DEFENSE IN DEPTH Collaboration Among Risk Management, Internal Audit and Compliance SEPTEMBER 9, 2013
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1 DEFENSE IN DEPTH Collaboration Among Risk Management, Internal Audit and Compliance SEPTEMBER 9, 2013
2 Speaker Chief Operating Officer, CaseWare RCM Over 20 years experience in IT audit, data analytics and forensics Previously at Ernst & Young
3 CaseWare International Founded in 1988 An industry leader in providing technology solutions for finance, accounting, governance, risk and audit professionals Over 400,000 users of our technologies across 130 countries and 16 languages Customers include Fortune 500 and Global 500 companies
4 Today s Topics 1. The Three Lines of Defense Model 2. Continuous Controls Monitoring (CCM) 3. Case Studies of CCM at Each Line of Defense 4. Q & A
5 THE THREE LINES OF DEFENSE MODEL
6 Three Lines of Defense Model
7 1 st Line of Defense
8 1 st Line of Defense OPERATIONAL MANAGEMENT Own and manage risks Design and implement internal controls Responsible for maintaining effective controls
9 2 nd Line of Defense
10 2 nd Line of Defense RISK MANAGEMENT & COMPLIANCE Help build and monitor first line of defense Ensure compliance with regulations Financial risks and reporting requirements Identify changes in risk appetite
11 3 rd Line of Defense
12 3 rd Line of Defense INTERNAL AUDIT Provide senior management with assurance Monitors the effectiveness of the first and second lines of defense Independent
13 Coordinating the Three Lines
14 CONTINUOUS CONTROLS MONITORING (CCM)
15 What is CCM? An audacious vision for CCM: Know the state of any control in the business Resolve identified breaches before impact Provide an unparalleled ROI
16 The Importance of Monitoring COSO Guidance (effective controls systems must include monitoring)
17 Role of CCM Independent monitoring of automated and partially automated controls Continuous detection of breaches Transparency in detection and remediation Address IT concerns Collaborative approach to timely remediation
18 An Example RISK: Invoices may not be valid and/or properly authorized CONTROL ACTIVITY: Matching invoices to goods receipt OWNER: Category Management METHOD: Partially Automated TYPE: Preventative FREQUENCY: Recurring COSO COMPONENT: Control Activities
19 Properties of the CCM Test FREQUENCY: Daily DETECT: Any non-compliance over and below the threshold ASSIGNMENT: Category Management DEADLINE: Resolve same day EVIDENCE: Due diligence performed on those over the threshold and any other exceptions detected VALUE: Ensure that the control effectiveness is sustained at a high level
20 CCM at Each Lines of Defense Effectively monitor internal controls at the 1 st and 2 nd lines of defense Allows the 3 rd line of defense to be confident in its assurance role Create a remediation process that minimizes the impact of a control breakdown Provide evidence of due diligence for external auditors and regulators
21 CASE STUDIES OF CCM AT EACH LINE OF DEFENSE
22 1 st Line of Defense
23 Canadian Energy Company since 1917 Third largest in Ontario Over 200,000 residential and commercial customers Provides electrical infrastructure design, construction, operations support and maintenance.
24 Reputational Risks
25 Financial Risks
26 Verification of Bills Reputational risk is the primary concern Was using an in-house MS Excel system to verify the accuracy of bills Upgraded to smart meters in 2009 Challenges Took 5 hours to process a batch of bills Exceptions manually circulated by Impossible to track resolution Labour intensive to make changes
27 The CCM Solution Independently calculate bills and identify inaccuracies Extract data from other sources not just billing system Sent exceptions in XML format to bill print system for those bills not to be printed Engaged users in the Billing Department to resolve issues Validate corrections made in core systems Maintain history of exceptions and actions taken to resolve them
28 Results Has not had a single public incident Accuracy of billing improved significantly Billing anomalies automatically distributed Bills verified in less than 5 minutes (not 5 hours) Bills sent out same day improving cash flow Evidence retained for regulators/auditors Labor-intensive manual reviews were eliminated
29 2 nd Line of Defense
30 Christies Auction House Founded in 1766 by James Christie 53 offices in 32 countries Prices range from $200 to $80M
31 Challenges Risk and Compliance Group mandated to review 100% of transactions Primary area of concern is client accounting Needed to ensure that fees and charges are accurate Needed to involve the business in timely remediation
32 The CCM Solution Implemented for 40 key controls Monitor transactions near real time Covering multiple locations (UK and New York) Phase I started in Risk and Compliance then rolled out to the business.
33 Phase II Customer Screening Important to meet regulatory requirements AML and KYC Compliance Integrate with World-Check sanction list data for screening
34 3 rd Line of Defense
35 Metcash A leading marketing and distribution company Operating in the grocery, liquor and hardware wholesale industries Turnover of $12Bn 5,000+ Employees Market cap $3.2Bn
36 Challenges Several disparate systems Many audit scripts ing exceptions in Excel SAP generating many exception reports Business struggling to cope
37 The CCM Solution All analytics built in-house by CM Team Covered 30 key controls to start CCM implemented for Purchase to Payment in Phase I Expanded to the retail business processes in Phase II Adopted as central exception management system (including SAP reports)
38 Results Started in Internal Audit Rolled out to business users Use action/reason codes to facilitate root cause analysis Daily examination of processes First year results: 5.5 billion transaction covered $1.8M in savings
39 Conclusion Internal Control effectiveness is positively impacted by collaboration. That covers collaboration at all three levels. CCM is a compelling vehicle to facilitate a collaborative process.
40 CONTACT Andrew Simpson, MBA Chief Operating Officer CaseWare RCM Inc ext. 2144
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