We are back with another series of Adventures in Compliance podcasts. This week I am exploring stories from The Casebook of Sherlock Holmes. In this week’s second offering, I consider The Problem of Thor Bridge. From this story we take the Holmes utterance “We must look for consistency. Where there is want of it, we must suspect deception”. This informs our discussion on monitoring controls in a best practices compliance program.

In this story, Neil Gibson, the Gold King approaches Holmes to investigate the murder of his wife Maria in order to clear his children’s governess, Grace Dunbar, of the crime. Maria Gibson was found lying in a pool of blood on Thor Bridge with a bullet through the head and note from the governess, agreeing to a meeting at that location, in her hand. A recently discharged revolver with one shot fired is found in Miss Dunbar’s wardrobe. Holmes agrees to look at the situation in spite of the damning evidence.

From the outset, Holmes observes some rather odd things about the case. How could Miss Dunbar so coolly and rationally have planned and carried out the murder and then carelessly tossed the murder weapon into her wardrobe? What was the strange chip on the underside of the bridge’s stone balustrade? Why was Mrs. Gibson clutching the note from Miss Dunbar when she died? If the murder weapon was one of a matched pair of pistols, why couldn’t the other one be found in Mr. Gibson’s collection?

Holmes uses his powers of deduction to solve the crime, and demonstrates, using Watson’s revolver, how it was perpetrated: Mrs. Gibson, outraged and jealous of Miss Dunbar’s relationship with her husband, resolved to end her own life and frame her rival for the crime. After arranging a meeting with Miss Dunbar, requesting her to leave her response in a note, Mrs. Gibson tied a rock on a piece of string to the end of a revolver, and shot herself, the rock pulling the revolver over the side of the bridge; the revolver found in Miss Dunbar’s wardrobe was the other pistol of the pair, which had been fired off in the woods earlier, and the chip in the bridge was caused by the pistol hitting the stonework as it was pulled off by the rock. Holmes’s reconstruction reproduces the damage to the balustrade of the bridge. He asks the police to drag the lake for the revolvers of Watson and Gibson.

Compliance Takeaways

  1. How do you determine that want of consistency? Monitoring controls is one key.
  2. Consider the fifth and final Objective from the COSO 2013 Internal Control Framework is Monitoring Activitiesas a guide.
  3. Further consider Principles 16 & 17 of the COSO Framework.
  4. Monitoring Activities should bring together your entire compliance program and give you a sense of whether it is running properly.
  5. Both ongoing monitoring and auditing are tools the CCO and compliance practitioner should use in support of this objective.
  6. The most important item to note is that all the controls need to be sustainable.

Join us tomorrow as we consider The Adventure of the Creeping Man.

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