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    Christine Doxey
    Your Roadmap for Implementing an Internal Controls Program
    Topic posted July 16, 2019 by Christine DoxeyRed Ribbon: 250+ Points, tagged Advanced Controls, Compliance, Financial Reporting Compliance, Financial Transactions, Financials, Fraud, Governance, GRC, Risk Management, Sarbanes Oxley 
    Your Roadmap for Implementing an Internal Controls Program
    In my previous posts, I wrote about segregation of duties (SoD), risk based and compensating controls. This post provides the suggested steps for an internal controls roadmap.

    We’ve defined internal controls as a critical component throughout business strategies, operations, and processes.  Operationally effective controls are the linchpin to assure that an organization can reliably achieve objectives while addressing uncertainty and acting with integrity. Where do we start the internal controls journey and how do we implement a strong internal controls program?

    Many organizations take an approach to internal control management that has defined intersections with risk, compliance, and audit processes and use a set of standards.  But typically, all organizations face the following challenges with building and maintaining an internal controls program.

    • Providing an integrated strategy and view of financial and operational controls across the organization.
    • Defining a common language for risk and control.
    • Increasing confidence in ongoing risk coverage throughout all business processes.
    • Establishing Overall Responsibility for a company’s internal controls program to ensure consistency and to avoid duplication of effort.
    • Capturing business changes with updated and changing controls.
    • Combining finance and operational control teams and revamping processes to address a controls weakness.
    • Prioritizing the key controls for a business process that can truly mitigate risk.
    • Managing the human element in controls management.
    • Expanding and reacting to the ongoing regulatory requirements for internal control management.
    • Addressing a lack of resources while being tasked with more internal control responsibilities across controls.
    • Keeping controls aligned with business processes and a changing environment.
    • Implementing a system and technology to manage all controls across the organization.
    • Developing Transparency, reporting, and monitoring
    • Integrating controls into daily workflow particularly when staff transitions occur.

    So how does a company establish a roadmap to build an internal controls program to address these challenges?  Here are some steps to consider when establishing or enhancing your internal controls program.

    1. Define the Organization and Process Context: For most organizations, inefficiencies from an internal controls program fragmentation are so great that huge savings are possible by taking the simple step of eliminating silos and operating on a common context and structure with well-defined responsibilities. Which business process is your focus? Which process has a known control weakness, an identified audit finding or a detected fraudulent activity? The outcome of these efforts will enable an organization to:
    • Establish priorities and focus of coverage. 
    • Coordinate planning across all business units.
    • Eliminate gaps and duplication in coverage.
    • Decrease time spent by business process owners.
    • Increase ability to spot control issues and trends as they develop.
    • Utilize a single strategy and methodology for risk mitigation.
    1. Establish a Common Language for Risks and Controls: Without a standard naming convention or common methodology for determining or classifying risks and controls, business process owners are unable to share information. The benefits of utilizing a common language for risks and controls include:
    • Improved reporting throughout the organization.
    • Audit and control issues are embedded in your program and are promptly assigned and corrected. 
    • Consistent coverage—all risks are considered but there is a focus on the risk of material misstatement.
    • Improved business performance—risks explain performance gaps.
    • Better decision making—decisions are risk based.
    • Less external oversight and audits—controls are standardized using a common methodology.
    1. Implement a Consistent Reliable Methodology: Without a consistent methodology for your internal controls program, the cost of controls can be expenses with incomplete coverage and inaccurate results. Examples of a consistent methodology include:
    • The top-down risk criteria is established with consistent risk identification.
    • The risks are properly accessed by appropriate internal controls.
    • The risks that require a response are identified.
    • The risk responses that require remediation are prioritized.
    1. Focus on Transparency, Reporting and Monitoring: All information on the status of risks and controls should be available for continuous reporting. If implemented effectively, communication between management and the board of directors is in place with a focus on risk mitigation and the achievement of business objectives.  The benefits of a consistent and disciplined reporting structure include:
    • Availability of accurate and consistent reports.
    • Positive knowledge and reporting of risks and controls across the company.
    • Information sharing across business processes.
    • Confidence of the reliability of all risk and control information.
    1. Leverage Technology: By eliminating information silos and redundant data entry, and taking a unique holistic approach to regulatory challenges, technology provides greater efficiency, improves collaboration, and reduces the time and resource costs.  Additional benefits that can be gained by utilizing a defined technology solution for internal controls include:
    • A single universe of all risk and controls data called "The Internal Controls Universe."
    • Elimination of duplicate documentation. 
    • The implementation of a controls self-assessment process.
    • More processes, risks, controls can be assessed and properly prioritized.
    • Increase in management accountability.
    • Consolidated and reliable reporting.
    • The ability to produce metrics and analytics for your internal controls program.

    In conclusion, the success of an internal controls strategy is dependent upon communication, well-defined roles and responsibilities, standards of internal control, technology and reporting. To address the challenges of a viable and ongoing internal controls program, standards of internal control are available.

     If you have questions about these standards or the implementation of an internal controls program, please post a comment below.