Giving evidence to the Commons Justice Select Committee, Mr Graham said that a process of regularaudit was a "darn sight more helpful" than public bodies continuing to be fined for mistakes and the money effectively being returned to the Treasury.
If the taxpayer wished to try to persuade the IRS that there were mitigating factors to reduce or eliminate the amnesty penalties, the taxpayer would have had to "exit" the program and make those arguments in the course of a regular tax audit.
Our board and audit committee gets regular updates on our security posture, the cyber threats we face, and the investments that are needed to ensure that we stay in business.
An independent, certified audit is conducted annually in addition to periodic, regular audits by NFA and information requests from the CFTC and exchange representatives.