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A good communication and networking system is important for providing a solid communications infrastructure between the operational and executive management Specifically for Sarbanes-Oxley purposes, this system must supply information in real time about material events Further, the whistleblower requirements of Section 301 mandate an anonymous and secure communication system The internal controls requirement of Section 404 and the financial accuracy requirements of Section 302 also require a secure communication system, because many important commands and controls are implemented through e-mail and messaging systems and important financial information travels through these communication channels
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Enterprise Integration: Data Integrity and Multiple Systems For Sarbanes-Oxley compliance, the sections on reporting significant events, together with those on accurate and timely financial and other data, reveal a critical need to bring all the data together The need for auditable internal controls also requires that all the data be integrated, work across various business processes, and be traceable Sections 302, 404, and 409 thus call for a massive enterprise integration effort Financial accuracy demands a highly integrated enterprise If the information from the trio of core transactional systems (ie, ERP, SCM, CRM) and other supporting functional automation systems is not integrated, the financial data will remain inaccurate, and large amounts of resources will be required to reconcile the differing, though overlapping, data from the various sources Such data remains open to distortion, loss, and corruption Further, it becomes easy to prove the inadequacy of internal controls All the places where data comes out of the transaction systems and is then entered into the financial reporting systems is a point of vulnerability, because of both unintentional human errors and intentional mischief The possibility of providing real-time reports of material events, as required under Section 409, is extremely low with a nonintegrated enterprise
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Fortunately, several integration technologies are available today The CIO will have to choose the appropriate one based on the specific requirements and constraints of the organization The main technologies are:
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Enterprise application integration Web services Middleware Business process integration Data integration4
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It is challenging to choose the right technology from this array In fact, chances are that all these technologies already exist in the organization and that compounds the problem Enterprise application integration (EAI) is a reliable technology; Web services (or, more generally, service-oriented architectures) are the integration tools of the future Hence, a company will probably want to adopt a combination of both these technologies Once all the data from an application is converted into XML, it becomes much easier to make that data accessible and available to other applications These applications can then use the data to generate whatever reports are required for regulatory purposes EAI legacy tools that are available in the organization, combined with service-oriented architecture based on Web services and XMLbased data storage, are recommended for enabling Sarbanes-Oxley compliance and better business practices
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Current Enterprise Technology Ecosystem: What Does It Deliver It is important first to audit the capabilities of the existing or current technology ecosystem The audit has to be done from the perspective of compliance with Sarbanes-Oxley A few CIOs might realize that they are already close to compliance; they just need to gain a clear understanding of what the Sarbanes-Oxley rules require and then configure a few functions in the key technology systems to achieve compliance Most CIOs, however, will need to perform a detailed study from the ecosystem perspective, to evaluate the overall system for compliance If the overall system seems healthy and can cope with compliance (ideally, this would be the case), then the next step is to identify
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SARBANES-OXLEY FOR THE IT PROFESSIONAL
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Do your transactional systems share data between them How many major transactional systems (ERP, SCM, CRM, etc) exist in your organization Are all of these on a single database platform If yes, is it the same version If no, are they integrated with each other Are all of these on the same or similar operating system platform If yes, is it the same version What other minor transactional systems exist in the organization What legacy systems are being used in the organization What reporting systems are being used in the organization What analysis tools exist What business intelligence or knowledge management tools exist Can an unauthorized person or software or IT user or any other entity gain access to the financial information of the company Is there a possibility of data loss Is the organization s IT infrastructure dependent on few important people, or is it more process driven What happens if these people leave their jobs, get sick, or for some reason are not available to the enterprise for an extended period Will the IT function keep working reasonably well with the help of other staff Are documents stored properly Can they be retrieved on demand Can these documents be stored for the long term (at least seven years) Are they safe from fire, floods, earthquakes, terrorist attacks, and other higher or lower forms of risk to their existence How close to real-time is the information delivery at the organization Can material events or operational risks be detected and reported as early as two days from the occurrence Can you certify that your financial reporting is accurate Can you certify that the internal controls are in place to prevent intentional or unintentional distortion of financial data
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