Item 4. Controls and Procedures
Item 4. Controls and Procedures
Evaluation of Disclosure Controls and Procedures
As required by Rule 13a-15(b) of the Securities
Exchange Act of 1934, as amended, or the Exchange Act, under the direction of the Chief Executive Officer and the Chief Financial
Officer, we have evaluated our disclosure controls and procedures (as defined in Rule 13a-15(e) or 15d-15(e)) as of the end of the period
covered by this Quarterly Report on Form 10-Q. Based on this evaluation, our Chief Executive Officer and our Chief Financial Officer have
concluded that our disclosure controls and procedures were not effective as of the end of the period covered by this report due to the
material weakness in our internal controls over financial reporting related to our verification process concerning wire transfer
payments to vendors as discussed further below. Notwithstanding this material weakness, our management has concluded that the financial
statements included elsewhere in this Quarterly Report present fairly, in all material respects, our financial position, results of operations
and cash flows in conformity with generally accepted accounting principles.
32
NeuroOne Medical Technologies
Corporation
Form 10-Q
In January 2023, we became aware that we had been
a victim of a criminal fraud that law enforcement authorities refer to as business email compromise fraud, which involved impersonation
of our vendor and fraudulent demands for wire transfers that targeted our finance department. The fraud resulted in a loss of approximately
$0.1 million. The Company’s investigation into this matter continues as further discussed in Item 1A.
Remediation
During the second fiscal quarter of 2023, enhancements
were made to our controls relating to electronic payments, including by wire transfer of funds. These enhancements include additional
verification and documentation procedures to be followed prior to the initiation or approval of electronic payments by or for us. We believe
these enhancements increase the ability of our personnel to identify and block attempts by third parties to fraudulently initiate electronic
payments from us. Our management believes that the foregoing actions will help improve our internal controls over financial reporting.
We are actively working to implement effective internal control over financial reporting, which includes remediation of the material weakness.
However, such compliance is not guaranteed, and we cannot provide any assurance that our internal control over financial reporting will
be effective as a result of these efforts.
Changes in Internal Control over Financial
Reporting
Other than the identification of the material
weakness described above, there has not been any change in our internal control over financial reporting (as such term is defined in Rule 13a-15(f) and 15d-15(f) under
the Exchange Act) during the period covered by this Quarterly Report on Form 10-Q that has materially affected, or is reasonably
likely to materially affect our internal control over financial reporting.
33
NeuroOne Medical Technologies
Corporation
Form 10-Q
PART II – OTHER INFORMATION
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.