When choosing transactions to test as part of anti-bribery assessments, the usual suspects include expense accounts like consulting, marketing, promotions, commissions, or miscellaneous. Other expense accounts are selected based on the nature of the company’s business, risk factors or descriptions of the account.
But don’t overlook the balance sheet. While it is true that corrupt payments may eventually flow through the income statement, the accounting for related activities sometimes starts on the balance sheet; and it can take years before the corrupt payment ends up in an income statement account.
‘Enforcement 40’ for 2020
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