Question on SOX and Overseas Invoices 2040

  • I need some help from the SOX experts please. I work for a small privately help company (trying to follow the SOX requirements) and a question came up regarding the generation of invoices for overseas shipments.
    Does SOX stipulate when an invoice should be generated? For instance, when it leaves our warehouse? When it reaches the port? When it arrives overseas? When it reaches the customer?

  • Sox has no specific requirements on any accounting controls.
    An invoice should be raised based on the terms of the sale when the rights to the goods being sold transfer to the customer. Sometimes that is when the item is shipped, sometimes, it is when the item is delivered.

  • Hi and welcome to the forums 🙂 … Adding to kymikes good advice, I’d recommend the following:

    • Establish standards for the process (so it’s as consistant as possible, recognizing that cargo shipments might have differing bill of laden requirements as kymike described)
    • Ensure that revenue recognition is consistant with SOX standards (e.g., not counting it too early)
    • Walk through the process with audit for any additional areas of improvement.

  • Harrywaldron is correct.
    what is important for SOX is that the standard terms and conditions that were agreed with your customer are complied with so that cut off can be treated on a consistent basis.
    Another point to add to this is that US GAAP requires that you communicate these terms and conditions for the recognition of a sale to your customer BEFORE you ship and invoice.

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