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Operational risks for example, a lack of documented processes, or failure to act quickly because of strong, centralized administrative controls Technological risks for example, failure to upgrade and modernize systems, or systems privacy or security penetration violations Quantify the magnitude and potential impact of each risk Create a risk portfolio to identify the interrelationships among the various risks Develop the enterprise risk management (ERM) framework 3 Set reporting objectives The overall objective is to create a system that ensures internal control compliance What Determine likelihood of risks and errors Define decision rules and reporting objectives to address risks How do we ensure that the internal control system is effective The controls must be Preventive (stop) Detective (catch) Corrective (fix) What areas of the operation require control objectives Assess and set objectives for internal control in the following areas: A Personnel Controls Separation of duties Careful hiring, assignment of duties, training, and supervision Performance reviews B System and Resource Controls Physical controls access to hardware components of system Logistics controls access and authorization to use system System controls document order, internal validity, checks and balances C Strategic Planning Controls Establishing steering committees Identifying opportunities provided by enterprise ERP systems
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Evaluating and balancing the level of skills and outside resources required to complete IT projects satisfactorily Evaluating automated systems for internal control D Business/Transactions Service Controls Policies and procedures Document validation and matching Transaction detail calculation Account summary comparison Periodic ledger reconciliations Help and incident reporting and support Management reports 4 Prepare a formal implementation plan (transition plan to move from project stage to ongoing, day-to-day internal control operations) What steps are involved in transitioning from the project stage to the ongoing, day-to-day operations for an internal control system Define the key controls and tasks and their start and end dates Allocate ownership of each control task to a specific employee Provide a mechanism for access to appropriate information and resources for each control task Establish various chains and lines of command Establish a direct and systematic reporting process through those lines of command Define individual roles and responsibilities within the organization Communicate individual roles and responsibilities to ensure organization-wide understanding and respect What factors affect the proper execution of internal control methods Employee execution of the internal controls depends on information being: Identified: Proper form Captured: A reasonable time frame Exchanged Accountability for each control activity depends on the methods used to
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Record: Transactions Process: Events Summarize Conditions Report 5 Communicate the ongoing procedures It is imperative that messages regarding Sarbanes-Oxley compliance emphasize the why associated with the changes New procedures must be presented clearly and effectively Focus on: Understanding Collaboration Acceptance Set a cultural tone Observance 6 Provide training Compliance committee will lead this process and will provide the resources employees need to function successfully in the new environment Training may consist of both internal and external components, depending on what type of system is put in place Focus on internal policies, procedures, and practices to ensure that each is being performed correctly, including: Classifying and recording authorized transactions in the proper period Making operational and financial disclosures Protecting company assets from improper, unauthorized use Potential changes: Job roles and responsibilities of some employees will change The human resources department should take appropriate measures (eg, compensation review) to eliminate any potential staff dissatisfaction 7 Document processes and risk management The CEO and CFO will have to certify that the internal control systems of the corporation are sufficient and that they have been monitored within 90 days of the report being filed A company must maintain evidential matter, including documentation, to prove that the internal control system is effective
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