Manager's Guide to the Sarbanes Oxley Act:
Improving Internal Controls to Prevent Fraud
by Scott Green
Foreword by Ira Millstein
Table of Contents
Foreword (by Ira Millstein)
Preface
Acknowledgments
Chapter 1: Sarbanes-Oxley Myth
Legislating Evil Out of Our Corporations
Employees, Fraud, and Lessons Forgotten
Why You Should Not Rely on Auditors
You Can’t Trust the Lawyers Either
Supporting the Fraud Culture
What Really Works
Chapter 2: The Control Smart Framework
Smart Basics
Case Study: Andy Fastow’s Shell Game
Chapter 3: Threats and Dangers
How to Recognize a Pending Nightmare
I See It. Should I Worry?
Whose Job Is It Anyway?
Chapter 4: Know Yourself
Do You Have Decision Rights?
Key Activities Model
Tell Your Story
Chapter 5: Identify Where You Are Vulnerable
What Are Controls?
Pull Levers—Often
Activities That Improve Your Business
Chapter 6: Smart Links
1: Establish Behavioral Boundaries
Step 2: Choose Your Customers
Step 3: Did You Get What You Paid For?
Case Study: Greed’s Siren Song: Dennis Kozlowski
Step 4: Who’s Reading Your E-mail?
Step 5: What’s It Really Worth?
Step 6: Growth Busters!
Step 7: Has Your Ship Sailed?
Step 8: Keep Everyone Happy
Step 9: Cash Is the Same as Money
Step 10: Where Did It Go? How Do You Know?
Step 11: Take Your Temperature Often
12: Speaking Out Loud to a Crowd
Case Study: The Cynthia Cooper Story
Step 13: Knowing the Best and Brightest
Chapter 7: Protect Yourself
Find Those Gaps: The Dentex Case
Applying Smart Links
Interrupting an Embezzlement
Finishing the Job
Applying Smart Links to Financial Reporting Processes
Chapter 8: Monitor Your Health
What Is Driving Your Business?
We Know We Are Better!
Are We There Yet?
What Happens Next?
Chapter 9: A Call to Action
Epilogue
Appendix A: Statement of Values
Appendix B: Key Performance Indicator Reporting
Appendix C: Examples of Key Performance Indicators
Appendix D: Control Activities
Appendix E: Example of Section 302 Certification
Appendix F: Attestation Checklist
Bibliography
Index
