What APS Questions and Answers feature?

TheTax and Regulatory Compliancetopic in the APS Certification Program includes understanding the Sarbanes-Oxley Act (SOX), enacted in 2002 to enhance corporate governance and financial reporting accuracy. SOX imposes strict requirements on public companies and holds individuals (e.g., executives, accountants) accountable for misconduct, such as falsifying financial records or obstructing audits. Violations can result incriminal penalties, including fines and imprisonment, depending on the severity of the misconduct.

Option A (Corporate dissolution): While SOX violations can lead to significant financial and reputational damage, corporate dissolution (complete closure of the company) is not a direct legal consequence specified in the Act. This option is incorrect.

Option B (Criminal penalties): SOX includes provisions for criminal penalties, such as fines up to $5 million and imprisonment up to 20 years for willful violations (e.g., falsifying records under Section 802). This is the correct answer.

Option C (Industry blacklisting): There is no formal “industry blacklisting” mechanism in SOX. While individuals may face reputational damage or debarment from certain roles, this is not a legal consequence. This option is incorrect.

Option D (Community service): SOX does not prescribe community service as a penalty for misconduct. Penalties are financial or custodial (fines, imprisonment). This option is incorrect.

Reference to IOFM APS Documents: The APS e-textbook underTax and Regulatory Complianceexplains that “the Sarbanes-Oxley Act imposes criminal penalties, including fines and imprisonment, for misconduct such as falsifying financial records or obstructing audits.” Thetraining video discusses SOX’s impact on AP, noting that internal controls must prevent fraudulent reporting to avoid penalties under sections like 906 (certification of financial reports) and 802 (document tampering).

TheInternal Controlstopic in the APS Certification Program explains that detective controls are designed to identify errors, fraud, or control failures after they occur. They include activities like reviewing transactions for irregularities and assessing the effectiveness of preventive controls.Segregation of duties, however, is a preventive control, not a detective one, as it prevents fraud by dividing responsibilities.

Item I (Establish segregation of duties): Segregation of duties prevents fraud by ensuring no single employee controls all aspects of a transaction (e.g., invoice approval and payment). This is a preventive control, not detective.

Item II (Look for errors and irregularities): Detective controls, such as account reconciliation or audits, identify errors or fraudulent activities after they occur. This is a valid function.

Item III (Determine if preventive controls are effective): Detective controls, like monitoring or control testing, assess whether preventive controls (e.g., vendor validation) are working. This is a valid function.

Option A (I, II, and III): Incorrect, as Item I is a preventive control.

Option B (I and III only): Incorrect, as Item I is not a detective control function.

Option C (II and III only): Correct, as Items II and III describe detective control functions.

Option D (I and II only): Incorrect, as Item I is not a detective control function.

Reference to IOFM APS Documents: The APS e-textbook underInternal Controlsstates, “Detective controls, such as audits and reconciliations, look for errors and irregularities and evaluate the effectiveness of preventive controls.” It clarifies that “segregation of duties is a preventive control to avoid conflicts of interest.” The training video discusses detective controls as tools for “post-transaction review and control assessment,” excluding segregation of duties.

The tolerance level for discrepancies between a purchase order (PO) and an invoice refers to the acceptable variance (e.g., in price or quantity) that an organization allows before requiring additional approval or investigation. Keeping this tolerance level confidential is critical to prevent vendor fraud, as vendors could exploit knowledge of the tolerance to submit invoices with intentional discrepancies just within the acceptable range, leading to overpayments or unauthorized charges.

The web source from NetSuite highlights the importance of internal controls in invoice matching: “Three-way matching is an AP process used to verify a supplier invoice by checking it against its corresponding purchase order and order receipt. It reduces the chances of fraudulent invoices going undetected and, worse, being paid.” While this source does not explicitly address confidentiality of tolerance levels, the emphasis on fraud prevention implies that exposing tolerance thresholds could undermine these controls. If vendors know the tolerance, they might adjust invoices to exploit it, bypassing scrutiny.

Options B, C, and D are incorrect. Keeping procurement alert (Option B) is a general goal but not directly tied to confidentiality of tolerance levels. Avoiding internal audit scrutiny (Option C) is not a legitimate reason, as internal audits ensure compliance. Option D (depositing overages into a fund) is unethical and unrelated to accounts payable processes.

The IOFM APS Certification Program covers “Internal Controls,” which includes measures toprevent fraud and ensure accurate invoice processing. The program’s focus on “peer-tested best practices” and fraud prevention, as noted in the curriculum description, supports the need to keep tolerance levels confidential to safeguard against vendor manipulation.