OPINION
One of my most mortifying moments as a compliance commentator happened one day in July 2018. I was speaking at an ethics and compliance event in Houston, and another speaker stumped everyone — me included — with a deceptively simple question: What is a control? A êļÕݲĆĆʞËĔČĭĆõ²čËÕĔêţËÕİĴļ²Ćă²ÊĔŁļËĔčļİĔĆĴ ËĔčĴļ²čļĆŘʣ&êêÕËļõŕÕËĔčļİĔĆĴ²İÕļñÕĆõêÕÊĆĔĔÑ of what makes a compliance program work. Most of us can rattle off examples of controls, or recognize a control when we see one. Then my fellow speaker had to get all philosophical on ŁĴʝ¥ñ²ļ is a control? Nobody dared answer. We all were suddenly uncertain ļñ²ļŖÕËĔŁĆÑÑÕţčÕ²ËĔčļİĔĆËĔİİÕËļĆŘʣ The speaker who posed this question, Jonathan Marks , õĴ²ĭİĔĆõţËļñõčăÕİĔč²ĆĆļñõčëĴêĔİÕčĴõËĴʞ²ŁÑõļ²čÑ internal control. Marks has a shtick of asking audit and ËĔČĭĆõ²čËÕ²ŁÑõÕčËÕĴļĔÑÕţčÕ²ËĔčļİĔĆʲ²čÑļĔñõĴ
ĔčļİĔĆʝ Noun or
Verb? Getting philosophical on internal controls
Matt Kelly Guest Editor
Opinion | Internal controls
corporatecomplianceinsights.com | 9
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