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Internal Information Controls: Corporate Accountability

By John L. Reed and Matt Neiderman

The swift enactment of Sarbanes-Oxley (SOX) in the wake of numerous corporate scandals brought at least as many questions as solutions for executives charged with ensuring corporate compliance with SOX's many provisions. As the various compliance deadlines for SOX draw near or expire and the Securities and Exchange Commission (SEC) continues to release rules and guidelines, even more questions emerge, requiring executives to quickly gain familiarity with otherwise unfamiliar topics in order to avoid the potential liability associated with violations of the law. One such topic is the security and control of financial information.

Section 404 of SOX requires corporate executives and auditors to confirm the effectiveness of internal controls for financial reporting. Similarly, Section 302 requires that executives certify the accuracy of corporate financial reports. Of course, the accuracy of financial reports is a direct product of the accuracy and integrity of the information on which they are based. Although the precise scope and impact of Sections 404 and 302 remain to be seen, it has become clear that compliance with SOX requires certain levels of security to protect the integrity of corporate information and to guard against its alteration, theft or misuse. Given the increased level of information piracy and the growing use of offshore IT resources, this may be an increasingly difficult task.

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