Which of the following would be considered a first line of defense in the Three Lines of Defense model?
a. An accounts payable supervisor conducting a weekly review to ensure all payments were issued by the required payment date.
b. A divisional compliance and ethics officer conducting a review of employee training records to ensure that all marketing and sales staff have completed the required FCPA training.
c. The external audit team observes the counting of inventory on December 31.
d. An internal audit team conducting an engagement to provide assurance on the company’s Sarbanes-Oxley compliance with internal controls over financial reporting.