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| Preface | |
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| Acknowledgments | |
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| The Basics | |
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| Sarbanes-Oxley: How It Applies to Accounts Payable | |
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| Background | |
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| Overview of the Act | |
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| Effective Dates of the Act | |
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| Whistleblower Protections | |
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| Auditor Independence: The Problem | |
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| Auditor Independence: The New Requirements | |
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| Timely Disclosure | |
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| How Material Events Are Reported | |
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| Management Assessment of Internal Controls | |
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| Auditors' Assessment of Internal Controls | |
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| Corporate Responsibility | |
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| Subcertifications | |
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| Using the Act to Foster Change | |
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| Directors Insurance | |
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| Concluding Thoughts | |
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| Compliance Alternatives: Outsourcing and the COSO Framework | |
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| Outsourcing | |
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| Sarbanes-Oxley Requirements if Using an Outsourcer | |
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| Mechanism for Demonstrating Appropriate Controls | |
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| COSO Framework: Background | |
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| COSO Objectives: Enterprise Risk | |
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| Enterprise Risk Management | |
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| Concluding Thoughts | |
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| Invoice Processing | |
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| Purchase Orders | |
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| Purchase Order Problems | |
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| Documentation | |
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| Flowcharts | |
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| Invoice Handling: Clear Instructions | |
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| Approval Process | |
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| Three-Way Match | |
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| Small-Dollar Invoices | |
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| Contract Compliance | |
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| Fraud | |
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| Segregation of Duties | |
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| Master Vendor File | |
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| Electronic Invoicing | |
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| Month-End Close | |
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| Year-End Close | |
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| Recommended Invoice-Processing Practices | |
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| Concluding Thoughts | |
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| Payment Process | |
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| Checks | |
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| Authorized Signers and Board Delegations | |
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| Check Signers | |
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| Documentation: Check Signers and Accounts | |
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| Check Stock | |
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| Check-Signing Procedures | |
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| Facsimile Signer | |
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| Rush Checks | |
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| Mailing Checks | |
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| Outsourcing Check Printing | |
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| Check Request Forms | |
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| Positive Pay | |
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| Reconcile Bank Statements | |
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| Recurring Payments | |
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| Concluding Thoughts | |
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| Purchasing Cards | |
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| P-Card Growth | |
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| Typical Usage | |
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| The Survey: How Has Sarbanes-Oxley Affected Your P-Card Operations? | |
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| Why Comply if You Don't Have to? | |
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| Implementation Resources | |
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| Who's Doing the Work? | |
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| Sarbanes-Oxley Impact on P-Card Programs | |
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| Sarbanes-Oxley Factor in Change | |
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| Has Sarbanes-Oxley Forced Change? | |
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| Additional Control Features | |
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| What's Being Certified? | |
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| Ramifications of Not Signing | |
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| Concluding Thoughts | |
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| Electronic Payments: Alternatives to the Paper Check | |
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| Wire Transfers | |
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| Automated Clearinghouse (ACH) | |
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| SAS 70 | |
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| Daily Reconciliations | |
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| Concluding Thoughts | |
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| Functions Related to and Often Handled in Accounts Payable | |
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| Travel and Entertainment Expense Processing | |
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| Bad Practices | |
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| Written Policies | |
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| Policy Enforcement | |
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| Spot-Checking | |
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| Exceptions to Spot-Checking | |
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| Who Submits When Multiple Employees Are Involved? | |
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| Electronic Reimbursement | |
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| T&E Cards | |
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| SAS 70 | |
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| Excel Reports | |
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| One-Card Programs | |
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| Concluding Thoughts | |
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| Unclaimed Property (Escheat) | |
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| State of Compliance | |
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| Effect of Sarbanes-Oxley on Private Company Reporting | |
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| Key Escheat Issues | |
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| Compliance | |
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| What's Required to Do Escheat Correctly? | |
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| Common Noncompliance Areas | |
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| Subcertifications | |
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| Segregation of Duties | |
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| Concluding Thoughts | |
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| 1099s and Other IRS-Related Information Reporting | |
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| Determining Status | |
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| Obtaining a W-9 | |
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| 1099s and Year-End Reporting | |
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| TIN Matching | |
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| B Notices | |
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| Nonresident Aliens | |
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| W-8 | |
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| OFAC and FTO Reporting | |
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| P-Card and QPCA Reporting | |
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| Additional Reading | |
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| Sales and Use Tax | |
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| Problems with Proper Tax Compliance | |
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| Really Bad Practice | |
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| Documented Procedures | |
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| Audit Trails | |
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| Software or Forms | |
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| Streamlined Sales Tax Project: Not a Solution | |
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| Overall Guidelines to Conform | |
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| Fraud Prevention Controls | |
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| Report to the Nation: 2004 | |
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| Fraudulent Disbursements | |
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| Uncovering Fraud | |
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| Who Commits These Crimes? | |
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| Recovery | |
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| Employee Fraud | |
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| Vendor Fraud | |
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| W-9 | |
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| Small-Dollar Invoice Fraud | |
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| Check Fraud | |
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| Demand Draft Fraud | |
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| Concluding Thoughts | |
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| Documentation Needed to Conform to the Act | |
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| Board Authorizations | |
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| Flowchart | |
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| Audit Trails | |
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| Records Retention | |
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| Records Retention in Merged Entities | |
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| Policy and Procedures Manual | |
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| A Written T&E Policy | |
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| Other Information that Should Be Shared with All Employees | |
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| Concluding Thoughts | |
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| Overall Guidelines for Conforming to the Act | |
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| Segregation of Duties | |
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| Employ Reasonable Hiring and Background-Checking Processes | |
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| Establish Internal Controls throughout the Accounts Payable Process | |
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| Eliminate Really Bad Accounts Payable Practices | |
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| Paper Trails | |
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| Monitoring Reports | |
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| Automated Monitoring for Compliance | |
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| Training | |
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| Concluding Thoughts | |
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| Appendices | |
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| Sarbanes-Oxley Act of 2002 | |
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| Segregation of Duties | |
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| Blank Check Stock Security Features | |
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| Demographics of the Purchase Card and Sarbanes-Oxley Survey | |
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| Independent Contractor or Employee 20 Questions | |
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| About Accounts Payable Now & Tomorrow | |
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| Index | |