Can a privately-held company benefit from adopting internal controls over financial reporting as required by the Sarbanes-Oxley Act (“SOX”) even though it is not subject to SOX?

Yes. Section 404 of SOX requires the management of a public company to report on the effectiveness of the company’s  internal control procedures over financial reporting in reports filed with the SEC. Examples of internal controls include procedures to ensure that transactions are properly authorized and recorded and that assets are protected from unauthorized use. […]