potential risks as they present themselves and communicate them to management in a timely enough fashion that controls can be put in place So far we have considered logistical, cultural, religious, and ethnic differences from the unknown-unknowns point of view What about the known unknowns, such as competing compliance issues Laws change from country to country and region to region One of the main concerns of opponents of the Sarbanes-Oxley Act is the buyin from foreign markets The fear has always been that foreign interest in the US market will drop because of the expense involved in becoming Sarbanes-Oxley compliant If they are to satisfy the PCAOB, foreign companies will have to follow the same stringent regulation as US companies How will this play out when US companies try to implement Sarbanes-Oxley compliance projects in foreign countries It is clear that the EPM team will have to be comprised of a diverse group of subject-matter experts experts in local laws as well as the languages and customs of the region in which the compliance project is taking place Where does one find a dream team such as this The answer is in the company s ERP package It is well known that the ERP package is essential in assessing a company s internal controls over financial reporting From an enterprise portfolio management perspective, it is also an excellent tool for identifying the best internal resources: the people who have the required skill sets for the roles and responsibilities needed for an enterprise-wide compliance project So far we have discussed risk management in general There is, however, another risk factor to be discussed: the fact that different industries come with their own inherent risks Companies that deal in merchandise and commodities will incur more and different risks than companies that deal only in information Manufacturing companies, for example, have inventory and supply chain management
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issues added to their potential risk factors Supply chain management (SCM) is just as important as ERP for these companies when it comes to assessing internal controls over their financial reporting There are software packages that will help manage an enterprisewide project, from a project management point of view; such packages usually use the Internet as a centralized project management database Naturally, the cost of this software package must be included in the compliance budget Also, to be useful and successful, it will have to be integrated with the company s SCM and ERP packages
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