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Ensuring SOX 404 Compliance for a Bitcoin Mining Company

Ensuring SOX 404 Compliance for a Bitcoin Mining Company

We worked with a bitcoin mining company and AI infrastructure provider to establish a reliable and repeatable annual process to enable SOX 404 compliance and support annual regulatory filings.​

Challenge

A large-scale publicly listed bitcoin miner and AI infrastructure provider needed assistance establishing a Sarbanes-Oxley 404 control environment to support annual 20-F filings. They engaged SolomonEdwards to provide the guidance necessary to produce the appropriate deliverables and meet the filing deadlines. When the SOX coordinator left unexpectedly in mid-audit, we stepped in to lead the compliance initiative and coordinate resources to create a reliable and repeatable annual process.

Solution

We led the development of process narratives and risk and control matrices, ensuring a comprehensive approach to SOX 404 compliance. As part of our efforts, we prepared detailed flowcharts for high-risk digital asset processes, including revenue, fixed assets and financial reporting. In addition, we reviewed entity-level control testing and conducted thorough testing of key controls for both interim and year-end reporting. To further strengthen the compliance framework, we provided risk assessments addressing fraud, account balances, processes, assertions and the final management report to create a robust and reliable control environment.

Outcome

We were able to assist our client in performing the necessary requirements to issue a timely Form 20-F filing. In addition, we helped management remediate control deficiencies and gaps identified during interim testing to reduce the number of final gaps and deficiencies reported to the audit committee at year-end. The client was pleased with our critical SOX compliance support, and we continue to work with the company on compliance-related initiatives as the company grows.

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