Continuous Monitoring - Definition
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2 Agenda Continuous Monitoring ADB Treasury Operation Road Map for Introducing Continuous Monitoring in Treasury Investment Activities using ACL Lessons Learnt References Q&A 2
3 Continuous Monitoring - Definition Continuous Monitoring a management process that monitors on an ongoing basis whether internal controls are operating effectively. Continuous monitoring encompasses ongoing efforts by the first and second lines of defense to ensure that policies, procedures, and business processes are operating effectively. It involves identifying applicable control objectives and assurance assertions, and establishing automated tests to highlight activities and transactions that fail to conform to expected norms. 3
4 Continuous Monitoring Benefit Enhance the ability to promptly identify and curtail control problems Reduce incidences of error and fraud Enhance operational efficiency Improve bottom-line results through a combination of cost savings and a reduction in overpayments and lost revenue Improve customer satisfaction through enhanced customer service quality and integrity 4
5 Continuous Monitoring Driver Advancements of technology Change of regulatory requirement Pressure to improve operation efficiency Need for more timely ongoing assurance of control effectiveness 5
6 ADB Treasury Operation Treasury Funding Investment Continuously Monitored Liquidity Risk Market Risk Credit Risk Counterparty Risk Payment Processing Operational Risk Segregation of Duty Fiduciary Duty Error and Fraud Risk 6
7 The Road Map Baseline Audit Propose Tests to Address Control Concerns Prepare and Craft Tests Advisory to Engage Clients Implementation 7
8 Baseline Audit Population audit vs. Sample audit Assess control effectiveness Review the effectiveness of existing continuous monitoring program Coordinate with IT or data management units (DMUs) Examine data completeness and reliability 8
9 Proposed Continuous Monitoring Tests Exception Test Information Purpose Medium-high risk data Low risk data Trades verified by non-back office Action by SSDMU and OIST Trades done by non-tdid Missing audit trails Trades verified after settlement day SSI assignment after settlement day Trade entry after settlement day Delayed trade entry Interfund trades InterPortfolio trade s settlement day Mismatched Structure Trades Trades without structure ID SSI Exception Trades without trader 9
10 Prepare and Craft Tests PC-version versus Server-version Scripting Testing Frequency Automatic Data Extraction Report Format Web format (ACL Analytics Exchange) 10
11 Enhance User Experience User Guide 11
12 format report Enhance User Experience 12
13 Continuous Monitoring Advisory ACL Testing Script ACL Data Uploading Output: (i) ACL online reports, and (ii) Notification with Exception Reports OAG verifies comments and improves reports. TD comments 13
14 Collaborating with Client TD Engagement: Designated Focal Person Receive user guide Login to ACL Exchange to view exception report and receive notification Disseminate the report to respective unit Gather responses on exceptions Correspond with OAG continuous monitoring team to discuss exception handling and false positives Collaborate with OAG to improve test criteria 14
15 Lessons Learnt Data Availability and Integrity Tools and Capacity Data Analytics Tools and Capacity to Analyze Transactional and Unstructured Data Client Engagement Controls to Monitor Criteria Frequency Exception Investigation Management Support 15
16 References IIA - GTAG-3-Continuous-Auditing-2nd-Edition Continuous Monitoring in a Risk Management Framework, US Census Bureau, 2012 Continuous Monitoring Core Principles, NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY, 2013 Continuous Monitoring and Auditing: What is the difference?, Protiviti,
17 THANK YOU 17
18 Q&A 18
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