Insight

COVID-19: The impact on SOX 404 Programs

Highlights and modifications to consider as you plan and execute your SOX program amidst COVID-19

Sue King

Sue King

Partner, Advisory, KPMG US

+1 213-955-8399

Susan Burkom

Susan Burkom

Managing Director, Internal Audit & Risk, KPMG US

+1 410-949-8771

Joe Manusakis

Joe Manusakis

Partner, Risk Advisory Solutions, KPMG US

+1 404-222-3675

Over the past few weeks, we have seen an unprecedented level of disruption to our normal lives and day-to-day processes as result of COVID-19 (commonly referred to as the coronavirus). With remote work, workforce disruptions, and a diverted focus to customer and employee safety, commercial viability, and the possibility of a global recession–there are numerous opportunities for internal controls to be shortcut or circumvented.

As organizations revisit their priorities, compliance with Sarbanes-Oxley 404  (SOX) and an appropriate internal control environment are not areas that can be deferred or ignored. While the situation continues to be extremely fluid, and there are many unanswered questions, there are a number of items to consider related to your SOX program. We believe that being proactive is critical to your organization’s control environment and that early action will minimize possible future cost and control implications.