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SOX and J-SOX Primer PDF Print E-mail
Sunday, 15 April 2007
On March 22nd, Michael Dell the founder and CEO of Dell, Inc. at a Customer Reception in Tokyo, Japan remarked on the planned implementation of the so-called J-SOX laws in April of next year. He stated that "it's increasingly important for Japanese companies to review their database management and information security procedures to structure and comply with enhanced legal requirements for internal controls."  In order to provide support, Dell has put in place a specialized team for Japanese customers to ensure that we can provide the right solution and the best experience to its customers.  Like with SOX in the US, IT and accounting companies are seizing on the new rules as new revenue streams.  Oracle Japan is offering software and consulting services to small and medium-sized companies for helping them comply.  IDC Japan is estimating that the J-SOX compliance market will reach 260.7 billion yen (over $2B) in 2008 with most of than money flowing into IT upgrades.  According to Forrester Research Services firms already focused on J-SOX include:
  • Deloitte (Tohmatsu)
  • Ernst & Young (Shin Nihon)
  • KPMG (Azusa)
  • Misuzu
  • PricewaterhouseCoopers (Arata)
  • Protiviti
Also according to Forrester Research Software firms focused on
J-SOX include:
  • Achiever Business Solutions
  • BWise
  • OpenPages
  • Oracle/Stellent
  • Paisley
  • AP
So why does the CM community care? 
Like SOX, J-SOX will need the rigors, processes and management of software configuration tools, software and the people to support and implement these solutions.

So I understand Sox, but what is J-Sox. 
Commodore Matthew Calbraith Perry opened a largely closed Japanese society to the Western world on July 8, 1853, when he arrived in Edo (Tokyo) bay [1].  Commodore Perry and the Treaty of Kangawa signed in 1854 allowed US vessels access to Japan's port and is widely credited with the triggering the modernization of Japan. More than 150 plus years later "J-SOX" the nickname of Japan's Financial Instruments and Exchange Law, which was promulgated on June 14th, 2006, is becoming a common term in corporate governance. Inspired by corporate scandals such as the Livedoor[2] and Murakami Fund[3] , the law has been dubbed "the Japanese version of the Sarbanes-Oxley Act," hence J-SOX.  "This is just like the early stages of Sarbanes-Oxley - nobody really knows" the specific requirements yet, said Michael Pellegrino, vice president of IT at Fuji Photo Film U.S.A. Inc., a Valhalla, N.Y.-based subsidiary of Tokyo-based Fujifilm Corp[4]

As Friedman said the world is getting flat.  Businesses' are learning from the mistakes made by individuals and corporations across the globe.  J-SOX, officially known as the Financial Instruments and Exchange Law, is scheduled to go into effect in April 2008 for roughly 3,800 companies listed in Japan, along with their foreign subsidiaries[5]

Challenges and difference J-Sox and Sox. 
Forrester Research lists the following challenges and difference between J-SOX and SOX:
  • Professional services. Japan has fewer than 10% of the number of qualified accountants than the US.
  • Independence of auditors. While the concept of auditor independence exists in the Japanese market similar to the US, many Japanese firms can and will rely on the influence and recommendations of their audit firms.
  • Audit automation is critical. With the extreme shortage of auditors compared to US per capita numbers, this shortage will increase the requirement and necessity for process efficiency in the internal audit process and software that can support these processes.
  • Support of IT governance. In the November guidance regarding the scope of the J-SOX process, it is clear that IT controls are a central point of focus for J-SOX        

David Lipien is a Senior Managing Consultant with IBM's Global Business Services Financial Services Insurance practice. He has over 10 years of IT Systems Development and Leadership experience. He has expertise in all phases of the project life cycle and experience in numerous roles, including project manager, senior business analyst, and programmer. Specialties include internet-based technologies, wireless and object-based project methodologies.


[1] Friedman, Thomas L. The World if Flat, New York NY, 2007 page 139.

[2] An Internet service provider based in Tokyo, Japan, that runs a Web portal and numerous other businesses. The media reported allegations of securities fraud (including window dressing and share-price manipulation) on January 17, 2006, prompting panic selling on the Tokyo Stock Exchange as investors tried to unload share.

[3] Outspoken investment fund manager Yoshiaki Murakami arrested for alleged insider trading linked to his investment fund's purchase of Nippon Broadcasting System Inc. shares between late 2004 and early 2005.

[4] ComputerWorld Thomas Hoffman March 17, 2007

[5] http://www.fsa.go.jp/en/index.html, Financial Services Agency, The Japanese Government

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