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Leverage InformationTechnology: Turn Corporate Governance into Business Performance™ Copyright ©. Fulcrum Information Technology, Inc. Application Risks.

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Presentation on theme: "Leverage InformationTechnology: Turn Corporate Governance into Business Performance™ Copyright ©. Fulcrum Information Technology, Inc. Application Risks."— Presentation transcript:

1 Leverage InformationTechnology: Turn Corporate Governance into Business Performance™ Copyright ©. Fulcrum Information Technology, Inc. Application Risks and Controls Management Survey Findings July 15 th, 2008 The surveys were conducted independently by Jeffrey T. Hare, CPA CISA CIA of ERP Seminars, reviewed by the board of Oracle Applications Internal Controls and Security SIG. Fulcrum is a Co-Sponsor of this Survey Disclaimer: The survey results, observations and findings included in this Webinar are not scientific. Our goal is to provide you information on how Oracle customers are dealing with key issues in application risk and controls management

2 Page 2 Application Risks and Controls Management Introduction Application Controls Survey Findings Governance Risk and Compliance Trends IT Controls Framework Application Controls Overview Auditing Challenges Case Studies AGENDA

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4 Page 4 Panel Members Jeff Hare, CPA, CISA, CIA –Jeff 's extensive background includes public accounting, industry, and Oracle applications implementation experience. His sole focus is on the development of internal controls and security best practices for companies running Oracle Applications. Jeff is a Certified Public Accountant (CPA), a Certified Information Systems Auditor (CISA), and a Certified Internal Auditor (CIA). He is the founder of ERP Seminars and the Oracle Users Best Practices Board and is widely published. Lane Leskela –Vice President of Technology Programs at nonprofit think tank the Open Compliance & Ethics Group.Prior to his role at OCEG, Lane served as the Senior Product Marketing Director for GRC applications at Oracle Corporation.Prior to joining Oracle, Lane was a Research Vice President at technology research firm Gartner, Inc. At Gartner, he managed software market research, analysis, reporting and client services for enterprise risk management, regulatory compliance management and financial control and reporting. Adil Khan –Senior Director at Fulcrum with over 15 years of experience in enterprise business systems. Adil also serves on the board of the Oracle Applications Users Group Internal Controls and Security Interest Group (OAUG- ICSSIG). At Fulcrum, Adil has successfully designed and implemented internal controls management systems for more than 50 global companies listed on NYSE and NASDAQ. His expertise includes streamlining and automating Governance Risk and Compliance processes based on industry standards such as ERM-COSO and COBit. Prior to Fulcrum, Adil served as a board member and Chief Executive Officer of ALTM - a public company listed on the NASDAQ.

5 Page 5 About Fulcrum We are a Leading provider of Governance, Risk and Compliance solutions for enterprise customers. Our solutions focus on: Enterprise Application Controls Monitoring GRC Process Management GRC Intelligence FulcrumWare GRC Tools include Content and On-line services to rapidly reduce risks such as Segregation of Duty violations in Enterprise Systems such as Oracle E-business Suite, PeopleSoft, JD Edwards, SAP and other Legacy Apps FulcrumWay Professionals are leading experts with real world experience in Internal Audit, Enterprise Systems and GRC Process Management. FulcrumPoint Insight provides the latest trends, best practices and thought leadership through regional and national conferences held by OAUG, IIA, ISACA Privately Held Delaware corporation with US presence in: New York, Texas and California International Presence in UK and India

6 Page 6 Fulcrum Credentials Media and Entertainment Financial Services Healthcare Natural Resources Life Sciences Industrial Manufacturing Defense/ Aerospace Retail Construction High Technology Readers Digest Retail Food

7 Page 7 FulcrumPoint Insight Thought Leadership - Events Compliance Week Magazine - Healthcare Firm Aligns Compliance Efforts, Cuts Costs Economist Magazine –Compliance Guide for Enterprise Systems POD Cast – How Automating the Enterprise Risk Management Process helps organizations comply with regulations OAUG - Impact of AS5 for Oracle Enterprise Customers IIA – Top Five Reasons for Automating Application Controls Oracle Open World – Annual GRC Dinner, GE and Birds Eye Case Study Web casts – GRC Best Practices, Trends and Expert Insight.

8 Page 8 Recap of surveys Two surveys conducted by ERP Seminars Fulcrum is a Co-Sponsor of the Survey Related to internal controls and security issues for Oracle’s eBusiness Suite

9 Page 9 Recap of surveys: Demographics Cross representation of industries Representing various sales levels from Under $100 million to over $5 billion Generally over 250 users ranging to many respondents over 5000 users Most common roles range from IT management, business analysts, and internal audit/corporate governance

10 Page 10 Recap of surveys Identify the awareness of the deficiency: My company was not aware of this risk My company is aware of this risk, but has chosen not to address it yet My company is aware of this risk and has chosen to accept the risk My company is aware of this risk and has addressed it via a manual control My company is aware of this risk and has implemented a customization / extension I am not qualified to address this risk My company does not use this functionality Other There were 20 scenarios presented and each scenario included two questions: Determine likelihood of implemented if Oracle provided a solution: Would likely not implement because we don't agree with the risks Would likely not implement because we already addressed via a Customization Would likely not implement because we have chosen to accept the risks Would likely implement it because we have not addressed the issue Would likely implement it because we would rather replace our customization I am not able to know what our company would do Other

11 Page 11 My company was not aware of this risk My company is aware of this risk, but has chosen not to address it yet My company is aware of this risk and has chosen to accept the risk My company is aware of this risk and has addressed it via a manual control My company is aware of this risk and has implemented a customization / extension I am not qualified to address this risk My company does not use this functionality Other

12 Page 12 Overview of results Lack of awareness of the risks - average 19%. (varied from 6.3% to 39%) Most of the deficiencies, if correctly by Oracle, would be widely adopted – average 78.4%. “Would likely implement it because we have not addressed the issue” or “Would likely implement it because we would rather replace our customization.” (varied from 55% to 89%)

13 Page 13 Specific results Workflow history retention:

14 Page 14 Specific results Workflow history retention:

15 Page 15 Specific results Workflow history retention recommendations: Remove purge program from all but one request group (DBA or business analyst?) – tightly control Document process for retaining history Maintain history for 15 months, then purge after 404 audit Develop archive and purge process for approvals separate from notifications

16 Page 16 Specific results Inquiry forms for support personnel / auditors – if Oracle provided standard forms: Question 7 on survey 1: Adjustment Approval Limits, Journal Authorization Limits, PO and Req Approval Limits, AME setups. 83% would implement. Question 8 on survey 1: Foundational setups such as Payables Options, Purchasing Options, Receiving Options, and Value Set Values. 86% would implement. Question 9 on survey 1: Menus, Functions, Request Groups, Responsibilities, and Users. 75% would implement.

17 Page 17 Specific results Inquiry forms recommendations: Take risk with access in Prod – not recommended Grant selected access to super users – recommended if proper controls are in place to monitor their activity Frequent cloning to non-prod instance Third party solution for inquiry forms

18 Page 18 Specific results Change management – lack of audit trails for security, setups, DDL, & development don’t allow for best practices audit Adoption rate for trigger or log-based auditing solution is low Companies general not following change management best practice guidance (IIA)

19 Page 19 Specific results Change management recommendations: Use a risk-based approach to identify critical audits to implement –SQL forms, development, security, high-risk setups and transactions Look at choices in log-based and trigger-based space – understand full scope before determining choice Look for companies with pre-seeded audits

20 Page 20 Specific results Manual controls to mitigate form/function deficiencies – examples: Order entry versus order approval AR Transaction entry versus approval Lack of credit checking in AR Override of matching level at PO level Monitoring of multiple adjustments entered in AR

21 Page 21 Specific results Form/function deficiencies recommendations: Look at using custom forms, forms personalization, or custom.pll to automate controls Analyze as part of risk-based approach access control risks / Segregation of Duties issues

22 Page 22 Fraud: Revenue Recognition (c) Deloitte Consulting LLP, 2008 The Deloitte Forensic Center reports large numbers of offenders with multiple fraud schemes: Seventy-four percent of the SEC enforcement releases described at least two fraud schemes Twenty-five percent described at least five schemes Seven percent described more than 10 alleged fraud schemes One percent alleged over 20 schemes

23 Page 23 Instead of This Mayhem… Regulation ARegulation BStandard C A1A2A3 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 Discrete Regulations & Standards Discrete Requirements Discrete Controls & Activities Siloed Functions & Departments B1B2B3 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 C1C2C3 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 No Linkage Weak Linkage 4/14/2015 (c) OCEG Adapted from Deloitte Consulting Graphic

24 Page 24 Full LinkageStronger Linkage Regulation ARegulation BStandard C A1A2A3 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 Discrete Regulations & Standards Common Requirements Common Controls & Activities Integrated Functions & Departments B1B2B3 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 C1C2C3 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 AB1 C1C2 C3C4 C5C6 C1C2 C3C4 C5C6 (c) OCEG AS5 also Supports This…

25 Page 25 Current State Managed in silos Mostly reactionary More projects than programs Handled separately from mainstream processes and decision-making People used as middleware Limited and fragmented use of technology GRC Program Management Future State Enterprise approach Integrated controls and processes Program based approach Embedded within mainstream processes and decision-making Effective use of information technology Architected solutions The Integration Imperative (c) OCEG, 2008

26 Page 26 (c) OCEG, 2008 The OCEG Capability Model

27 Page 27 Industry Process Applications (P) GRC Core Applications (G) Business Applications (B) Infrastructure (I) Industry Specific Requirements (PR) GRC Process Requirements (GR) Internal and External Content Specialists (e.g., law firms, consultants, departmental staff, management) Role and Context Applications (e.g., compliance processes, risk, quality, audit, legal, contracts) Organizational Functionality (e.g., ECM, BPM, BI, LMS, ERP) IT infrastructure (e.g., identity management, Databases, Information Security) (c) OCEG, 2008 The GRC Technology Model

28 Page 28 Performance-Based Control EFFECTIVE EFFICIENTRESPONSIVE O U T C O M E S ACTIVITIES EFFECTIVE Design Effectiveness – Is the system logically designed to meet all legal and other defined requirements? Operating Effectiveness – Does the system operate as designed for all users? EFFICIENT Financial Efficiency – How much capital investments is required to maintain it? Human Capital Efficiency – What level of individual(s) are required to use it? RESPONSIVE Cycle Time – How much time does it take to implement and upgrade? Flexibility / Adaptability – Can the system adapt to the changing environment including new Audit requirements and/or new business units? (c) OCEG 4/14/2015 (c) OCEG, 2008

29 Page 29 IT Controls Framework IT organizations should consider the nature and extent of their operations in determining which, if not all, of the following control objectives need to be included in internal control program: PLAN AND ORGANIZE ACQUIRE AND IMPLEMENT DELIVER AND SUPPORT MONITOR AND EVALUATE IT Controls

30 Page 30 What are Application Controls? Application controls apply to the business processes they support. These controls are designed within the application to prevent or detect unauthorized transactions. When combined with manual controls, as necessary, application controls ensure completeness, accuracy, authorization and validity of processing transactions Control objectives can be supported with automated application controls. They are most effective in integrated ERP environments, such as SAP, PeopleSoft, Oracle, JD Edwards and others. Examples:  Orders are processed only within approved customer credit limits.  Orders are approved by management as to prices and terms of sale.  Purchase orders are placed only for approved requisitions.  Purchase orders are accurately entered.  All purchase orders issued are input and processed.  All recorded production costs are consistent with actual direct and indirect expenses associated with production.  All direct and indirect expenses associated with production are recorded as production costs. Application Controls Overview

31 Page 31 Risk Assessment The IT organization has an entity- and activity-level risk assessment framework, which is used periodically to assess information risk to achieving business objectives. Management’s risk assessment framework focuses on the examination of the essential elements of risk and the cause and effect relationship among them. A risk assessment framework exists and considers the risk assessment probability and likelihood of threats. The IT organization’s risk assessment framework measures the impact of risks according to qualitative and quantitative criteria. The IT organization’s risk assessment framework is designed to support cost-effective controls to mitigate exposure to risks on a continuing basis, including risk avoidance, mitigation or acceptance. A comprehensive security assessment is performed for critical systems and locations based on their relative priority. Application Controls Overview

32 Page 32 Control Monitoring Changes to IT systems and applications are performed and designed to meet the expectations of users. IT management monitors its delivery of services to identify shortfalls and responds with actionable plans to improve. IT management monitors the effectiveness of internal controls Monitoring in the normal course of operations through management and supervisory activities, comparisons and benchmarks. Serious deviations in the operation of internal control, Monitoring including major security, availability and processing integrity events, are reported to senior management. Internal control assessments are performed periodically, using Monitoring self-assessment or independent audit, to examine whether internal controls are operating satisfactorily. Application Controls Overview

33 Page 33 Establish Rules Repository Detect Violations Analyze Issues Remediate Issues Implement Changes Monitor Application Environment Determine Scope by Application Extract ERP Data Manage Exceptions Setup Preventive Controls Application Control Teams Corporate Access Controls Business Process Teams IT Management Establish Test Environment Application Controls Management Best Practices Automation Approach

34 Page 34 Achieving regulatory compliance requires more than IT policies and process documentation Effective application audit planning requires mapping controls over application test environments, audit units and significant business processes based on risk likelihood and impact to thousands of functions and activities accessible through many roles, menus and functions. Detecting users that have unauthorized access to one or more critical business functions such as purchase to pay requires business analytics based on application control rules. Compensating controls are needed for certain users and transactions where business constraints require exceptions. Remediation effort requires strong collaboration among Audit, IT and Business stakeholders to reconfigure security, reassign users, prevent configuration changes, monitor transaction thresholds. ERP Access Provisioning and Configurations must be approved in “real time” to keep up with business needs. Auditing Challenges

35 Page 35 A. Case Study – Improve User Provisioning Company Overview Wholly owned subsidiary of Fortune 500 focused on communication and information technologies for security, safety and lifestyle enhancements. Operations in more than 30 countries Oracle E Business Suite GRC Challenges/Opportunities Comply with SOX Needed to automate a manual and labor- intensive process to define and approve user access. Segregation of Duties Concerns Oracle E-Business Environment –40 Modules –2500 Users, user responsibilities GRC Solutions Automate User Access Provisioning Compliant with SOD Policies Results Implemented access provisioning solution to identify users violations and allow auditable override capability for authorized access. Security provisioning time reduction Management Commitment to GRC SOD Rules Content jump started the process Detected over 5,000 violations Reduced access provisioning time from 14 days to 4 hours Trained Process Owners through online self-service portal

36 Page 36 B. Case Study – Remediate Access Control Deficiency Company Overview Leading manufacturer of electrical and mechanical motion control products Growing Rapidly through acquisitions Manufacturing and service facilities are located worldwide Multiple Enterprise Applications GRC Challenges/Opportunities Remediate Significant Deficiency identified by external Auditor Needed a central system to detect over 5000 user access violations and implement new roles across multiple systems within 90 days Limited IT Audit Resources – One Full Time Equivalent (FTE) GRC Solutions Risk Analytics Service Access Policies Detection and Remediation Service Results Completed First Test in 24 hours No time or resources wasted on additional IT Infrastructure with the On Demand Web Service Setup Compensating Controls for Waived Users Preventive Controls Functions reduced the risk of security violations in real time. Fully Compatible with all Enterprise Systems Access Controls Content helped management define risk likelihood and impact Faster Remediation through Analytical Reports and Filters What-if Analysis Improved Self- Service User Provisioning Process

37 Page 37 C. Case Study – Reduce Expense through Configurable Controls Company Overview World’s pre-eminent gold producer, with a portfolio of 27 operating mines Many advanced exploration and development projects located across five continents The largest gold reserves in the industry GRC Challenges/Opportunities Need to reduce SOX Compliance Audit expense Implement continuous controls monitoring Baseline ERP Configurable Controls for AS5 GRC Solutions Identify Controls for full or partial automation. Benchmark ERP Configurations Setup audit logs on all configuration changes. Results Analyzed over 1,000 controls Application Audit Portal provides audit trail on all configuration changes in ERP Systems Track changes to key application setup data and code. Approval workflows and notifications facilitate change management without negatively impacting core business operations. Increase visibility into the actual operations of the controls environment Reduced Testing Time by 30%

38 Page 38 Closing Comments Download Full Survey Results at: Speaker Contacts: Jane Jeffrey Lane Adil


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