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Effective ICFR? The Citigroup Example

Audit Analytics | November 19, 2014

This article is cross-posted courtesy of Audit Analytics.

On Aug. 1, 2014 Citigroup Inc [C] received a comment letter from the SEC. One of the comments referred to a $235 million after-tax charge resulting from a fraud discovered at its Banco Nacional de Mexico (Banamex) subsidiary, recorded during the 12/31/2013 year-end close process. Commenting on this charge, the SEC raised concerns that the identification of the fraud might have affected the company’s evaluation of the effectiveness of its internal controls over financial reporting (ICFR), and that the deficiency might not be limited to the Banamex subsidiary:

“Tell us how the identification of this fraud impacted your conclusion on the effectiveness of your disclosure...

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