Control and Accounting Information Systems

Control and Accounting Information Systems
HAPTER 6 Control and Accounting Information Systems

INTRODUCTION Questions to be addressed in this chapter:
What are the basic internal control concepts, and why are computer control and security important? What is the difference between the COBIT, COSO, and ERM control frameworks? What are the major elements in the internal environment of a company? What are the four types of control objectives that companies need to set? What events affect uncertainty, and how can they be identified? How is the Enterprise Risk Management model used to assess and respond to risk? What control activities are commonly used in companies? How do organizations communicate information and monitor control processes?

INTRODUCTION Why AIS threats are increasing
Control risks have increased in the last few years because: There are computers and servers everywhere, and information is available to an unprecedented number of workers. Distributed computer networks make data available to many users, and these networks are harder to control than centralized mainframe systems. Wide area networks are giving customers and suppliers access to each other’s systems and data, making confidentiality a major concern.

INTRODUCTION Historically, many organizations have not adequately protected their data due to one or more of the following reasons: Computer control problems are often underestimated and downplayed. Control implications of moving from centralized, host-based computer systems to those of a networked system or Internet-based system are not always fully understood. Companies have not realized that data is a strategic resource and that data security must be a strategic requirement. Productivity and cost pressures may motivate management to forego time-consuming control measures.

INTRODUCTION Some vocabulary terms for this chapter:
A threat is any potential adverse occurrence or unwanted event that could injure the AIS or the organization. The exposure or impact of the threat is the potential dollar loss that would occur if the threat becomes a reality. The likelihood is the probability that the threat will occur.

INTRODUCTION Control and security are important
Companies are now recognizing the problems and taking positive steps to achieve better control, including: Devoting full-time staff to security and control concerns. Educating employees about control measures. Establishing and enforcing formal information security policies. Making controls a part of the applications development process. Moving sensitive data to more secure environments.

INTRODUCTION To use IT in achieving control objectives, accountants must: Understand how to protect systems from threats. Have a good understanding of IT and its capabilities and risks. Achieving adequate security and control over the information resources of an organization should be a top management priority.

INTRODUCTION Control objectives are the same regardless of the data processing method, but a computer-based AIS requires different internal control policies and procedures because: Computer processing may reduce clerical errors but increase risks of unauthorized access or modification of data files. Segregation of duties must be achieved differently in an AIS. Computers provide opportunities for enhancement of some internal controls.

INTRODUCTION One of the primary objectives of an AIS is to control a business organization. Accountants must help by designing effective control systems and auditing or reviewing control systems already in place to ensure their effectiveness. Management expects accountants to be control consultants by: Taking a proactive approach to eliminating system threats; and Detecting, correcting, and recovering from threats when they do occur.

INTRODUCTION It is much easier to build controls into a system during the initial stage than to add them after the fact. Consequently, accountants and control experts should be members of the teams that develop or modify information systems.

OVERVIEW OF CONTROL CONCEPTS
In today’s dynamic business environment, companies must react quickly to changing conditions and markets, including steps to: Hire creative and innovative employees. Give these employees power and flexibility to: Satisfy changing customer demands; Pursue new opportunities to add value to the organization; and Implement process improvements. At the same time, the company needs control systems so they are not exposed to excessive risks or behaviors that could harm their reputation for honesty and integrity.

Internal control is the process implemented by the board of directors, management, and those under their direction to provide reasonable assurance that the following control objectives are achieved: Assets (including data) are safeguarded. This objective includes prevention or timely detection of unauthorized acquisition, use, or disposal of material company assets.

Internal control is the process implemented by the board of directors, management, and those under their direction to provide reasonable assurance that the following control objectives are achieved: Assets (including data) are safeguarded. Records are maintained in sufficient detail to accurately and fairly reflect company assets.

Internal control is the process implemented by the board of directors, management, and those under their direction to provide reasonable assurance that the following control objectives are achieved: Assets (including data) are safeguarded. Records are maintained in sufficient detail to accurately and fairly reflect company assets. Accurate and reliable information is provided.

Internal control is the process implemented by the board of directors, management, and those under their direction to provide reasonable assurance that the following control objectives are achieved: Assets (including data) are safeguarded. Records are maintained in sufficient detail to accurately and fairly reflect company assets. Accurate and reliable information is provided. There is reasonable assurance that financial reports are prepared in accordance with GAAP.

Internal control is the process implemented by the board of directors, management, and those under their direction to provide reasonable assurance that the following control objectives are achieved: Assets (including data) are safeguarded. Records are maintained in sufficient detail to accurately and fairly reflect company assets. Accurate and reliable information is provided. There is reasonable assurance that financial reports are prepared in accordance with GAAP. Operational efficiency is promoted and improved. This objective includes ensuring that company receipts and expenditures are made in accordance with management and directors’ authorizations.

Internal control is the process implemented by the board of directors, management, and those under their direction to provide reasonable assurance that the following control objectives are achieved: Assets (including data) are safeguarded. Records are maintained in sufficient detail to accurately and fairly reflect company assets. Accurate and reliable information is provided. There is reasonable assurance that financial reports are prepared in accordance with GAAP. Operational efficiency is promoted and improved. Adherence to prescribed managerial policies is encouraged.

Internal control is the process implemented by the board of directors, management, and those under their direction to provide reasonable assurance that the following control objectives are achieved: Assets (including data) are safeguarded. Records are maintained in sufficient detail to accurately and fairly reflect company assets. Accurate and reliable information is provided. There is reasonable assurance that financial reports are prepared in accordance with GAAP. Operational efficiency is promoted and improved. Adherence to prescribed managerial policies is encouraged. The organization complies with applicable laws and regulations.

Internal control is a process because: It permeates an organization’s operating activities. It is an integral part of basic management activities. Internal control provides reasonable, rather than absolute, assurance, because complete assurance is difficult or impossible to achieve and prohibitively expensive.

Internal control systems have inherent limitations, including: They are susceptible to errors and poor decisions. They can be overridden by management or by collusion of two or more employees. Internal control objectives are often at odds with each other. EXAMPLE: Controls to safeguard assets may also reduce operational efficiency.

Internal controls perform three important functions: Preventive controls Deter problems before they arise.

Internal controls perform three important functions: Preventive controls Detective controls Discover problems quickly when they do arise.

Internal controls perform three important functions: Preventive controls Detective controls Corrective controls Remedy problems that have occurred by: Identifying the cause; Correcting the resulting errors; and Modifying the system to prevent future problems of this sort.

Internal controls are often classified as: General controls Those designed to make sure an organization’s control environment is stable and well managed. They apply to all sizes and types of systems. Examples: Security management controls.

Internal controls are often classified as: General controls Application controls Prevent, detect, and correct transaction errors and fraud. Concerned with accuracy, completeness, validity, and authorization of the data captured, entered into the system, processed, stored, transmitted to other systems, and reported.

An effective system of internal controls should exist in all organizations to: Help them achieve their missions and goals. Minimize surprises.

SOX AND THE FOREIGN CORRUPT PRACTICES ACT
In 1977, Congress passed the Foreign Corrupt Practices Act, and to the surprise of the profession, this act incorporated language from an AICPA pronouncement. The primary purpose of the act was to prevent the bribery of foreign officials to obtain business. A significant effect was to require that corporations maintain good systems of internal accounting control. Generated significant interest among management, accountants, and auditors in designing and evaluating internal control systems. The resulting internal control improvements weren’t sufficient.

In the late 1990s and early 2000s, a series of multi-million-dollar accounting frauds made headlines. The impact on financial markets was substantial, and Congress responded with passage of the Sarbanes-Oxley Act of 2002 (aka, SOX). Applies to publicly held companies and their auditors.

The intent of SOX is to: Prevent financial statement fraud Make financial reports more transparent Protect investors Strengthen internal controls in publicly-held companies Punish executives who perpetrate fraud SOX has had a material impact on the way boards of directors, management, and accountants operate.

Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. Has five members, three of whom cannot be CPAs. Charges fees to firms to fund the PCAOB. Sets and enforces auditing, quality control, ethics, independence, and other standards relating to audit reports. Currently recognizes FASB statements as being generally accepted.

Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. New rules for auditors They must report specific information to the company’s audit committee, such as: Critical accounting policies and practices Alternative GAAP treatments Auditor-management disagreements Audit partners must be rotated periodically.

Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. New rules for auditors Auditors cannot perform certain non-audit services, such as: Bookkeeping Information systems design and implementation Internal audit outsourcing services Management functions Human resource services

Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. New rules for auditors Permissible non-audit services must be approved by the board of directors and disclosed to investors. Cannot audit a company if a member of top management was employed by the auditor and worked on the company’s audit in the past 12 months.

Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. New rules for auditors New rules for audit committees Members must be on the company’s board of directors and must otherwise be independent of the company. One member must be a financial expert. The committee hires, compensates, and oversees the auditors, and the auditors report directly to the committee.

The CEO and CFO must certify that: The financial statements and disclosures are fairly presented, were reviewed by management, and are not misleading. Management is responsible for internal controls. The auditors were advised of any material internal control weaknesses or fraud. Any significant changes to controls after management’s evaluation were disclosed and corrected. Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. New rules for auditors New rules for audit committees New rules for management

If management willfully and knowingly violates the certification, they can be: Imprisoned up to 20 years Fined up to $5 million Management and directors cannot receive loans that would not be available to people outside the company. They must disclose on a rapid and current basis material changes to their financial condition. Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. New rules for auditors New rules for audit committees New rules for management

New internal control requirements: Section 404 of SOX requires companies to issue a report accompanying the financial statements that: States management is responsible for establishing and maintaining an adequate internal control structure and procedures. Contains management’s assessment of the company’s internal controls. Attests to the accuracy of the internal controls, including disclosures of significant defects or material noncompliance found during the tests. Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. New rules for auditors New rules for audit committees New rules for management New internal control requirements

Important aspects of SOX include: Creation of the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing profession. New rules for auditors New rules for audit committees New rules for management New internal control requirements SOX also requires that the auditor attests to and reports on management’s internal control assessment. Each audit report must describe the scope of the auditor’s internal control tests.

After the passage of SOX, the SEC further mandated that: Management must base its evaluation on a recognized control framework, developed using a due-process procedure that allows for public comment. The most likely framework is the COSO model discussed later in the chapter. The report must contain a statement identifying the framework used. Management must disclose any and all material internal control weaknesses. Management cannot conclude that the company has effective internal control if there are any material weaknesses.

Levers of control Many people feel there is a basic conflict between creativity and controls. Robert Simons has espoused four levers of controls to help companies reconcile this conflict: A concise belief system Communicates company core values to employees and inspires them to live by those values. Draws attention to how the organization creates value. Helps employees understand management’s intended direction. Must be broad enough to appeal to all levels.

Helps employees act ethically by setting limits beyond which they must not pass. Does not create rules and standard operating procedures that can stifle creativity. Encourages employees to think and act creatively to solve problems and meet customer needs as long as they operate within limits such as: Meeting minimum standards of performance Shunning off-limits activities Avoiding actions that could damage the company’s reputation. Levers of Control Many people feel there is a basic conflict between creativity and controls. Robert Simons has espoused four levers of controls to help companies reconcile this conflict: A concise belief system A boundary system

Levers of control Many people feel there is a basic conflict between creativity and controls. Robert Simons has espoused four levers of controls to help companies reconcile this conflict: A concise belief system A boundary system A diagnostic control system Ensures efficient and effective achievement of important controls. This system measures company progress by comparing actual to planned performance. Helps managers track critical performance outcomes and monitor performance of individuals, departments, and locations. Provides feedback to enable management to adjust and fine-tune.

Helps top-level managers with high-level activities that demand frequent and regular attention. Examples: Developing company strategy. Setting company objectives. Understanding and assessing threats and risks. Monitoring changes in competitive conditions and emerging technologies. Developing responses and action plans to proactively deal with these high-level issues. Also helps managers focus the attention of subordinates on key strategic issues and to be more involved in their decisions. Data from this system are best interpreted and discussed in face-to-face meetings. Levers of Control Many people feel there is a basic conflict between creativity and controls. Robert Simons has espoused four levers of controls to help companies reconcile this conflict: A concise belief system A boundary system A diagnostic control system An interactive control system

CONTROL FRAMEWORKS A number of frameworks have been developed to help companies develop good internal control systems. Three of the most important are: The COBIT framework The COSO internal control framework COSO’s Enterprise Risk Management framework (ERM)

CONTROL FRAMEWORKS COBIT framework
Also know as the Control Objectives for Information and Related Technology framework. Developed by the Information Systems Audit and Control Foundation (ISACF). A framework of generally applicable information systems security and control practices for IT control.

CONTROL FRAMEWORKS The COBIT framework allows:
Management to benchmark security and control practices of IT environments. Users of IT services to be assured that adequate security and control exists. Auditors to substantiate their opinions on internal control and advise on IT security and control matters.

CONTROL FRAMEWORKS To satisfy business objectives, information must conform to certain criteria referred to as “business requirements for information.” The criteria are divided into seven distinct yet overlapping categories that map into COSO objectives: Effectiveness (relevant, pertinent, and timely) Efficiency Confidentiality Integrity Availability Compliance with legal requirements Reliability The framework addresses the issue of control from three vantage points or dimensions: Business objectives

CONTROL FRAMEWORKS The framework addresses the issue of control from three vantage points or dimensions: Business objectives IT resources Includes: People Application systems Technology Facilities Data

CONTROL FRAMEWORKS The framework addresses the issue of control from three vantage points or dimensions: Business objectives IT resources IT processes Broken into four domains: Planning and organization Acquisition and implementation Delivery and support Monitoring

CONTROL FRAMEWORKS COBIT consolidates standards from 36 different sources into a single framework. It is having a big impact on the IS profession. Helps managers to learn how to balance risk and control investment in an IS environment. Provides users with greater assurance that security and IT controls provided by internal and third parties are adequate. Guides auditors as they substantiate their opinions and provide advice to management on internal controls.

CONTROL FRAMEWORKS COSO’s internal control framework
The Committee of Sponsoring Organizations (COSO) is a private sector group consisting of: The American Accounting Association The AICPA The Institute of Internal Auditors The Institute of Management Accountants The Financial Executives Institute

CONTROL FRAMEWORKS In 1992, COSO issued the Internal Control Integrated Framework: Defines internal controls. Provides guidance for evaluating and enhancing internal control systems. Widely accepted as the authority on internal controls. Incorporated into policies, rules, and regulations used to control business activities.

CONTROL FRAMEWORKS COSO’s internal control model has five crucial components: Control environment The core of any business is its people. Their integrity, ethical values, and competence make up the foundation on which everything else rests.

CONTROL FRAMEWORKS COSO’s internal control model has five crucial components: Control environment Control activities Policies and procedures must be established and executed to ensure that actions identified by management as necessary to address risks are, in fact, carried out.

CONTROL FRAMEWORKS COSO’s internal control model has five crucial components: Control environment Control activities Risk assessment The organization must be aware of and deal with the risks it faces. It must set objectives for its diverse activities and establish mechanisms to identify, analyze, and manage the related risks.

CONTROL FRAMEWORKS COSO’s internal control model has five crucial components: Control environment Control activities Risk assessment Information and communication Information and communications systems surround the control activities. They enable the organization’s people to capture and exchange information needed to conduct, manage, and control its operations.

CONTROL FRAMEWORKS COSO’s internal control model has five crucial components: Control environment Control activities Risk assessment Information and communication Monitoring The entire process must be monitored and modified as necessary.

CONTROL FRAMEWORKS Nine years after COSO issued the preceding framework, it began investigating how to effectively identify, assess, and manage risk so organizations could improve the risk management process. Result: Enterprise Risk Manage Integrated Framework (ERM) An enhanced corporate governance document. Expands on elements of preceding framework. Provides a focus on the broader subject of enterprise risk management.

CONTROL FRAMEWORKS Intent of ERM is to achieve all goals of the internal control framework and help the organization: Provide reasonable assurance that company objectives and goals are achieved and problems and surprises are minimized. Achieve its financial and performance targets. Assess risks continuously and identify steps to take and resources to allocate to overcome or mitigate risk. Avoid adverse publicity and damage to the entity’s reputation.

CONTROL FRAMEWORKS ERM defines risk management as:
A process effected by an entity’s board of directors, management, and other personnel. Applied in strategy setting and across the enterprise. To identify potential events that may affect the entity. And manage risk to be within its risk appetite. In order to provide reasonable assurance of the achievement of entity objectives.

CONTROL FRAMEWORKS Basic principles behind ERM:
Companies are formed to create value for owners. Management must decide how much uncertainty they will accept. Uncertainty can result in: Risk The possibility that something will happen to: Adversely affect the ability to create value; or Erode existing value.

CONTROL FRAMEWORKS Basic principles behind ERM:
Companies are formed to create value for owners. Management must decide how much uncertainty they will accept. Uncertainty can result in: Risk Opportunity The possibility that something will happen to positively affect the ability to create or preserve value.

CONTROL FRAMEWORKS The framework should help management manage uncertainty and its associated risk to build and preserve value. To maximize value, a company must balance its growth and return objectives and risks with efficient and effective use of company resources.

CONTROL FRAMEWORKS COSO developed a model to illustrate the elements of ERM.

CONTROL FRAMEWORKS Columns at the top represent the four types of objectives that management must meet to achieve company goals. Strategic objectives Strategic objectives are high-level goals that are aligned with and support the company’s mission.

CONTROL FRAMEWORKS Columns at the top represent the four types of objectives that management must meet to achieve company goals. Strategic objectives Operations objectives Operations objectives deal with effectiveness and efficiency of company operations, such as: Performance and profitability goals Safeguarding assets

CONTROL FRAMEWORKS Reporting objectives help ensure the accuracy, completeness, and reliability of internal and external company reports of both a financial and non-financial nature. Improve decision-making and monitor company activities and performance more efficiently. Columns at the top represent the four types of objectives that management must meet to achieve company goals. Strategic objectives Operations objectives Reporting objectives

CONTROL FRAMEWORKS Columns at the top represent the four types of objectives that management must meet to achieve company goals. Strategic objectives Operations objectives Reporting objectives Compliance objectives Compliance objectives help the company comply with applicable laws and regulations. External parties often set the compliance rules. Companies in the same industry often have similar concerns in this area.

CONTROL FRAMEWORKS ERM can provide reasonable assurance that reporting and compliance objectives will be achieved because companies have control over them. However, strategic and operations objectives are sometimes at the mercy of external events that the company can’t control. Therefore, in these areas, the only reasonable assurance the ERM can provide is that management and directors are informed on a timely basis of the progress the company is making in achieving them.

CONTROL FRAMEWORKS Columns on the right represent the company’s units:
Entire company

Entire company Division

Entire company Division Business unit

Entire company Division Business unit Subsidiary

CONTROL FRAMEWORKS The horizontal rows are eight related risk and control components, including: Internal environment The tone or culture of the company. Provides discipline and structure and is the foundation for all other components. Essentially, the same as control environment in the COSO internal control framework.

CONTROL FRAMEWORKS The horizontal rows are eight related risk and control components, including: Internal environment Objective setting Ensures that management implements a process to formulate strategic, operations, reporting, and compliance objectives that support the company’s mission and are consistent with the company’s tolerance for risk. Strategic objectives are set first as a foundation for the other three. The objectives provide guidance to companies as they identify risk-creating events and assess and respond to those risks.

CONTROL FRAMEWORKS The horizontal rows are eight related risk and control components, including: Internal environment Objective setting Event identification Requires management to identify events that may affect the company’s ability to implement its strategy and achieve its objectives. Management must then determine whether these events represent: Risks (negative-impact events requiring assessment and response); or Opportunities (positive-impact events that influence strategy and objective-setting processes).

Identified risks are assessed to determine how to manage them and how they affect the company’s ability to achieve its objectives. Qualitative and quantitative methods are used to assess risks individually and by category in terms of: Likelihood Positive and negative impact Effect on other organizational units Risks are analyzed on an inherent and a residual basis. Corresponds to the risk assessment element in COSO’s internal control framework. CONTROL FRAMEWORKS The horizontal rows are eight related risk and control components, including: Internal environment Objective setting Event identification Risk assessment

Management aligns identified risks with the company’s tolerance for risk by choosing to:
Avoid Reduce Share Accept Management takes an entity-wide or portfolio view of risks in assessing the likelihood of the risks, their potential impact, and costs-benefits of alternate responses. CONTROL FRAMEWORKS The horizontal rows are eight related risk and control components, including: Internal environment Objective setting Event identification Risk assessment Risk response

CONTROL FRAMEWORKS The horizontal rows are eight related risk and control components, including: Internal environment Objective setting Event identification Risk assessment Risk response Control activities To implement management’s risk responses, control policies and procedures are established and implemented throughout the various levels and functions of the organization. Corresponds to the control activities element in the COSO internal control framework.

Information about the company and ERM components must be identified, captured, and communicated so employees can fulfill their responsibilities. Information must be able to flow through all levels and functions in the company as well as flowing to and from external parties. Employees should understand their role and importance in ERM and how these responsibilities relate to those of others. Has a corresponding element in the COSO internal control framework. CONTROL FRAMEWORKS The horizontal rows are eight related risk and control components, including: Internal environment Objective setting Event identification Risk assessment Risk response Control activities Information and communication

CONTROL FRAMEWORKS The horizontal rows are eight related risk and control components, including: Internal environment Objective setting Event identification Risk assessment Risk response Control activities Information and communication Monitoring ERM processes must be monitored on an ongoing basis and modified as needed. Accomplished with ongoing management activities and separate evaluations. Deficiencies are reported to management. Corresponding module in COSO internal control framework.

CONTROL FRAMEWORKS The ERM model is three-dimensional.
Means that each of the eight risk and control elements are applied to the four objectives in the entire company and/or one of its subunits.

CONTROL FRAMEWORKS ERM Framework Vs. the Internal Control Framework
The internal control framework has been widely adopted as the principal way to evaluate internal controls as required by SOX. However, there are issues with it. It has too narrow of a focus. Examining controls without first examining purposes and risks of business processes provides little context for evaluating the results. Makes it difficult to know: Which control systems are most important. Whether they adequately deal with risk. Whether important control systems are missing.

CONTROL FRAMEWORKS ERM framework vs. the internal control framework
The internal control framework has been widely adopted as the principal way to evaluate internal controls as required by SOX. However, there are issues with it. It has too narrow of a focus. Focusing on controls first has an inherent bias toward past problems and concerns. May contribute to systems with many controls to protect against risks that are no longer important.

CONTROL FRAMEWORKS These issues led to COSO’s development of the ERM framework. Takes a risk-based, rather than controls-based, approach to the organization. Oriented toward future and constant change. Incorporates rather than replaces COSO’s internal control framework and contains three additional elements: Setting objectives. Identifying positive and negative events that may affect the company’s ability to implement strategy and achieve objectives. Developing a response to assessed risk.

CONTROL FRAMEWORKS Controls are flexible and relevant because they are linked to current organizational objectives. ERM also recognizes more options than simply controlling risk, which include accepting it, avoiding it, diversifying it, sharing it, or transferring it.

CONTROL FRAMEWORKS Over time, ERM will probably become the most widely adopted risk and control model. Consequently, its eight components are the topic of the remainder of the chapter.

INTERNAL ENVIRONMENT The most critical component of the ERM and the internal control framework. Is the foundation on which the other seven components rest. Influences how organizations: Establish strategies and objectives Structure business activities Identify, access, and respond to risk A deficient internal control environment often results in risk management and control breakdowns.

INTERNAL ENVIRONMENT Internal environment consists of the following:
Management’s philosophy, operating style, and risk appetite The board of directors Commitment to integrity, ethical values, and competence Organizational structure Methods of assigning authority and responsibility Human resource standards External influences

INTERNAL ENVIRONMENT Management’s philosophy, operating style, and risk appetite An organization’s management has shared beliefs and attitudes about risk. That philosophy affects everything the organization does, long- and short-term, and affects their communications. Companies also have a risk appetite, which is the amount of risk a company is willing to accept to achieve its goals and objectives. That appetite needs to be in alignment with company strategy.

INTERNAL ENVIRONMENT The more responsible management’s philosophy and operating style, the more likely employees will behave responsibly. This philosophy must be clearly communicated to all employees; it is not enough to give lip service. Management must back up words with actions; if they show little concern for internal controls, then neither will employees.

INTERNAL ENVIRONMENT This component can be assessed by asking questions such as: Does management take undue business risks or assess potential risks and rewards before acting? Does management attempt to manipulate performance measures such as net income? Does management pressure employees to achieve results regardless of methods or do they demand ethical behavior?

INTERNAL ENVIRONMENT The board of directors
An active and involved board of directors plays an important role in internal control. They should: Oversee management Scrutinize management’s plans, performance, and activities Approve company strategy Review financial results Annually review the company’s security policy Interact with internal and external auditors

INTERNAL ENVIRONMENT Directors should possess management, technical, or other expertise, knowledge, or experience, as well as a willingness to advocate for shareholders. At least a majority should be independent, outside directors not affiliated with the company or any of its subsidiaries.

INTERNAL ENVIRONMENT Public companies must have an audit committee, composed entirely of independent, outside directors. The audit committee oversees: The company’s internal control structure; Its financial reporting process; and Its compliance with laws, regulations, and standards. Works with the corporation’s external and internal auditors. Hires, compensates, and oversees the auditors. Auditors report all critical accounting policies and practices to the audit committee. Provides an independent review of management’s actions.

INTERNAL ENVIRONMENT Commitment to integrity, ethical values, and competence Management must create an organizational culture that stresses integrity and commitment to both ethical values and competence. Ethical standards of behavior make for good business. Tone at the top is everything. Employees will watch the actions of the CEO, and the message of those actions (good or bad) will tend to permeate the organization.

INTERNAL ENVIRONMENT Companies can endorse integrity as a basic operating principle by actively teaching and requiring it. Management should: Make it clear that honest reports are more important than favorable ones. Management should avoid: Unrealistic expectations, incentives, or temptations. Attitude of earnings or revenue at any price. Overly aggressive sales practices. Unfair or unethical negotiation practices. Implied kickback offers. Excessive bonuses. Bonus plans with upper and lower cutoffs.

INTERNAL ENVIRONMENT Management should not assume that employees would always act honestly. Consistently reward and encourage honesty. Give verbal labels to honest and dishonest acts. The combination of these two will produce more consistent moral behavior.

INTERNAL ENVIRONMENT Management should develop clearly stated policies that explicitly describe honest and dishonest behaviors, often in the form of a written code of conduct. In particular, such a code would cover issues that are uncertain or unclear. Dishonesty often appears when situations are gray and employees rationalize the most expedient action as opposed to making a right vs. wrong choice.

INTERNAL ENVIRONMENT SOX only requires a code of ethics for senior financial management. However, the ACFE suggests that companies create a code of conduct for all employees: Should be written at a fifth-grade level. Should be reviewed annually with employees and signed. This approach helps employees keep themselves out of trouble. Helps the company if they need to take legal action against the employee.

INTERNAL ENVIRONMENT Management should require employees to report dishonest, illegal, or unethical behavior and discipline employees who knowingly fail to report. Reports of dishonest acts should be thoroughly investigated. Those found guilty should be dismissed. Prosecution should be undertaken when possible, so that other employees are clear about consequences. Companies must make a commitment to competence. Begins with having competent employees. Varies with each job but is a function of knowledge, experience, training, and skills.

INTERNAL ENVIRONMENT The levers of control, particularly beliefs and boundaries systems, can be used to create the kind of commitment to integrity an organization wants. Requires more than lip service and signing forms. Must be systems in which top management actively participates in order to: Demonstrate the importance of the system. Create buy-in and a team spirit.

INTERNAL ENVIRONMENT Management should require employees to report dishonest, illegal, or unethical behavior and discipline employees who knowingly fail to report. Reports of dishonest acts should be thoroughly investigated. Those found guilty should be dismissed. Prosecution should be undertaken when possible, so that other employees are clear about consequences.

INTERNAL ENVIRONMENT Companies must make a commitment to competence.
Begins with having competent employees. Varies with each job but is a function of knowledge, experience, training, and skills.

INTERNAL ENVIRONMENT The levers of control, particularly beliefs and boundary systems, can be used to create the kind of commitment to integrity an organization wants. Requires more than lip service and signing forms. Must be systems in which top management actively participates in order to: Demonstrate the importance of the system. Create buy-in and a team spirit.

INTERNAL ENVIRONMENT Organizational structure
A company’s organizational structure defines its lines of authority, responsibility, and reporting. Provides the overall framework for planning, directing, executing, controlling, and monitoring its operations.

INTERNAL ENVIRONMENT Important aspects or organizational structure:
Degree of centralization or decentralization. Assignment of responsibility for specific tasks. Direct-reporting relationships or matrix structure. Organization by industry, product, geographic location, marketing network. How the responsibility allocation affects management’s information needs. Organization of accounting and IS functions. Size and nature of company activities.

INTERNAL ENVIRONMENT Statistically, fraud occurs more frequently in organizations with complex structures. The structures may unintentionally impede communication and clear assignment of responsibility, making fraud easier to commit and conceal; or The structure may be intentionally complex to facilitate the fraud.

INTERNAL ENVIRONMENT In today’s business world, the hierarchical organizations with many layers of management are giving way to flatter organizations with self-directed work teams. Team members are empowered to make decisions without multiple layers of approvals. Emphasis is on continuous improvement rather than on regular evaluations. These changes have a significant impact on the nature and type of controls needed.

INTERNAL ENVIRONMENT Methods of assigning authority and responsibility
Management should make sure: Employees understand the entity’s objectives. Authority and responsibility for business objectives is assigned to specific departments and individuals. Ownership of responsibility encourages employees to take initiative in solving problems and holds them accountable for achieving objectives. Management: Must be sure to identify who is responsible for the IS security policy. Should monitor results so decisions can be reviewed and, if necessary, overruled.

INTERNAL ENVIRONMENT Authority and responsibility are assigned through: Formal job descriptions Employee training Operating plans, schedules, and budgets Codes of conduct that define ethical behavior, acceptable practices, regulatory requirements, and conflicts of interest Written policies and procedures manuals (a good job reference and job training tool) which covers: Proper business practices Knowledge and experience needed by key personnel Resources provided to carry out duties Policies and procedures for handling particular transactions The organization’s chart of accounts Sample copies of forms and documents

INTERNAL ENVIRONMENT Human resources standards
Employees are both the company’s greatest control strength and the greatest control weakness. Organizations can implement human resource policies and practices with respect to hiring, training, compensating, evaluating, counseling, promoting, and discharging employees that send messages about the level of competence and ethical behavior required. Policies on working conditions, incentives, and career advancement can powerfully encourage efficiency and loyalty and reduce the organization’s vulnerability.

INTERNAL ENVIRONMENT The following policies and procedures are important: Hiring Compensating Training Evaluating and promoting Discharging Managing disgruntled employees Vacations and rotation of duties Confidentiality insurance and fidelity bonds

INTERNAL ENVIRONMENT Hiring
Should be based on educational background, relevant work experience, past achievements, honesty and integrity, and how well candidates meet written job requirements. Employees should undergo a formal, in-depth employment interview. Resumes, reference letters, and thorough background checks are critical.

INTERNAL ENVIRONMENT Background checks can involve:
Verifying education and experience. Talking with references. Checking for criminal records, credit issues, and other publicly available data. Note that you must have the employee’s or candidate’s written permission to conduct a background check, but that permission does not need to have an expiration date. Background checks are important because recent studies show that about 50% of resumes have been falsified or embellished.

INTERNAL ENVIRONMENT Sometimes professional firms are hired to do the background checks because applicants are becoming more aggressive in their deceptions. Some get phony degrees from online “diploma mills.” A Pennsylvania district attorney recently filed suit against a Texas “university” for issuing an MBA to the DA’s 6-year-old black cat. Others actually hack (or hire someone to hack) into the systems of universities to create or alter transcripts and other academic data. No employee should be exempted from background checks. Anyone from the custodian to the company president is capable of committing fraud, sabotage, etc.

INTERNAL ENVIRONMENT Compensating
Employees should be paid a fair and competitive wage. Poorly compensated employees are more likely to feel the resentment and financial pressures that lead to fraud. Appropriate incentives can motivate and reinforce outstanding performance.

INTERNAL ENVIRONMENT Policies on training
Training programs should familiarize new employees with: Their responsibilities. Expected performance and behavior. Company policies, procedures, history, culture, and operating style. Training needs to be ongoing, not just one time. Companies who shortchange training are more likely to experience security breaches and fraud.

INTERNAL ENVIRONMENT Many believe employee training and education are the most important elements of fraud prevention and security programs. Fraud is less likely to occur when employees believe security is everyone’s business. An ideal corporate culture exists when: Employees are proud of their company and protective of its assets. They believe fraud hurts everyone and that they therefore have a responsibility to report it.

INTERNAL ENVIRONMENT These cultures do not just happen. They must be created, taught, and practiced, and the following training should be provided: Fraud awareness Employees should be aware of fraud’s prevalence and dangers, why people do it, and how to deter and detect it. Ethical considerations The company should promote ethical standards in its practice and its literature. Acceptable and unacceptable behavior should be defined and labeled, leaving as little gray area as possible.

INTERNAL ENVIRONMENT Punishment for fraud and unethical behavior.
Employees should know the consequences (e.g., reprimand, dismissal, prosecution) of bad behavior. Should be disseminated as a consequence rather than a threat. EXAMPLE: “Using a computer to steal or commit fraud is a federal crime, and anyone doing so faces immediate dismissal and/or prosecution.” The company should display notices of program and data ownership and advise employees of the penalties of misuse.

INTERNAL ENVIRONMENT Training can take place through:
Informal discussions Formal meetings Periodic memos Written guidelines Codes of ethics Circulating reports of unethical behavior and its consequences Promoting security and fraud training programs

INTERNAL ENVIRONMENT Evaluating and promoting
Do periodic performance appraisals to help employees understand their strengths and weaknesses. Base promotions on performance and qualifications.

INTERNAL ENVIRONMENT Discharging
Fired employees are disgruntled employees. Disgruntled employees are more likely to commit a sabotage or fraud against the company. Employees who are terminated (whether voluntary or involuntary) should be removed from sensitive jobs immediately and denied access to information systems.

INTERNAL ENVIRONMENT Managing disgruntled employees
Disgruntled employees may be isolated and/or unhappy, but are much likelier fraud candidates than satisfied employees. The organization can try to reduce the employee’s pressures through grievance channels and counseling. Difficult to do because many employees feel that seeking counseling will stigmatize them in their jobs. Disgruntled employees should not be allowed to continue in jobs where they could harm the organization.

INTERNAL ENVIRONMENT Vacations and rotation of duties
Some fraud schemes, such as lapping and kiting, cannot continue without the constant attention of the perpetrator. Mandatory vacations or rotation of duties can prevent these frauds or lead to early detection. These measures will only be effective if someone else is doing the job while the usual employee is elsewhere.

INTERNAL ENVIRONMENT Confidentiality agreements and fidelity bond insurance Employees, suppliers, and contractors should be required to sign and abide by nondisclosure or confidentiality agreements. Key employees should have fidelity bond insurance coverage to protect the company against losses from fraudulent acts by those employees.

INTERNAL ENVIRONMENT In addition to the preceding policies, the company should seek prosecution and incarceration of hackers and fraud perpetrators Most fraud cases and hacker attacks go unreported. They are not prosecuted for several reasons. Companies fear: Public relations nightmares Copycat attacks But unreported fraud and intrusions create a false sense of security.

INTERNAL ENVIRONMENT Law enforcement officials and courts are busy with violent crimes and may regard teen hacking as “childish pranks.” Fraud is difficult, costly, and time-consuming to investigate and prosecute. Law enforcement officials, lawyers, and judges often lack the computer skills needed to investigate, prosecute, and evaluate computer crimes. When cases are prosecuted and a conviction obtained, penalties are often very light. Judges often regard the perps as “model citizens.”

INTERNAL ENVIRONMENT External influences
External influences that affect the control environment include requirements imposed by: FASB PCAOB SEC Insurance commissions Regulatory agencies for banks, utilities, etc.

OBJECTIVE SETTING Objective setting is the second ERM component.
It must precede many of the other six components. For example, you must set objectives before you can define events that affect your ability to achieve objectives

OBJECTIVE SETTING Top management, with board approval, must articulate why the company exists and what it hopes to achieve. Often referred to as the corporate vision or mission. Uses the mission statement as a base from which to set corporate objectives. The objectives: Need to be easy to understand and measure. Should be prioritized. Should be aligned with the company’s risk appetite.

OBJECTIVE SETTING Objectives set at the corporate level are linked to and integrated with a cascading series of sub-objectives in the various sub-units. For each set of objectives: Critical success factors (what has to go right) must be defined. Performance measures should be established to determine whether the objectives are met.

OBJECTIVE SETTING Objective-setting process proceeds as follows:
First, set strategic objectives, the high-level goals that support the company’s mission and create value for shareholders. To meet these objectives, identify alternative ways of accomplishing them. For each alternative, identify and assess risks and implications. Formulate a corporate strategy. Then set operations, compliance, and reporting objectives.

OBJECTIVE SETTING As a rule of thumb:
The mission and strategic objectives are stable. The strategy and other objectives are more dynamic: Must be adapted to changing conditions. Must be realigned with strategic objectives.

OBJECTIVE SETTING Operations objectives:
Are a product of management preferences, judgments, and style. Vary significantly among entities: One may adopt technology; another waits until the bugs are worked out. Are influenced by and must be relevant to the industry, economic conditions, and competitive pressures. Give clear direction for resource allocation—a key success factor.

OBJECTIVE SETTING Compliance and reporting objectives:
Many are imposed by external entities, e.g.: Reports to IRS or to EPA Financial reports that comply with GAAP A company’s reputation can be impacted significantly (for better or worse) by the quality of its compliance.

EVENT IDENTIFICATION Events are:
Incidents or occurrences that emanate from internal or external sources. That affect implementation of strategy or achievement of objectives. Impact can be positive, negative, or both. Events can range from obvious to obscure. Effects can range from inconsequential to highly significant.

EVENT IDENTIFICATION By their nature, events represent uncertainty:
Will they occur? If so, when? And what will the impact be? Will they trigger another event? Will they happen individually or concurrently?

EVENT IDENTIFICATION Management must do its best to anticipate all possible events—positive or negative—that might affect the company: Try to determine which are most and least likely. Understand the interrelationships of events. COSO identified many internal and external factors that could influence events and affect a company’s ability to implement strategy and achieve objectives.

EVENT IDENTIFICATION Some of these factors include: External factors:
Availability of capital; lower or higher costs of capital Lower barriers to entry, resulting in new competition Price movements up or down Ability to issue credit and possibility of default Concentration of competitors, customers, or vendors Presence or absence of liquidity Movements in the financial markets or currency fluctuations Rising or lowering unemployment rates Mergers or acquisitions Potential regulatory, contractual, or criminal legal liability Some of these factors include: External factors: Economic factors

Economic factors Natural environment Natural disasters such as fires, floods, or earthquakes Emissions and waste Energy restrictions or shortages Restrictions limiting development

Economic factors Natural environment Political factors Election of government officials with new agendas New laws and regulations Public policy, including higher or lower taxes Regulation affecting the company’s ability to compete

Changing demographics, social mores, family structures, and work/life priorities Consumer behavior that changes demand for products and services or creates new buying opportunities Corporate citizenship Privacy Terrorism Human resource issues causing production shortages or stoppages Some of these factors include: External factors: Economic factors Natural environment Political factors Social factors

New e-business technologies that lower infrastructure costs or increase demand for IT-based services Emerging technology Increased or decreased availability of data Interruptions or down time caused by external parties Some of these factors include: External factors: Economic factors Natural environment Political factors Social factors Technological factors

EVENT IDENTIFICATION Some of these factors include: Internal factors:
Infrastructure Inadequate access or poor allocation of capital Availability and capability of company assets Complexity of systems

Infrastructure Personnel Employee skills and capability Employees acting dishonestly or unethically Workplace accidents, health or safety concerns Strikes or expiration of labor agreements

Infrastructure Personnel Process Process modification without proper change management procedures Poorly designed processes Process execution errors Suppliers cannot deliver quality goods on time

Infrastructure Personnel Process Technology Insufficient capacity to handle peak IT usages Security breaches Data or system unavailability from internal factors Inadequate data integrity Poor systems selection/development Inadequately maintained systems

EVENT IDENTIFICATION Lists can help management identify factors, evaluate their importance, and examine those that can affect objectives. Identifying events at the activity and entity levels allows companies to focus their risk assessment on major business units or functions and align their risk tolerance and risk appetite.

EVENT IDENTIFICATION Companies usually use two or more of the following techniques together to identify events: Use comprehensive lists of potential events Often produced by special software that can tailor lists to an industry, activity, or process.

EVENT IDENTIFICATION Companies usually use two or more of the following techniques together to identify events: Use comprehensive lists of potential events Perform an internal analysis An internal committee analyzes events, contacting appropriate insiders and outsiders for input.

EVENT IDENTIFICATION Companies usually use two or more of the following techniques together to identify events: Use comprehensive lists of potential events Perform an internal analysis Monitor leading events and trigger points Appropriate transactions, activities, and events are monitored and compared to predefined criteria to determine when action is needed.

EVENT IDENTIFICATION Companies usually use two or more of the following techniques together to identify events: Use comprehensive lists of potential events Perform an internal analysis Monitor leading events and trigger points Conduct workshops and interviews Employee knowledge and expertise is gathered in structured discussions or individual interviews.

EVENT IDENTIFICATION Companies usually use two or more of the following techniques together to identify events: Use comprehensive lists of potential events Perform an internal analysis Monitor leading events and trigger points Conduct workshops and interviews Perform data mining and analysis Examine data on prior events to identify trends and causes that help identify possible events.

EVENT IDENTIFICATION Companies usually use two or more of the following techniques together to identify events: Use comprehensive lists of potential events Perform an internal analysis Monitor leading events and trigger points Conduct workshops and interviews Perform data mining and analysis Analyze processes Analyze internal and external factors that affect inputs, processes, and outputs to identify events that might help or hinder the process.

RISK ASSESSMENT AND RISK RESPONSE
The fourth and fifth components of COSO’s ERM model are risk assessment and risk response. COSO indicates there are two types of risk: Inherent risk The risk that exists before management takes any steps to control the likelihood or impact of a risk.

The fourth and fifth components of COSO’s ERM model are risk assessment and risk response. COSO indicates there are two types of risk: Inherent risk Residual risk The risk that remains after management implements internal controls or some other form of response to risk.

Companies should: Assess inherent risk Develop a response Then assess residual risk The ERM model indicates four ways to respond to risk: Reduce it The most effective way to reduce the likelihood and impact of risk is to implement an effective system of internal controls.

Companies should: Assess inherent risk Develop a response Then assess residual risk The ERM model indicates four ways to respond to risk: Reduce it Accept it Don’t act to prevent or mitigate it.

Companies should: Assess inherent risk Develop a response Then assess residual risk The ERM model indicates four ways to respond to risk: Reduce it Accept it Share it Transfer some of it to others via activities such as insurance, outsourcing, or hedging.

Companies should: Assess inherent risk Develop a response Then assess residual risk The ERM model indicates four ways to respond to risk: Reduce it Accept it Share it Avoid it Don’t engage in the activity that produces it. May require: Sale of a division Exiting a product line Canceling an expansion plan

Accountants: Help management design effective controls to reduce inherent risk. Evaluate internal control systems to ensure they are operating effectively. Assess and reduce inherent risk using the risk assessment and response strategy.

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Event identification The first step in risk assessment and response strategy is event identification, which we have already discussed. Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Estimate likelihood and impact Some events pose more risk because they are more probable than others. Some events pose more risk because their dollar impact would be more significant. Likelihood and impact must be considered together: If either increases, the materiality of the event and the need to protect against it rises. Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Identify controls Management must identify one or more controls that will protect the company from each event. In evaluating benefits of each control procedure, consider effectiveness and timing. Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring All other factors equal: A preventive control is better than a detective one. However, if preventive controls fail, detective controls are needed to discover the problem, and corrective controls are needed to recover. Consequently, the three complement each other, and a good internal control system should have all three. Similarly, a company should use all four levers of control. Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Estimate costs and benefits It would be cost-prohibitive to create an internal control system that provided foolproof protection against all events. Also, some controls negatively affect operational efficiency, and too many controls can make it very inefficient. Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring The benefits of an internal control procedure must exceed its costs. Benefits can be hard to quantify, but include: Increased sales and productivity Reduced losses Better integration with customers and suppliers Increased customer loyalty Competitive advantages Lower insurance premiums Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Costs are usually easier to measure than benefits. Primary cost is personnel, including: Time to perform control procedures Costs of hiring additional employees to effectively segregate duties Costs of programming controls into a system Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Other costs of a poor control system include: Lost sales Lower productivity Drop in stock price if security problems arise Shareholder or regulator lawsuits Fines and penalties imposed by governmental agencies Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring The expected loss related to a risk is measured as: Expected loss = impact x likelihood The value of a control procedure is the difference between: Expected loss with control procedure Expected loss without it Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Determine cost-benefit effectiveness After estimating benefits and costs, management determines if the control is cost beneficial, i.e., is the cost of implementing a control procedure less than the change in expected loss that would be attributable to the change? Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring In evaluating costs and benefits, management must consider factors other than those in the expected benefit calculation. If an event threatens an organization’s existence, it may be worthwhile to institute controls even if costs exceed expected benefits. The additional cost can be viewed as a catastrophic loss insurance premium. Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Expected Loss without control procedure = $800,000 x .12 = $96,000. Expected loss with control procedure = $800,000 x .005 = $4,000. Estimated value of control procedure = $96,000 - $4,000 = $92,000. Estimated cost of control procedure = $43,000 (given). Benefits exceed costs by $92,000 - $43,000 = $49,000. In this case, Hobby Hole should probably install the motion detectors. RISK ASSESSMENT AND RISK RESPONSE Let’s go through an example: Hobby Hole is trying to decide whether to install a motion detector system in its warehouse to reduce the probability of a catastrophic theft. A catastrophic theft could result in losses of $800,000. Local crime statistics suggest that the probability of a catastrophic theft at Hobby Hole is 12%. Companies with motion detectors only have about a .5% probability of catastrophic theft. The present value of purchasing and installing a motion detector system and paying future security costs is estimated to be about $43,000. Should Hobby Hole install the motion detectors?

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Implement the control or avoid, share, or accept the risk When controls are cost effective, they should be implemented so risk can be reduced. Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

Identify the events or threats that confront the company Estimate the likelihood or probability of each event occurring Risks that are not reduced must be accepted, shared, or avoided. If the risk is within the company’s risk tolerance, they will typically accept the risk. A reduce or share response is used to bring residual risk into an acceptable risk tolerance range. An avoid response is typically only used when there is no way to cost-effectively bring risk into an acceptable risk tolerance range. Estimate the impact of potential loss from each threat Identify set of controls to guard against threat Estimate costs and benefits from instituting controls Is it cost-beneficial to protect system Avoid, share, or accept risk No Yes Reduce risk by implementing set of controls to guard against threat

CONTROL ACTIVITIES The sixth component of COSO’s ERM model.
Control activities are policies, procedures, and rules that provide reasonable assurance that management’s control objectives are met and their risk responses are carried out.

CONTROL ACTIVITIES It is management’s responsibility to develop a secure and adequately controlled system. Controls are much more effective when built in on the front end. Consequently, systems analysts, designers, and end users should be involved in designing adequate computer-based control systems. Management must also establish a set of procedures to ensure control compliance and enforcement. Usually, the purview of the information security officer and the operations staff.

CONTROL ACTIVITIES It is critical that controls be in place during the year-end holiday season. A disproportionate amount of computer fraud and security break-ins occur during this time because: More people are on vacation and fewer around to mind the store. Students are not tied up with school. Counterculture hackers may be lonely.

CONTROL ACTIVITIES Generally, control procedures fall into one of the following categories: Proper authorization of transactions and activities Segregation of duties Project development and acquisition controls Change management controls Design and use of documents and records Safeguard assets, records, and data Independent checks on performance

CONTROL ACTIVITIES Proper authorization of transactions and activities
Management lacks the time and resources to supervise each employee activity and decision. Consequently, they establish policies and empower employees to perform activities within policy. This empowerment is called authorization and is an important part of an organization’s control procedures.

CONTROL ACTIVITIES Authorizations are often documented by signing initializing, or entering an authorization code. Computer systems can record digital signatures as a means of signing a document. Employees who process transactions should verify the presence of the appropriate authorizations. Auditors review transactions for proper authorization, as their absence indicates a possible control problem.

CONTROL ACTIVITIES Typically at least two levels of authorization:
General authorization Management authorizes employees to handle routine transactions without special approval. Special authorization For activities or transactions that are of significant consequences, management review and approval is required. Might apply to sales, capital expenditures, or write-offs over a particular dollar limit. Management should have written policies for both types of authorization and for all types of transactions.

CONTROL ACTIVITIES Segregation of duties
Good internal control requires that no single employee be given too much responsibility over business transactions or processes. An employee should not be in a position to commit and conceal fraud or unintentional errors. Segregation of duties is discussed in two sections: Segregation of accounting duties Segregation of duties within the systems function

CONTROL ACTIVITIES To learn a little about segregation of duties, let’s first meet Bill.

CONTROL ACTIVITIES Bill is in charge of a pile of the organization’s money—let’s say $1,000.

CONTROL ACTIVITIES Bill also keeps the books for that money. Ledger
$1,000 Bill also keeps the books for that money.

CONTROL ACTIVITIES Ledger $1,000 Bill has a date tonight, and he’s a little desperate to impress that special someone, so he takes $100 of the cash. (Thinks he’s only borrowing it, you know.)

CONTROL ACTIVITIES Ledger $900 Bill also records an entry in the books to show that $100 was spent for some “legitimate” purpose. Now the balance in the books is $900.

CONTROL ACTIVITIES How will Bill ever get caught at his theft? Ledger
$900 How will Bill ever get caught at his theft?

CONTROL ACTIVITIES Now let’s change the story. Bill is in charge of the pile of cash.

CONTROL ACTIVITIES But Mary keeps the books.
Ledger $1,000 But Mary keeps the books. This arrangement is a form of segregation of duties.

CONTROL ACTIVITIES Ledger $1,000 Bill gets in a pinch again and takes $100 of the organization’s cash.

CONTROL ACTIVITIES Ledger $1,000 How will Bill get caught?

CONTROL ACTIVITIES Segregation of accounting duties
Effective segregation of accounting duties is achieved when the following functions are separated: Authorization—Approving transactions and decisions. Recording—Preparing source documents; maintaining journals, ledgers, or other files; preparing reconciliations; and preparing performance reports. Custody—Handling cash, maintaining an inventory storeroom, receiving incoming customer checks, writing checks on the organization’s bank account. If any two of the preceding functions are the responsibility of one person, then problems can arise.

AUTHORIZATION FUNCTIONS
CONTROL ACTIVITIES CUSTODIAL FUNCTIONS Handling cash Handling inventories, tools, or fixed assets Writing checks Receiving checks in mail RECORDING FUNCTIONS Preparing source documents Maintaining journals, ledgers, or other files Preparing reconciliations Preparing performance reports EXAMPLE OF PROBLEM: A person who has custody of cash receipts and the recording for those receipts can steal some of the cash and falsify accounts to conceal the theft. SOLUTION: The pink fence (segregation of custody and recording) prevents employees from falsifying records to conceal theft of assets entrusted to them. AUTHORIZATION FUNCTIONS Authorization of transactions

EXAMPLE OF PROBLEM: A person who has custody of checks for transactions that he has authorized can authorize fictitious transactions and then steal the payments. SOLUTION: The green fence (segregation of custody and authorization) prevents employees from authorizing fictitious or inaccurate transactions as a means of concealing a theft. CONTROL ACTIVITIES CUSTODIAL FUNCTIONS Handling cash Handling inventories, tools, or fixed assets Writing checks Receiving checks in mail RECORDING FUNCTIONS Preparing source documents Maintaining journals, ledgers, or other files Preparing reconciliations Preparing performance reports AUTHORIZATION FUNCTIONS Authorization of transactions

EXAMPLE OF PROBLEM: A person who can authorize a transaction and keep records related to the transactions can authorize and record fictitious payments that might, for example, be sent to the employee’s home address or the address of a shell company he creates. SOLUTION: The purple fence (segregation of recording and authorization) prevents employees from falsifying records to cover up inaccurate or false transactions that were inappropriately authorized. CONTROL ACTIVITIES CUSTODIAL FUNCTIONS Handling cash Handling inventories, tools, or fixed assets Writing checks Receiving checks in mail RECORDING FUNCTIONS Preparing source documents Maintaining journals, ledgers, or other files Preparing reconciliations Preparing performance reports AUTHORIZATION FUNCTIONS Authorization of transactions

CONTROL ACTIVITIES In a system that incorporates an effective separation of duties, it should be difficult for any single employee to commit embezzlement successfully. But when two or more people collude, then segregation of duties becomes impotent and controls are overridden.

CONTROL ACTIVITIES Ledger $1,000 If this happens . . .

CONTROL ACTIVITIES Ledger $1,000 Then segregation of duties is out the window. Collusion overrides segregation.

CONTROL ACTIVITIES Employees can collude with other employees or with customers or vendors. The most frequent form of employee/vendor collusions include: Billing at inflated prices Performing substandard work and receiving full payment Payment for non-performance Duplicate billings Improperly funneling more work to or purchasing more goods from a colluding company

CONTROL ACTIVITIES The most frequent form of employee/customer collusions include: Unauthorized loans or insurance payments Receipt of assets or services at unauthorized discount prices Forgiveness of amounts owed Unauthorized extension of due dates

CONTROL ACTIVITIES Segregation of duties
Good internal control requires that no single employee be given too much responsibility over business transactions or processes. An employee should not be in a position to commit and conceal fraud or unintentional errors. Segregation of duties is discussed in two sections: Segregation of accounting duties Segregation of duties within the systems function

CONTROL ACTIVITIES Segregation of duties within the systems function
In a highly integrated information system, procedures once performed by separate individuals are combined. Therefore, anyone who has unrestricted access to the computer, its programs, and live data could have the opportunity to perpetrate and conceal fraud. To combat this threat, organizations must implement effective segregation of duties within the IS function.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Responsible for ensuring that the different parts of an information system operate smoothly and efficiently.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Ensures that all applicable devices are linked to the organization’s internal and external networks and that the networks operate continuously and properly.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Security management Ensures that all aspects of the system are secure and protected from internal and external threats.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Security management Change management Manages changes to the organization’s information system to ensure they are made smoothly and efficiently and to prevent errors and fraud.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Security management Change management Users Record transactions, authorize data to be processed, and use system output.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Security management Change management Users Systems analysts Help users determine their information needs and design systems to meet those needs.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Security management Change management Users Systems analysts Programming Use design provided by the systems analysts to write the computer programs for the information system.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Security management Change management Users Systems analysts Programming Computer operations Run the software on the company’s computers. Ensure that data are input properly, correctly processed, and needed output is produced.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Security management Change management Users Systems analysts Programming Computer operations Information systems library Maintains custody of corporate databases, files, and programs in a separate storage area.

CONTROL ACTIVITIES Authority and responsibility must be divided clearly among the following functions: Systems administration Network management Security management Change management Users Systems analysts Programming Computer operations Information systems library Data control Ensures that source data have been properly approved. Monitors the flow of work through the computer. Reconciles input and output. Maintains a record of input errors to ensure their correction and resubmission. Distributes system output.

CONTROL ACTIVITIES It is important that different people perform the preceding functions. Allowing a person to do two or more jobs exposes the company to the possibility of fraud. In addition to adequate segregation of duties, organizations should ensure that the people who design, develop, implement, and operate the IS are qualified and well trained. The same holds true for systems security personnel.

CONTROL ACTIVITIES Project development and acquisition controls
It’s important to have a formal, appropriate, and proven methodology to govern the development, acquisition, implementation, and maintenance of information systems and related technologies. Should contain appropriate controls for: Management review and approval User involvement Analysis Design Testing Implementation Conversion Should make it possible for management to trace information inputs from source to disposition and vice versa (the audit trail).

CONTROL ACTIVITIES Examples abound of poorly managed projects that have wasted large sums of money because certain basic principles of project management control were ignored.

CONTROL ACTIVITIES A multi-year strategic plan should align the organization’s information system with its business strategies and show the projects that must be completed to achieve long-range goals. Should address hardware, software, personnel, and infrastructure requirements. Each year, the board and top management should prepare and approve the plan and its supporting budget. Should be evaluated several times a year to ensure the organization can acquire needed components and maintain existing ones. The following basic principles of control should be applied to systems development in order to reduce the potential for cost overruns and project failure and to improve the efficiency and effectiveness of the IS: Strategic master plan

CONTROL ACTIVITIES A project development plan shows how a project will be completed, including: Modules or tasks to be performed Who will perform them Anticipated completion dates Project costs Project milestones should be specified—points when progress is reviewed and actual completion times are compared to estimates. Each project should be assigned to a manager and team who are responsible for its success or failure. At project completion, a project evaluation of the team members should be performed. The following basic principles of control should be applied to systems development in order to reduce the potential for cost overruns and project failure and to improve the efficiency and effectiveness of the IS: Strategic master plan Project controls

CONTROL ACTIVITIES The following basic principles of control should be applied to systems development in order to reduce the potential for cost overruns and project failure and to improve the efficiency and effectiveness of the IS: Strategic master plan Project controls Data processing schedule Data processing tasks should be organized according to a schedule to maximize the use of scarce computer resources.

CONTROL ACTIVITIES The following basic principles of control should be applied to systems development in order to reduce the potential for cost overruns and project failure and to improve the efficiency and effectiveness of the IS: Strategic master plan Project controls Data processing schedule Steering committee A steering committee should guide and oversee systems development and acquisition.

CONTROL ACTIVITIES The following basic principles of control should be applied to systems development in order to reduce the potential for cost overruns and project failure and to improve the efficiency and effectiveness of the IS: Strategic master plan Project controls Data processing schedule Steering committee System performance measurements To be evaluated properly, a system should be assessed with measures such as: Throughput (output per unit of time) Utilization (percent of time it is used productively) Response time (how long it takes to respond)

CONTROL ACTIVITIES The following basic principles of control should be applied to systems development in order to reduce the potential for cost overruns and project failure and to improve the efficiency and effectiveness of the IS: Strategic master plan Project controls Data processing schedule Steering committee System performance measurements Post-implementation review A review should be performed after a development project is completed to determine if the anticipated benefits were achieved. Helps control project development activities and encourage accurate and objective initial cost and benefit estimates.

CONTROL ACTIVITIES To simplify and improve systems development, some companies hire a systems integrator—a vendor who uses common standards and manages the development effort using their own personnel and those of the client and other vendors. Many companies rely on the integrator’s assurance that the project will be completed on time. Unfortunately, the integrator is often wrong. These third-party systems development projects are subject to the same cost overruns and missed deadlines as systems developed internally.

CONTROL ACTIVITIES Before third parties bid, provide clear specifications, including: Exact descriptions and definitions of the system Explicit deadlines Precise acceptance criteria Although it’s expensive to develop these specifications, it will save money in the end. When using systems integrators, companies should adhere to the same basic rules used for project management of internal projects. In addition, they should: Develop clear specifications

A sponsors committee should monitor third-party development projects.
Established by the CIO and chaired by the project’s internal champion. Should include department managers from all units that will use the system. Should establish formal procedures for measuring and reporting project status. Best approach is to: Divide project into manageable tasks. Assign responsibility for each task. Meet on a regular basis (at least monthly) to review progress and assess quality. CONTROL ACTIVITIES When using systems integrators, companies should adhere to the same basic rules used for project management of internal projects. In addition, they should: Develop clear specifications Monitor the systems integration project

CONTROL ACTIVITIES Change management controls
Organizations constantly modify their information systems to reflect new business practices and take advantage of information technology advances. Change management is the process of making sure that the changes do not negatively affect: Systems reliability Security Confidentiality Integrity Availability

CONTROL ACTIVITIES Design and use of adequate documents and records
Proper design and use of documents and records helps ensure accurate and complete recording of all relevant transaction data. Form and content should be kept as simple as possible to: Promote efficient record keeping Minimize recording errors Facilitate review and verification Documents that initiate a transaction should contain a space for authorization. Those used to transfer assets should have a space for the receiving party’s signature.

CONTROL ACTIVITIES Documents should be sequentially pre-numbered:
To reduce likelihood that they would be used fraudulently. To help ensure that all valid transactions are recorded. A good audit trail facilitates: Tracing individual transactions through the system. Correcting errors. Verifying system output.

CONTROL ACTIVITIES Safeguard assets, records, and data
When people consider safeguarding assets, they most often think of cash and physical assets, such as inventory and equipment. Another company asset that needs to be protected is information. According to the ACFE’s 2004 National Fraud Survey, theft of information made up only 17.3% of non-cash misappropriations; however, the median cost of an information theft was $340,000. This cost was 126% higher than the next most costly non-asset theft. (Equipment theft had a median cost of $150,000.)

CONTROL ACTIVITIES Many people mistakenly believe that the greatest risks companies face are from outsiders. However, employees pose a much greater risk when it comes to loss of data because: They know the system and its weaknesses better. They are better able to hide their illegal acts.

CONTROL ACTIVITIES Insiders also create less-intentional threats to systems, including: Accidentally deleting company data. Turning viruses loose. Trying to fix hardware or software without appropriate expertise (i.e., when in doubt, unplug it). These actions can result in crashed networks, corrupt data, and hardware and software malfunctions. Companies also face significant risks from customers and vendors that have access to company data.

CONTROL ACTIVITIES Many steps can be taken to safeguard both information and physical assets from theft, unauthorized use, and vandalism. Chapters 7 and 8 discuss computer-based controls. In addition, it is important to: Maintain accurate records of all assets Periodically reconcile recorded amounts to physical counts.

CONTROL ACTIVITIES Many steps can be taken to safeguard both information and physical assets from theft, unauthorized use, and vandalism. Chapters 7 and 8 discuss computer-based controls. In addition, it is important to: Maintain accurate records of all assets Periodically reconcile recorded amounts to physical counts Restrict access to assets Use restricted storage areas for inventories and equipment. Use cash registers, safes, lockboxes, and safe deposit boxes to limit access to cash, securities, and paper assets.

CONTROL ACTIVITIES Many steps can be taken to safeguard both information and physical assets from theft, unauthorized use, and vandalism. Chapters 7 and 8 discuss computer-based controls. In addition, it is important to: Maintain accurate records of all assets Periodically reconcile recorded amounts to physical counts Restrict access to assets Protect records and documents Use fireproof storage areas, locked filing cabinets, backup of files (including copies at off-site locations). Limit access to blank checks and documents to authorized personnel.

CONTROL ACTIVITIES Ledger $1,000 Let’s look at Bill and Mary again. Assume that Bill stole cash but Mary did NOT alter the books.

CONTROL ACTIVITIES Ledger $1,000 Can Bill’s theft be discovered if an independent party doesn’t compare a count of the cash to what’s recorded on the books?

CONTROL ACTIVITIES Ledger $1,000 Segregation of duties only has value when supplemented by independent checks.

CONTROL ACTIVITIES Internal checks to ensure that transactions are processed accurately are an important control element. These checks should be performed by someone independent of the party(ies) responsible for the activities.

CONTROL ACTIVITIES The following independent checks are typically used: Top-level reviews Management at all levels should monitor company results and periodically compare actual performance to: Planned performance as shown in budgets, targets, and forecasts Prior-period performance The performance of competitors

CONTROL ACTIVITIES The following independent checks are typically used: Top-level reviews Analytical reviews Examinations of relationships between different sets of data. EXAMPLE: If credit sales increased significantly during the period and there were no changes in credit policy, then bad debt expense should probably have increased also. Management should periodically analyze and review data relationships to detect fraud and other business problems.

CONTROL ACTIVITIES Check the accuracy and completeness of records by reconciling them with other records that should have the same balance. EXAMPLES: Bank reconciliations Comparing accounts payable control account to sum of subsidiary accounts. The following independent checks are typically used: Top-level reviews Analytical reviews Reconciliation of independently maintained sets of records

CONTROL ACTIVITIES The following independent checks are typically used: Top-level reviews Analytical reviews Reconciliation of independently maintained sets of records Comparison of actual quantities with recorded amounts Periodically, count significant assets and reconcile the count to company records. EXAMPLE: Annual physical inventory. High-dollar items and critical components should be counted more frequently.

CONTROL ACTIVITIES The following independent checks are typically used: Top-level reviews Analytical reviews Reconciliation of independently maintained sets of records Comparison of actual quantities with recorded amounts Double-entry accounting Ensure that debits equal credits.

CONTROL ACTIVITIES The following independent checks are typically used: Top-level reviews Analytical reviews Reconciliation of independently maintained sets of records Comparison of actual quantities with recorded amounts Double-entry accounting Independent review After one person processes a transaction, another reviews their work.

INFORMATION AND COMMUNICATION
The seventh component of COSO’s ERM model. The primary purpose of the AIS is to gather, record, process, store, summarize, and communicate information about an organization. So accountants must understand how: Transactions are initiated Data are captured in or converted to machine-readable form Computer files are accessed and updated Data are processed Information is reported to internal and external parties

Accountants must also understand the accounting records and procedures, supporting documents, and specific financial statement accounts involved in processing and reporting transactions. The preceding items facilitate an audit trail which allows for transactions to be traced from origin to financial statements and vice versa.

According to the AICPA, an AIS has five primary objectives: Identify and record all valid transactions. Properly classify transactions. Record transactions at their proper monetary value. Record transactions in the proper accounting period. Properly present transactions and related disclosures in the financial statements.

How to safeguard information and physical assets: Create and enforce appropriate policies and procedures. Maintain accurate records of all assets. Restrict access to assets. Protect records and documents.

Accounting systems generally consist of several accounting subsystems, each designed to process transactions of a particular type. Though they differ with respect to the type of transactions processed, all accounting subsystems follow the same sequence of procedures, referred to as accounting cycles. The five major accounting cycles and their related control objectives and procedures are detailed in Chapters 10–14.

MONITORING The eighth component of COSO’s ERM model.
Monitoring can be accomplished with a series of ongoing events or by separate evaluations.

MONITORING Key methods of monitoring performance include:
Perform ERM evaluation Implement effective supervision Use responsibility accounting Monitor system activities Track purchased software Conduct periodic audits Employ a computer security officer, a Chief Compliance Officer, and security consultants Engage forensic specialists Install fraud detection software Implement a fraud hotline

Perform ERM evaluation Implement effective supervision Use responsibility accounting Monitor system activities Track purchased software Conduct periodic audits Employ a computer security officer and security consultants Engage forensic specialists Install fraud detection software Implement a fraud hotline

MONITORING Perform ERM evaluation
Can measure ERM effectiveness through a formal evaluation or through a self-assessment process. A special group can be assembled to conduct the evaluation or it can be done by internal auditing.

MONITORING Implement effective supervision Involves:
Training and assisting employees; Monitoring their performance; Correcting errors; and Safeguarding assets by overseeing employees with access. Especially important in organizations that: Can’t afford elaborate responsibility reporting; or Are too small for segregation of duties.

MONITORING Use responsibility accounting Includes use of:
Budgets, quotas, schedules, standard costs, and quality standards; Performance reports that compare actual with planned performance and highlight variances; and Procedures for investigating significant variances and taking timely actions to correct adverse conditions.

MONITORING Monitor system activities
Risk analysis and management software packages are available to: Review computer and network security measures; Detect illegal entry into systems; Test for weaknesses and vulnerabilities; Report weaknesses found; and Suggest improvements.

MONITORING Cost parameters can be entered to balance acceptable levels of risk tolerance and cost-effectiveness. Software is also available to monitor and combat viruses, spyware, spam, pop-up ads, and to prevent browsers from being hijacked. Also helps companies recover from frauds and malicious actions and restore systems to pre-incident status.

MONITORING System transactions and activities should be recorded in a log which indicates who accessed what data, when, and from which terminal. Logs should be reviewed frequently to monitor system activity and trace any problems to their source. Data collected can be used to: Evaluate employee productivity; Control company costs; Fight corporate espionage and other attacks; and Comply with legal requirements.

MONITORING Companies that monitor system activities need to ensure they do not violate employee privacy rights. Employers cannot discreetly observe communications of employees when those employees have a “reasonable expectation of privacy.” Employers must therefore ensure that employees realize their business communications are not “private.” One way to accomplish that objective is to have written policies that employees agree to in writing which indicate: The technology employees use on the job belongs to the company. s received on company computers are not private and can be read by supervisory personnel. Employees should not use technology in any way to contribute to a hostile work environment.

MONITORING Track purchased software
The Business Software Alliance (BSA) aggressively tracks down and fines companies who violate software license agreements. To comply with copyrights, companies should periodically conduct software audits to ensure that. There are enough licenses for all users; and The company is not paying for more licenses than needed. Employees should be informed of the consequences of using unlicensed software.

MONITORING Conduct periodic audits
To monitor risk and detect fraud and errors, the company should have periodic: External audits Internal audits Special network security audits Auditors should test system controls and browse system usage files looking for suspicious activities (discussed in Chapter 9).

MONITORING Again, care should be exercised that employees’ privacy rights are not violated. Therefore, inform employees that auditors will conduct random surveillance, which: Avoids privacy violations Creates a “perception of detection” that can deter crime and reduce errors

MONITORING Internal auditing involves:
Reviewing the reliability and integrity of financial and operating information. Providing an appraisal of internal control effectiveness. Assessing employee compliance with management policies and procedures and applicable laws and regulations. Evaluating the efficiency and effectiveness of management.

MONITORING Internal audits can detect: Excess overtime
Under-used assets Obsolete inventory Padded expense reimbursements Excessively loose budgets and quotas Poorly justified capital expenditures Production bottlenecks

MONITORING Internal auditing should be organizationally independent of the accounting and operating functions. The head should report to the audit committee of the board of directors rather than to the controller or CFO.

MONITORING Employ a computer security officer and computer consultants
The computer security officer (CSO) is in charge of AIS security Should be independent of the IS function Should report to the COO or CEO Many companies also use outside computer consultants or in-house teams to test and evaluate their security procedures and computer systems.

MONITORING Engage forensic specialists
Forensic accountants specialize in fraud detection and investigation. Now one of the fastest growing areas of accounting due to: SOX SAS-99 Boards of Directors demanding that forensic accounting be an ongoing part of the financial reporting and corporate governance process.

MONITORING Most forensic accountants are CPAs and may have received special training with the FBI, CIA, or other law enforcement agencies. In particular demand are those with the necessary computer skills to ferret out and combat fraudsters who use sophisticated technology to perpetrate their crimes. The Association of Certified Fraud Examiners (ACFE) has created a professional certification program for fraud examiners.

MONITORING Management may also need to call on computer forensic specialists for help. They assist in discovering, extracting, safeguarding, and documenting computer evidence so that its authenticity, accuracy, and integrity will not succumb to legal challenges.

MONITORING Common incidents investigated by computer forensic experts include: Improper internet usage Fraud Sabotage Loss, theft, or corruption of data Retrieving information from s and databases that users thought they had erased Determining who performed certain actions on a computer

MONITORING Install fraud detection software
People who commit fraud tend to follow certain patterns and leave behind clues. Software has been developed to seek out these fraud symptoms. Some companies employ neural networks (programs that mimic the brain and have learning capabilities), which are very accurate in identifying suspected fraud. For example, if a husband and wife were each using the same credit card in two different stores at the same time, a neural network would probably flag at least one of the transactions immediately as suspicious. These networks and other recent advances in fraud detection software are significantly reducing the incidences of credit card fraud.

MONITORING Implement a fraud hotline
People who witness fraudulent behavior are often torn between conflicting feelings. They want to protect company assets and report fraud perpetrators. But they are uncomfortable in the whistleblower role and find it easier to remain silent. They are particularly reluctant to report if they know of others who have suffered repercussions from doing so.

MONITORING SOX mandates that companies set up mechanisms for employees to anonymously report abuses such as fraud. An effective way to comply with the law and resolve employee concerns is to provide access to an anonymous hotline. Anonymous reporting can be accomplished through: Phone lines Web-based reporting Anonymous s Snail mail

MONITORING Outsourcing is available through a number of third parties and offers several benefits, including: Increased confidence on the part of employee that his/her report is truly anonymous. 24/7 availability. Often have multilingual capabilities—an important plus for multinational organizations. The outsourcer may be able to do follow up with the employee if additional information is needed after the initial contact. The employee can be advised of the outcome of his report. Low cost.

MONITORING A downside to anonymous reporting mechanisms is that they will produce a significant amount of petty or slanderous reports that do not require investigation. The ACFE’s 2004 Report to the Nation indicates that companies without fraud hotlines had median fraud losses that were 140% higher than companies that had fraud hotlines.

SUMMARY In this chapter, you’ve learned about basic internal control concepts and why computer control and security are so important. You’ve learned about the similarities and differences between the COBIT, COSO, and ERM control frameworks. You’ve learned about the major elements in the internal control environment of a company and the four types of control objectives that companies need to set. You’ve also learned about events that affect uncertainty and how these events can be identified. You’ve explored how the Enterprise Risk Management model is used to assess and respond to risk, as well as the control activities that are commonly used in companies. Finally, you’ve learned how organizations communicate information and monitor control processes.

Control and Accounting Information Systems

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