Section 404 of SOX places stringent requirements on the internal controls used for financial reporting. UK companies with a US listing must be compliant for financial year-ends as of July 2005. In the US, the cost of s404 compliance has soared well beyond expectations. Although the average cost per company was estimated at US$1.93m in January, it is now US$3.14m. There is no escape for treasurers of UK companies with a US listing. They must play a key role in ensuring the effectiveness of internal controls, and be prepared to take the blame should things go wrong. To ensure compliance, treasurers must start early, focus on key controls and collate adequate evidence over a sufficient period of time. Testing of internal controls is one of the biggest hurdles, accounting for about 40% of a s404 project – and it is not going to go away in the future either. An independent audit of controls must also be conducted annually. New IT systems that provide s404 compliance may be the answer to treasurers’ prayers. Although the technology is still in its infancy, solutions that allow greater transparency of processes are being developed.