THE WEEKLY BRIEF: Thursday, Oct. 15, 2026

25 Years After Sarbanes-Oxley, How Is Fraud This Simple Still Possible?

And how did it go undetected for so long?

The alleged frauds that took down First Brands and Tricolor were almost mundane — misstated assets, double-pledged collateral, inflated invoices — yet the schemes went undetected for years. Anne Eberhardt, an accountant and certified fraud examiner at Gavin/Solmonese, explains how fraud this unsophisticated still succeeds after nearly a quarter-century of the reforms SOX brought to the US economy.

LEGAL, RISK & REGULATION

Treat the release note as a third-party risk event. Tech exec Robin Horstmann warns us that a vendor can switch on AI decision-making through a routine software update that sets off none of the usual diligence gates: no purchase, no contract event, nothing for a reviewer to flag. 

COMPLIANCE

Earned wage access is among the fastest-growing employee benefits and among the most unevenly regulated.  Federal guidance has flipped three times in five years and a dozen states have written their own rules on letting employees draw compensation they’ve already earned before payday. CCI contributing writer Erin Binney digs into the risk for employers. 

GOVERNANCE

What Happens When Governance Handovers Lose Their Escalation History? A control concern can spend nine months under scrutiny, with repeated challenges, broken promises and missed deadlines, only to reach a successor as a single line marked “open.” Glenn Oborne of Ingen Partners explains how critical escalation history gets lost during senior governance handovers — and how a simple live concerns register can keep important issues from losing the scrutiny they're already received.

SPONSORED

The Definitive Guide Part 2:

Choosing Your Due Diligence Partner

Just launched: Part 2 of The Definitive Guide to Future-Ready Third-Party Due Diligence, a three-part series for risk and compliance teams who want to modernize third-party risk management while keeping speed, accuracy, rigor and control.

• How to define requirements and map decisions that carry legal effect
• Seven vendor evaluation criteria, each with a regulator test
• How to run a pilot using placebo checks
• How to build a business case your board will recognize

Plus a one-page checklist covering every step from requirements to signature.

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