Compliance and Ethics Program - Committee of Sponsoring Organizations

Committee of Sponsoring Organizations

In response to the FCPA and its requirement to implement internal control programs, in 1985 a private-sector initiative was formed called the National Committee on Fraudulent Financial Reporting (commonly known as the Treadway Commission). This Commission recommended that its organizational sponsors work together to develop guidance on internal controls. Subsequently, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) was formed, and in conjunction with the CPA firm Coopers & Lybrand, COSO authored and published in 1992 the “Internal Control-Integrated Framework" (http://www.coso.org/publications/executive_summary_integrated_framework.htm). This framework has become the de facto standard in the accounting industry for auditing, evaluating and monitoring internal control systems.

The COSO Internal Control-Integrated Framework is now widely used by most organizations as the basis for “establishing and maintaining an adequate internal control structure and procedures for financial reporting” ( 15 USC § 7262) and for the assessment of control effectiveness under section 404 of Sarbanes-Oxley. (http://www.pcaobus.org/About_the_PCAOB/Sarbanes_Oxley_Act_of_2002.pdf)