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The goal of this study is to analyze the implementation process of the controls in Sarbanes-Oxley (SOX) Law, Section 404, its implications and organizational reflexes in the companies with American Depositary Receipts (ADRs) issuance. An exploratory research with a qualitative approach was conducted through a study in medium and large size companies in Santa Catarina - Brazil, being two multinational and of national capital. The technique of content analysis as proposed by Bardin (1971) was used for analysis of the interviews with main responsible for the SOX implementation in each company and a representative of one of the largest auditing companies in Brazil. The results highlight the cultural changes deriving from the implementation of an American legislation in Brazil, the adoption of The Committee of Sponsoring Organizations – COSO – methodology in the internal and external validation of the processes, the lack of employees and departments’ adherence to the Law implementation process, and the relevance of the top management in determining the level of importance given to the new procedures in the company. It was concluded that the SOX implementation process had significant reflexes in the organizational culture and the implications resulting from the implementation process, except the different proportionality of the Law implementation in each company

IMPLEMENTATION PROCESS OF SARBANES-OXLEY ACT CONTROLS: A STUDY OF COMPANIES WITH ADRs ISSUANCE IN SANTA CATARINA – BRAZIL