Recommendation For An Effective Continuous Audit Process ..1
Recommendation For An Effective Continuous Audit Process ..1
Recommendation For An Effective Continuous Audit Process ..1
Continued in page 2
Page 2
[The Prodigy Group] By using data-driven indicators of risk and electronic testing of controls, IT auditors can
provide audit committees and senior management with independent assurance that control
Singapore – (65) 6221 2810 systems are working effectively and risk is being managed. Furthermore, continuous
Hong Kong – (852) 2815 5606 auditing helps IT-savvy auditors to:
Malaysia – (60) (3) 2283 5050
Indonesia – (62) (21) 4288 3120 Develop a dynamic risk-based plan by assessing changing levels of risk on an ongoing
basis
[Email: [email protected]] Support the scope and objectives of individual audits by providing the audit team with
a better understanding of the materiality and nature of the transactions being
performed
Find us on the Web: Assess levels of compliance by performing detailed testing of controls
[www.prodigy-group.com] Identify potential fraud, waste, and abuse by brainstorming fraud risks and the
development of data-support audit tests
Continuous auditing consists of two main components — continuous risk assessment and
continuous control assessment. Below is a description of each. Continuous risk
assessments refer to audit activities that identify and evaluate companywide risk levels by
examining trends and comparisons within a single process or system. These processes are
then compared to their past performance and other business systems. For example,
product line performance is compared to previous-year results and also is assessed within
the context of one plant's performance versus the others.
While management is responsible for developing and maintaining a system that identifies
and mitigates risk, The Institute of Internal Auditors' (The IIA's) states that auditors should
assist the organisation by identifying and evaluating significant exposures to risk and by
contributing to the improvement of risk management and control systems.
Continued in page 3
[The Prodigy Group] have on future audit reports and findings. Finally, auditors must be prepared to manage and
report the results obtained. For instance, auditors need to consider:
Singapore – (65) 6221 2810
Hong Kong – (852) 2815 5606 How often will continuous audit tests be run?
Malaysia – (60) (3) 2283 5050 How will the company deal with anomalies?
Indonesia – (62) (21) 4288 3120 What reporting mechanisms will be developed?
What will be audit's and management's response?
[Email: [email protected]]
Other Considerations
While technology has made data easier to access than before, and computing power makes
Find us on the Web: real-time analysis increasingly feasible, technical hurdles remain. In particular, information to
[www.prodigy-group.com] be audited must be generated by reliable systems, the continuous audit process must be
highly automated, and an effective link between the auditor's system and that of the audited
entity must exist. The CAE must ensure that continuous auditing is adopted as an integrated,
consistent approach to a controls-based, risk-oriented audit plan.
In addition, the audit department will have to document, develop, and maintain the technical
competencies and technology necessary to access, manipulate, and analyze the data
contained in disparate information systems. To overcome these challenges, IT auditors must
understand the business process sufficiently well before defining the appropriate analytical
techniques and identifying potential risk and key control points. IT auditors also should have
the ability to gain access to relevant data in a timely manner and be capable of normalising
data from disparate systems across the organization.
In addition, the audit department will have to document, develop, and maintain the technical
competencies and technology necessary to access, manipulate, and analyze the data
contained in disparate information systems.
To overcome these challenges, IT auditors must understand the business process sufficiently
well before defining the appropriate analytical techniques and identifying potential risk and key
control points. IT auditors also should have the ability to gain access to relevant data in a
timely manner and be capable of normalising data from disparate systems across the
organization. The aim is to identify the most accurate and effective data source and control
points to perform continuous audit tests and analyses. This also will enable auditors to
perform a comprehensive set of tests and analyses that address key control points and risk
areas, as well as report results in a timely manner. Doing this will require auditors to
understand the nature of the tests or analyses used to:
Finally, IT auditors will have to manage and respond to continuous audit results and determine
their appropriate use, follow-up, and reporting mechanisms. For instance, auditors will have to
identify whether appropriate action is taken on the findings reported to management and if
continuous audit results are considered by management when assessing activities.
Moving Forward
Management's use of continuous audit procedures will help determine if controls are effective
and the information produced for decision-making is relevant and reliable. An important
benefit of continuous auditing is that instances of error and fraud are reduced significantly,
operational efficiency is increased, and bottom-line results are improved through a
combination of cost savings and a reduction in overpayments. Additionally, organisations that
use continuous auditing often find that they achieve a rapid return on investment. When using
continuous auditing, internal auditors need to address the end-to-end business process and IT
controls present in business activities. The reliability of business systems and transactional
data is paramount not only to the internal control framework and the integrity of financial
reporting, but also to the efficiency of business operations. Thus, ensuring the reliability,
integrity, and availability of business systems and data should be a key objective for IT
auditors and senior managers.
Finally, continuous auditing can help internal auditors and senior management identify and
assess risk at many levels throughout the organisation. At a higher level, continuous auditing
should take place as part of the annual planning process. Continuous audit results should be
used when determining the risk-based audit plan and be made available to the audit team
leader as a starting point for the audit. During the conduct of individual audits, continuous
auditing can be used to further examine risks. As part of the planning and implementation
phases, specific key controls can be tested, such as separation of duties, while comparisons
can be used to identify operation improvement areas. After the audit, data-driven indicators
can be used to determine if improvements were realised and whether audit recommendations
were implemented and had the desired effect.
Page 5
But do you know in the Any commands that you performed from now on will be
context of the command log, recorded onto the new session log file (in the example
sessions give you the ability above, the new activities will be log onto Accounting Audit
to label a series of Session).
commands for historical
purposes? When you start a
session, you can give it a
descriptive name. When you
later review your log, you can
easily see the commands in
the session, and the
descriptive name reminds
you why you performed the
commands.
The top 20% of participants in the study spent 29 US cents for each US$1,000 of revenue
on budgeting, planning, and forecasting, making it their highest cost. They spent just 25
US cents on cost accounting, controls, and cost management, and 24 US cents on
evaluating and managing financial performance. The worst performers spent the most on
controls and cost management (US$2.47) and still spent US$1.81 on planning and
US$2.08 on managing financial performance.
“High cost does not equal effectiveness,” says Lisa Higgins, chief operating officer of
APQC and co-author of the report. She says companies that spend a higher percentage
up front on B&P have lower overall costs across the board in finance and faster cycle
times.
For example, the top performers complete the budget cycle in 30 days, while the bottom
20% take 90 days. High performers are also more likely to use rolling forecasts and link
the budgeting process to strategy and compensation. Of course, higher spending on
controls and cost management is often a symptom of deeper problems rather than a
cause of them. Companies that spend more on planning probably have the luxury of
doing so because their financial house is already in order.
Continued in page 6
Page 6
[Email: [email protected]]
Over the past few years, most large organisations have expended a great deal of effort in
complying with new legislation that has been introduced in response to a spate of corporate
collapses resulting from fraudulent and corrupt behaviour. This has included significant
investment in corporate governance, operational risk management and corporate responsibility
frameworks.
The result is that there is a greater understanding of the processes and controls that mitigate
fraud and corruption. However, once the regulatory requirements have been satisfied, that has
usually been the extent of the fraud and corruption prevention strategy, particularly if the
organisation has not suffered any prior large frauds. As a number of banks have recently
discovered, focusing purely on processes and controls is not enough to prevent fraud. Even
after expending all the effort to comply with the legislation, fraudsters have still been able to
work undetected over long periods of time. Those organisations have found that there are
other elements of a strategy that need to be in place if they are to avoid the unpleasant effects
of fraud and corruption.
They have realised that they have not invested enough time and effort in developing one of the
most potent anti-fraud and corruption weapons – their own employees. To implement an
effective strategy, the organisation needs to empower employees to prevent fraud and
corruption. The first step in this process is to make senior management aware that investing in
an anti-fraud and corruption culture can help to avoid the unpleasant after effects.
Continued in page 7
Page 7
[The Prodigy Group] Not having a sponsor can lead to the program not being taken seriously and people being too
scared to report potential problems for fear of retribution. Often a joint sponsorship team
Singapore – (65) 6221 2810 involving one or more executive board members is the preferred and stronger solution. The
training program should demystify fraud and corruption for the participants, help their
Hong Kong – (852) 2815 5606
Malaysia – (60) (3) 2283 5050 understanding of the methods used against the company by different opponents, as well as
Indonesia – (62) (21) 4288 3120 teach them how to defend against fraud and how to spot and deal with the red flags.
Participants should be encouraged to recognise the loopholes from the perspective of a
potential criminal, and the way that psychology may be used to fool an honest person.
[Email: [email protected]]
Example
An employee with a severe gambling problem used a ballpoint pen containing erasable ink to
Find us on the Web: make out a spurious cheque to a genuine payee. He waited until his manager had an office
[www.prodigy-group.com]
full of people before knocking on the door and requesting an ‘urgent’ signature. The
manager, whose mind was on other urgent issues, verified that the cheque was made out to
the expected payee and signed it without querying the supporting documentation. After this,
the employee rubbed out the payee name, inserted his own name and cashed the cheque.
He used this technique to raise dozens of cheques over a number of years and obtained
more than $5 million. The fraud only came to light when he went on holiday and a colleague
discovered how he had been hiding discrepancies in the books. Equally important is to train
managers to detect when employees may have problems that could potentially lead to fraud.
For example, several recent frauds have involved employees who had developed gambling
addictions as a result of depression. To feed their addictions, they had resorted to stealing
from their employer. In each case, the employees had displayed changes to their behaviour
and other red flags, which colleagues had either ignored, or not recognised the significance
of. Specific training should be provided on how to identify and deal with employees who may
be suffering from depression.
Empowering employees
Having trained employees to spot the red flags or fraud and corruption, it is then essential to
empower employees to report concerns. Usually, the first reporting line is to their direct line
manager. If that is not feasible – for example, when they have suspicions about their line
manager – the organisation should implement a whistle blowing procedure to provide a
confidential and anonymous route for employees. There is a legal requirement in some
countries that have adopted whistle blowing legislation for the whistleblower to be protected
from any adverse reaction by the company or directors following their disclosure, providing
that the disclosure was not malicious. However, in spite of improvements in legislation, it is
still a brave employee who raises issues involving the CEO or other executive director.
Employees working for an executive who is a corporate psychopath may find it very difficult to
come up with solid proof even if suspicions are raised about behaviour or lifestyle, or if there
is evidence in transactions or documents. The corporate psychopath is an expert at
manipulating situations, evidence and people and will have built up a powerful network of
supporters, both executive and non-executive. The employee who raises concerns can be
sidelined, but not in a manner where they could successfully argue that they had been
unfairly discriminated against as a result of them blowing the whistle. Designing and
implementing a whistle blowing reporting line, the sponsors together with independent
executives – for example, on the audit committee – should include a procedure for dealing
with those extreme cases where an employee or external party may raise issues implicating
the CEO or other director. Employees are then empowered to report concerns at every level
of the organisation without the fear of retribution.
For example, element 1 (Tone at the Top) explores the role of senior management in setting
the ‘tone at the top’ and how the message that fraud and corruption will not be tolerated is
communicated throughout the organisation. It is then further divided into eight sub-elements:
policy; quality of policy; fraud and corruption resistance management strategy; stakeholder
engagement; management representative; operational risk management; existence of
relevant standards and procedures; and senior management participation.
Continued in page 9
Page 9
The following statistics about fraud and white-collar crime are featured in the Association of
Certified Fraud Examiners’ Report to the Nation. The Report contains a wealth of
information about the causes of fraud, the direct and indirect costs of occupational fraud
and abuse, and the methods by which employees and other insiders commit fraud. Fraud
and abuse costs U.S. organizations more than $400 billion annually.
• The average organization loses more than $9 per day per employee to fraud and
abuse.
• The average organization loses about 6% of its total annual revenue to fraud and
abuse committed by its own employees.
• The typical perpetrator is a college-educated white male.
• Men commit nearly 75% of the offenses.
• Losses caused by managers are four times those caused by employees.
• Median losses caused by executives are 16 times those of their employees.
• The most costly abuses occur in organizations with less than 100 employees.
Let’s break OREA down this a little further to get a better view of some of the specific
operational attributes:
Plan
Establish policy, objectives, targets, processes and procedures for managing operational
risks to deliver results in accordance with the organisations business objectives.
Do
Implement and operate the policy, controls, processes and procedures.
Check
Assess and measure in applicable areas while reporting results to management for
review.
Act
Take corrective and preventive actions based on results to continually improve the OREA
framework.
Operational risk management is getting the attention of organizations outside of the major
banks at a rapid pace. Board of directors in any industry will soon realize that the
successful CEO of the future will be a master of building a culture with effective
operational risk management systems at its core.
Page 10
[Email: [email protected]]
Interested to be on our mailing list for our next Hong Kong seminar? Email us at
[email protected]
Page 11
Onsite specialised workshops are also available. Kindly contact [email protected] for more information
The Prodigy Group is a total solution provider offering extensive solutions on Audit & Compliance, Risk Management,
Financial Management and Security Management to financial executives, audit professionals, fraud investigators, risk
managers, business analysts, IT professionals and senior executives. Through the experiences and expertise of our
consultants, our solutions developed have been proven and tested in many established organisations, giving our clients
confidence in the reliability, accuracy, and integrity of the data underlying the increasingly complex business operations.
Integrating market-leading software, Prodigy facilitates our clients in managing commitments and obligations better and
hence improved their internal business processes. Transformed around the themes of simplicity and usability, our solution
can be applied extensively throughout the organisation, be it for financial management, anti-money laundering, data
forensics, performance analysis, management reporting and so forth, providing organisations with the in-depth analysis
and foresight needed to overcome the complex challenges ahead and to Prodigy's overarching goal of performance with
integrity.