Internal controls over financial reporting

Internal controls over financial reporting in the Trade and Geopolitical Risk sector now sit at the intersection of sanctions enforcement, export control disclosure obligations, and cross-border transaction transparency requirements. The U.S. Securities and Exchange Commission has pressed firms on whether geopolitical exposure and trade restriction impacts are adequately reflected in ICFR assessments, particularly following its 2023 guidance on material risk disclosure. The U.S. Department of the Treasury's Office of Foreign Assets Control and the Bureau of Industry and Security at the U.S. Department of Commerce both generate control-relevant actions that feed directly into a firm's financial reporting obligations when restricted-party exposure or export licensing failures surface.