This case study analyzed the internal controls of a real estate company using the widely accepted COSO framework. Testing of the internal environment and controls was completed using the COSO framework. The major internal control problem identified in the study was a lack of ethical standards in the control environment. In addition to this main problem, inadequate documentation, no separation of duties, and unqualified employees were also identified as violations of effective internal controls. The department of real estate ordered a "cease and desist" on August 8, 2013 due to illegal company activities. The company participated in illegal actions regarding: the trust account and company documentation and procedures. Material weaknesses were found in the company's internal controls; therefore the result of this study was an adverse opinion on internal controls.