There will be semi-annual audits to make sure each system is in compliance and remediation plans will be worked out if a department or agency is not in compliance for two consecutive audits.
In addition to formal performance reviews against pre-set performance targets and financial metrics, employees are also assessed against compliance and risk audits in order to ensure that the bonus pool properly reflects this performance.
Mr. van Heerden said the FLA's investigation was more "bottoms up" than Apple's own audits, which are designed to assess compliance with particular codes.
Another approach is to make third parties provide more information about taxpayers to the IRS. That has a way of keeping taxpayers honest and enables the IRS to use computers to monitor the compliance of most Americans, while better targeting its more intrusive human audits.
The other 14 brokers and dealers whose audits were selected did not maintain a Special Reserve Bank Account and reported compliance with the exemptive provisions of Rule 15c3-3.