The Bulletin: Volume 2, Issue 3

From a compliance standpoint, “sustainability” refers to the continuing effectiveness of two interrelated management imperatives: repeatability and effectiveness of the internal control structure; cost-effectiveness of the organization’s capabilities to comply with Sarbanes-Oxley Act of 2002 (SOX) Sections 302 and 404. Once a company achieves sustainability for these compliance initiatives, there must be a mechanism in place to evaluate the effectiveness of the internal control structure.

Management should think of compliance with SOX Sections 302 and 404 as a single requirement of continuous reporting. This issue highlights strategies for integrating compliance activities around Sections 302 and 404 of SOX with the objective of achieving sustainability of the internal control structure.