In the United States, public companies large and small have labored over the requirements of section 404 of the Sarbanes-Oxley Act. Accelerated filers with international operations are now finalizing their assessment of internal control over financial reporting. Foreign Private Issuers (FPIs), beginning with year-ends on or after July 15, 2006, are required to include an internal control report from management in their annual report. Although the Securites and Exchange Commission has delayed the effective date of section 404, we highly recommend that FPIs do not change the timing or scope of their section 404 work.

Sarbanes-Oxley Section 404: Compliance Challenges for Foreign Private Issuers summarizes the experiences of FPIs and highlights key challenges that your company may face as part of your section 404 readiness activities.

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