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What does this mean The controls must be documented diligently All systems require detailed descriptions and analysis clear enough that any audit of that system can be conducted easily and efficiently Risks must be documented: To provide reasons and a resource for why the controls were put in place To assist in the identification of new or changing sources of risk 8 Perform continuous evaluation Continuous evaluation and modification of internal controls are musts Who It is management s responsibility to establish and maintain controls, and to ensure that they operate as intended or are modified as appropriate Maintenance and monitoring of the internal controls depend on Detection of deviation Timeliness of response What is the process for detection of noncompliance Initially, a reactive process can work for early detection, analysis, and resolution of problems With experience, the process should be formalized Action against violations of the internal controls should be swift and just Actions can include disciplinary and corrective actions to help reinforce established codes of practice
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1 Assemble project team, including sponsor and other review team members Review team members should include representatives from Finance Internal Audit
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IT Legal Human Resources 2 Define project objectives and assess where the organization is with regard to Sarbanes-Oxley compliance Determine the scope of the review Will it cover controls other than financial ones Determine which business units will be covered Review results from any previous Section 404 or internal audit reviews requiring follow-up Establish project time line Be sure to allow time for external auditing and review Develop guidelines for assessing risk management Develop the ERM framework following the COSO guidelines: Develop internal ERM environment Management is responsible for establishing the foundation of attitudes toward the organization s appetite for risk, for all members of the organization, as a set of guidelines Set strategic and risk objectives in support of management s choice as to how the organization will seek to enhance value These should involve some overall riskrelated objectives Develop processes to implement the ERM framework successfully and to identify events that may affect (either positively or negatively) the risk-related strategies Develop plans to respond to the various risk challenges that were identified in the risk assessments Identify various responses to risk options and consider their effect on event likelihood and impact, in relation to the organization s response for risk (This is a management task) Undertake control activities, as defined in the policies and procedures to ensure that appropriate risk responses are executed, throughout all levels and functions within the organization, including approvals, authorizations, performance reviews, safety and security issues, and appropriate segregation of duties
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Develop an information and communication plan that identifies, captures, and communicates risk-related information in a form that allows appropriate members of the organization to carry out their responsibilities, as well as flowing throughout the organization at all levels and to external parties such as customers, vendors, regulators, and shareholders Develop ongoing risk monitoring procedures to monitor the ERM program and the quality of its performance over time Review planned objectives with the CFO and the audit committee 3 Create a project plan that covers in detail the internal processes that are to be reviewed
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1 Establish a review approach for each process/system included in the review Identify financial reporting processes Identify key systems and supporting systems Review existing documentation Define nature and types of possible errors and omissions Define nature, size, and composition of transactions to be reviewed Determine volume, size, complexity, and homogeneity of individual transactions processed Establish guidelines for materiality and error significance Understand process transaction susceptibility to error or omission 2 Review approach and timing with external auditors
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