Key Considerations for Your Internal Audit Plan AU1607

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    iii Insights on governance, risk and compliance | May 2013

    Risk assessment leading practices ..................... 2

    Accounting ....................................................... 4

    Finance ............................................................6

    Tax .................................................................. 8

    Sustainability .................................................. 10

    Customer ....................................................... 12

    Corporate development ..................................14

    Fraud and corruption ......................................16

    Information security ....................................... 18

    Business continuity management .................... 19

    Mobile ............................................................20

    Cloud .............................................................21

    IT risk management ........................................ 22

    Program management ....................................24

    Software/IT asset management ....................... 26

    Social media risk management ........................ 28

    Segregation of duties/identity

    and access management ................................. 30

    Data loss prevention and privacy ..................... 32

    Human resources ............................................ 34

    Supply chain and operations............................36

    Contents

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    )Insights on governance, risk and compliance | May 2013

    Lhe internal amdit risk assessment and the ongoing re^resh processes are

    critical to identi^qing and ^iltering the activities that internal amdit can per^orm

    to provide measmraZle Zene^it to the organiration&Ohile there are o^ten a

    nmmZer o non%negotiaZle activities that internal amdit ^mnctions mmst

    smpport KGP and other regmlatorq compliance, epternal amditor assistance!,

    the internal amdit department has the opportmnitq to deliver increased risk

    coverage, cost savings and measmraZle valme to the Zmsiness Zq identi qing and

    per^orming amdits across the companqs valme chain& In omr role as the leading

    provider o^ internal amdit services, oe have spent consideraZle time oorking

    oith omr clients and thomght leaders to2

    )& Identi q emerging risks and areas that most organirations are cmrrentlq

    focused on

    *&

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    * Insights on governance, risk and compliance | May 2013

    Components of the

    risk assessment

    Data reviewed

    Data analytics

    Stakeholderengagement

    Interview/surveytechniques

    Collaboration

    Audit prioritization

    Outputs

    Ohq is the need for a oorld%class internal audit risk assessmentmore vital than ever7

    Lhere are multiple drivers Zehind the grooing importance of epecuting a roZust and

    comprehensive risk assessment2

    Internal audit executives continue to be challenged by the Audit Committee and

    executive management to look around the corner and answer the question, Have

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    Changes in the marketplace and external environment:

    Increased risk due to expanding operations in emerging markets and developing

    countries

    Increased regulatory demands

    Increased focus on cost savings across all functions including internal audit

    Changes in the role of internal audit within organizations:

    Effective use of internal audit resources no longer means only maintaining a world-class

    assurance program that keeps the organization out of trouble. The department must

    also improve the business through value-based audits and recommendations.

    Investors are willing to pay for it 82% of institutional investors are more willing to

    pay a premium for effective risk management (source: Ernst & Young survey)

    Jisk assessmentleading practices

    Ohen assessing risk to the organiration, internal audit functions

    tqpicallq fall Zetoeen Zasic and leading on the maturitq curve Zeloo&

    9s qour department moves tooard leading Zq utiliring the techniiues

    listed here, qou increase qour aZilitq to look around the corner andidentifq the right risks&

    )

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    +Insights on governance, risk and compliance | May 2013

    :asic

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    4 Insights on governance, risk and compliance | May 2013

    Operationalizing statutory

    reporting: driving global

    consistency to create savings

    and transparency

    www.ey.com/Publication/vwLUAssets/Operationalizing_Statutory_

    Reporting/$FILE/Operationalizing%20Statutory%20Reporting_Driving%20global%20consistency.pdf

    Operationalizing statutory reportingDrivingglobalconsistencyto createsavingsand transparency

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    Jecommended reading

    Accounting

    The pace of change to accounting standards is unprecedented

    in the US and globally. Multinational organizations need to

    understand how business decisions affect accounting and

    reporting today, as well as the impact anticipated changes to

    standards may have. The business needs to develop practical

    strategies for managing the impact of accounting changes on

    the organization. There needs to be particular focus in countrieswhere regulators are increasingly aligning local regulations with

    IFRS, such as Brazil and the United Kingdom. It is imperative for

    the internal audit department to be aware of potential changes

    to accounting regulations, such as:

    SEC accounting, disclosure and reporting matters The

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    considerations and their areas of focus: revenue recognition

    disclosures, valuation of deferred tax assets and observations

    related to the new fair value disclosures. It is expected that

    auditors will need to place extra scrutiny in these areas.

    FASB and IASB The two organizations recently commented

    on their joint convergence projects related to:

    Revenue recognition. The new standard is expected to be

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    to disclosure and transition to the new standard.

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    developed by the Boards, and the revised proposal is expected

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    new draft is expected to end off-balance-sheet accounting for

    leases by lessees.

    Seizing the opportunity in

    global compliance and

    reporting: survey trends

    www.ey.com/GL/en/Services/Tax/Seizing-the-opportunity-in-Global-

    Compliance-and-Reporting--Global-Compliance-and-Reporting-Survey

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    2013. Many changes have been made for convergence in these

    areas, but the two Boards remain relatively far apart on the

    issue of impairment.

    IFRS update The SEC is continuing to investigate whether to

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    made anytime soon.

    As organizations are executing the day-to-day activities to meet

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    need to focus on to mitigate the associated risks:

    Statutory reporting Multinational organizations need to

    understand the statutory reporting requirements and the

    processes they need in place to meet them. The business must

    assess its requirements and evaluate the opportunity to increase

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    Business transformation As organizations continue to lookfor opportunities to drive cost out of the business through major

    transformations (e.g., shared service center implementations),

    the accounting and reporting function must be aware of the

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    transformations as an opportunity to streamline their accounting

    policies and controls, thereby reducing both cost and risk.

    ERP system implementation The implementation of an ERP

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    takes several years to be fully integrated. As an organization

    is planning such a migration, the business should assess the

    changing accounting and control requirements and incorporate

    them into their plans.

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    5Insights on governance, risk and compliance | May 2013

    Lhe audits that make an impact Cey iuestions to evaluate during audit

    Accounting policy review The internal audit team focuses on

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    The team reviews the consistency of application across entities

    through sample testing (e.g., account reconciliations, accruals,

    manual journal entries). Additional time is spent reviewingaccounting policies against leading practices (e.g., number of

    days to close each month/quarter) and proposed legislation or

    regulatory changes.

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    What is the process to disseminate updates and/or changes

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    Lease accounting review The internal audit team inventories

    and reviews the organizations leases. A review of the policy for

    leases is conducted, with individual leases being sampled for

    adherence to policy and applicable guidance. For additional

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    improvement opportunities in the lease analysis (e.g., use of

    a standard template) process.

    Does the organization have a database or repository of all of

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    Statutory risk assessment The internal audit team focuseson the countries in which the organization operates and

    assesses the statutory risk to the business. A risk assessment

    is performed of the locations based on the statutory reporting

    risk of each location, as well as the materiality and inherent

    risk of the companys operations in each location.

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    For countries in which we operate, which are inherently

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    Are we appropriately aligning our resources for statutory

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    6 Insights on governance, risk and compliance | May 2013

    Jecommended reading

    >inance

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    audit departments, pressures from within the organization to

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    augmented by emerging challenges. The push for shared service

    centers, implementations of global ERP systems, and the

    standardization of global policies, procedures and operations

    have increased the pressure on CFOs and their functions. With

    these initiatives come risks that internal audit needs to identify,

    assess and help the organization mitigate with appropriate

    controls and strategies.

    In addition to the internal pressures to reduce costs and operate

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    implementation of the Patient Protection and Affordable Care Act

    in the United States, and the uncertainty surrounding additional

    governmental policy and legislation. While all of this is occurring,

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    partner in strategic decision-making by putting the right informationin the hands of decision makers at the right time.

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    function and organization.

    Disparate nance systems and processes Multinational and

    global organizations frequently grow through inorganic methods

    (e.g., acquisitions), often leading to the need to manage

    different ERP packages and supporting systems. Additionally,

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    consistently designed (or performed), leading to a potential

    roadblock in the businesss operations.

    Managing performance

    through famine and feast:

    the CFOs role as economic

    advisor

    www.ey.com/GL/en/Services/Advisory/Managing-performance-through-famine-and-feast---CFO-report

    Views. Vision. Insights:

    the evolving role of

    todays CFO

    www.ey.com/GL/en/Issues/EYfY_af_%fYf[]'L`]%

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    7Insights on governance, risk and compliance | May 2013

    The audits that make an impact Cey iuestions to evaluate during audit

    Analysis of the budgeting and forecasting process

    Assess the annual budgeting and forecasting processes including

    the internal controls and potential process, improvement

    recommendations. Review the primary business segments of the

    organization, current state processes and root cause issuesdriving inaccuracies in the forecast.

    What is the current process for budgeting and forecasting and

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    How do we monitor the accuracy of the budgeting and

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    Capital allocation review Review the comprehensive capital

    allocation process focusing on internal controls and potential

    process improvement recommendations. Evaluate the capital

    request and approval process, committee and approval structure

    and return on investment tracking.

    How does the organization manage capital allocation requests

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    How does the capital allocation process mirror the goals and

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    Global costing review Review the policies and internal controls

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    line/service. Evaluate the organizations internal control structure

    and provide potential process improvement recommendations for

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    Are controls related to margin analysis designed and operating

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    Treasury process review The internal audit team focuses on

    the business process and controls for cash forecasting, funding,

    hedging and derivatives, and compliance with applicable debt

    covenants. Additional focus is given to the vetting and granting

    of credit to customers (if owned by Treasury).

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    Finance benchmarking assessment As the organization

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    internal audit has a role in the compliance and controls

    workstream. The team focuses on benchmarking the

    organizations cost of controls relative to its competitors and

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    continuous control monitoring).

    What is the companys total spend on the planning, execution

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    Opportunities for integrated audits between IT and operational audit Audit was frequently mentioned in survey of leading IA organizations

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    8 Insights on governance, risk and compliance | May 2013

    Tap

    Tax risk goes well beyond the tax technical application of the law.

    Factors that contribute to increased pressure on organizations to

    develop and maintain an effective tax risk management strategy

    include expanding business operations, increasingly complex tax

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    expanding global internal control and tax authority regimes and

    greater transparency and increased accountability to stakeholders.

    Interestingly, since the inception of reporting under Section 404

    of the Sarbanes-Oxley Act (SOX 404), tax reasons have accounted

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    and continue to be a leading cause of restatements.

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    Policy-makers in emerging markets are rapidly enacting mechanisms

    to capture their fair share of the global tax pie. In many mature

    markets, governments have an urgent need to increase revenues.

    As a result, they are attempting to raise taxes and intensify

    enforcement for companies operating within their borders.

    It is in this context that the following tax topics are receivingattention across the enterprise and should be considered during

    the risk assessment and potentially in the audit plan:

    Failure to integrate tap in large global initiatives Large

    initiatives such as moves to a shared service environment,

    implementation of an ERP or supply chain transformation

    are all examples of initiatives that are critical for tax to be

    involved in up front. Where tax is not involved, tax compliance

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    purposes all emerge as concerns for the organization.

    Dack of availability of data Tax is one of the largest

    consumers of data within any organization. A lack of accurate

    and accessible transactional data for tax purposes is a top root

    cause of tax compliance issues, not to mention a driver

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    Transfer pricing While tax owns the transfer pricing policy, it

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    controls that ensure compliance with the policy. Therefore, a

    key risk related to transfer pricing remains the ability to sustain

    transfer pricing controls. Operationally, a lack of transparency

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    the organization waiting until it is too late to make changes to

    prices or controls. Transfer pricing risk is compounded by tax

    authorities with very divergent goals.

    VAT and other indirect tapes These transactional taxes

    continue to create risk due to the fact that heavy reliance is

    placed on the accuracy of information in the business to comply.

    While tax can provide direction and guidance related to indirect

    taxes, it is the transactions being executed by the business that

    drive compliance, and organizations often do not have the right

    processes and controls in place. Identifying the right structure

    (in the business, versus within tax) to manage VAT and indirect

    tax is a complex issue companies continue to assess.

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    tax risk for organizations. This is driven by the complexity of tax

    rules, a lack of resources familiar with both US and Brazilian tax

    rules in the region and governmental policy decisions.

    Other risks that continue to receive attention include: failure to

    identify tax planning opportunities and manage tax obligations

    across all jurisdictions; failure to manage non-income tax

    obligations like customs duties; failure to track the movement

    of expatriates and assets across foreign tax locations, resulting

    in permanent establishment or nexus issues; and/or a lack of

    resources with tax accounting skills in foreign jurisdictions.

    The management of tax risk is complex and requires the participation

    of different constituents with the requisite skills partnering with the

    business and tax department to properly assess, remediate and

    monitor these risks. Internal audit can, and should, play an integral

    role in the organizations broader tax risk management approach.

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    Jecommended readingwww.ey.com/US/en/Services/Tax/Tax-Library

    The audits that make an impact Cey iuestions to evaluate during audit

    Transfer pricing audit This audit is not just an assessment

    of the companys compliance with policy but a broader look at the

    processes, controls and data in place to sustain compliance. Assess the

    accuracy, completeness and availability of data used to understand

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    transfer prices, and evaluate the design and operating effectiveness

    of managements monitoring processes, including reports and

    periodic meetings to monitor performance. An emerging area of

    risk to consider would be the harmonization of transfer pricing and

    custom valuations.

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    What controls are in place within the business to monitor transfer

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    What can be done to improve the accuracy of transfer prices and

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    Is the organization at risk for inconsistent transfer pricing and

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    Tax data assessment Evaluate the availability, completeness

    and accuracy of data needed to comply with tax regulations.

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    necessary for tax (determined in coordination with tax or third

    party). The team then evaluates gaps in either the completeness,

    accuracy and availability of data and articulates the impact of the

    gap. Management can use the results of this audit to evaluate future

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    What data and related data resources are the most critical to

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    Where does a lack of data availability, completeness or accuracy

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    VAT (indirect taxes) Perform an end to end process review of the

    companys VAT tax process. This includes evaluation of how data

    is compiled, processed and ultimately reported to tax authorities.

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    opportunities for substantial cost savings by improving the accuracy

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    such as sales and use tax could also be considered for this audit.

    Is data needed for VAT purposes captured accurately and

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    Who owns VAT processes and do they have the necessary skills

    lg]fkmj][gehdaYf[]7

    9j]l`]j]ghhgjlmfala]k^gj[gklkYnaf_kj]dYl]\lgN9L7

    Tax compliance audit Evaluate the tax provision and other tax-

    [gehdaYf[]%j]dYl]\hjg[]kk]klg[gfje[gfljgdkYj]\]ka_f]\Yf\

    operating effectively. To add value to the organization, identify

    ways in which controls can be further optimized for adequate risk

    [gn]jY_]o`ad]af[j]Ykaf_]^[a]f[q&

    @go]^[a]flakl`]hjg[]kklg[gehad]\YlY^gjl`]lYphjgnakagf7

    Akl`]j]_dgZYdnakaZadalqaflgl`]hjg[]kk7

    Are controls related to compliance designed and operating

    ]^^][lan]dq7

    9j]l`]j]ghhgjlmfala]klgaf[j]Yk]l`]]^[a]f[qg^[gfljgdk7

    Af\aj][lLYp:ja]f_2

    a review of global indirect tax

    developments and issuesIndirect Tap:riengA review of global indirecttap developments and issues

    Issue5tAugust *()*

    Navigating a complex tax

    controversy environment

    Inthisissue:

    2 Ernst&Youngtaxcontroversysurveyaneweraof taxriskand

    mf[]jlYaflq2 \]faf_l ]businessimperative

    4 IRSpracticeandprocedures

    ;`a]^ ;gmfk]dakkm]kfgla[]gf

    9hh]Ydk]phYjl][geemfa[Ylagfk

    AJKoal`\jYok;AHgf[gkl%k`Yjaf_Zmq%afljYfkY[lagfk

    AJKj]nakalkj]k]Yj[`[j]\alj]^mf\[dYaek

    10 Transferpricing

    enforcementtrends

    Hjagjala]klg]f`Yf[]l`]EmlmYd9_j]]e]flHjg[]\mj]

    13 Penaltycorner

    O`a[`h]fYdlqYhhda]k

    mf\]jhYqe]flgj]p[]kkan]j]^mf\715 Courts

    20 Legislative,regulatoryand

    gl ]j_ma\Yf[]F]odqj]d]Yk]\lYf_aZd]

    hjgh]jlqj]_mdYlagfk

    26 Ernst&YoungLLPaddsnew

    taxcontroversytalent

    Summer2012

    Wearepleasedtopresentthelatest issueofournewsletterdedicatedtotax controversyand

    relatedrisks.Asbusinessmodelsgrowincomplexityandgeographicreach,the challengesYf\jakckj]dYl]\lglYp[gfljgn]jkqaf[j]Yk]ka_fa[Yfldq&L`]j]Yj]fYf[aYdYko]dd Yk

    j]hmlYlagfYdjakckl`Yl[YfZ][gkldq a^fgleYfY_]\hjgY[lan]dq&L`]klYc]kYj]`a_`$l`]

    rulesarenotalwaysclear,anditcan bechallengingtokeepup withallofthe changesinIRSprocedures,toolstoresolvedisputes,andthevariousrolesand responsibilitiesoftheteams

    Yf\eYfY_]jk&L`akf]okd]ll]jakafl]f\]\lg`]dh qgmc]]hmhlg\Yl] gfl`][`Yf_]kaf AJKinitiativesandenforcementfocus,courtdecisionsandtheir implications,regulatorychanges,

    andotherinformationthatcanhelp youmakeinformeddecisionsaboutmanagingtaxcontroversyandrelatedrisk.

    L`]AJKj][]fldqj]n]Yd]\l`Yll`]l`j]]lgh Yj]Ykg^mf[]jlYaflYphgkalagfk\ak[dgk]\gf>gje))*(MLHYj]l`]j]k]Yj[`[j]\al$ljYfk^]jhja[af_$Yf\akkm]kj]dYl]\lg AJ;k][lagf

    ).*$ljY\]gjZmkaf]kk]ph]fk]k&Afl`ak]\alagf g^gmjf]okd]ll]j$qgmoaddf\Yjla[d]kj]dYl]\lgl`]k]l`j]]Yj]Yk&9dkgaf[dm\]\ak YkmeeYjqg^l`]f\af_k ^jgegmj*())*()*LYpjakc

    andcontroversysurvey.Seehowyourcompanycompareswiththeperspectivesof500tax\aj][lgjkYf\;>Gko`ga\]fla]\l`]ajlgh jakcYj]YkYf\lj]f\kl`Yll`]qgZk]jn]&Qgmoadd

    alsoseewhattaxauthorities,taxpolicy makersandauditcommitteemembersconsidertobetheirkeychallenges.

    L`]j]Yj]ka_fa[Yfl[`Ydd]f_]kafeYfY_af_lYpjakc Yf\[gfljgn]jkqaflg\Yqk][gfgea[andglobalenvironment.However,withthosechallengescomeopportunitiestodealwithtax

    [gfljgn]jkqegj]]^[a]fldqYf\]^^][lan]dqafl`]MKYf\ gfY_dgZYdZYkak& O`]l`]jqgmoYfllgeYc]Yka_fa[Yflk`a^l afqgmjj]dYlagfk`ahYf\hjg[]kkaf \]Ydaf_oal`lYpYml`gjala]k$gj

    justwanttoimprovetheprocessto obtaincertaintysooner,knowledgeofthetoolsavailableYf\`golgfYna_Yl]l`jgm_`l`] gj_YfarYlagfak]kk]flaYd&O]`gh]l`Ylqgm f\l`ak

    informationhelpful.

    Ifyouhaveanyquestionsor feedbackrelatedtothisnewsletter,pleasefeelfreeto

    [gflY[lgmjLYp;gfljgn]jkqYf\JakcEYfY_]e]fld]Y\]jkj]^]j]f[]\Yll`]]f\ofthispublication.

    DeborahNolan9e]ja[YkLYp;gfljgn]jkqD]Y\]j

    Tax controversy andrisk management review

    Navigating a complex taxcontroversy environment

    Opportunities for integrated audits between IT and operational audit Audit was frequently mentioned in survey of leading IA organizations

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    Sustainability

    Awareness of environmental issues and the increased focus onthe scarcity of natural resources has brought sustainability to theforefront for many organizations. In a recent review of the proxystatements of the Russell 3000, more than 900 shareholderproposals were submitted on environmental and social topics, themost across the four major proposal categories (environmental/social, board-focused, compensation and anti-takeover/strategic

    proposals). This shift was attributed to growing support frommainstream investors on environmental/social topics as wellas widespread corporate recognition of the business case forsustainability. Additionally, legislation such as the Dodd-Frank9[lYf\\ak[dgkmj]j]imaj]e]flkgf[gfa[leaf]jYdk`Yn]increased the risk in this area.

    As the focus on sustainability grows, key topics continue to emerge:

    Managing the global supply chainL`]j]akka_fa[Yflafl]j]klin how organizations are identifying and mitigating risks relatedto sustainability of their supply chain. Stakeholders are focusedon sustainability reporting, environmental impacts and human/labor rights and working conditions. Companies are frequentlybeing asked for disclosure of supply chain practices and/orrelated risks.

    Dinking executive compensation to sustainability metrics To drive sustainable change through the organization, theexecutives must be properly incented and measured. Leadinggj_YfarYlagfkYj]af[gjhgjYlaf_fgffYf[aYdh]j^gjeYf[]metrics into their executive compensation programs a trendthat will only increase as sustainability grows in importance.

    Including environmental'social considerations in employeeiualication Stakeholders are seeking information on howorganizations link their overall business strategies withenvironmental/social matters.

    Conict minerals Section 1502 of the Dodd-Frank Act requires

    certain public companies to provide disclosures about the use of[gfa[leaf]jYdk^jgel`]

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    The audits that make an impact Cey iuestions to evaluate during audit

    Corporate responsibility audit Evaluate the processesfor developing and issuing the corporate responsibility report.Additional focus will be given to the metrics utilized in the report,hjg[]kk^gj[gdd][laf_l`akaf^gjeYlagf$Yf\l`]n]ja[Ylagfg^the completeness and accuracy of this data. The internal auditteam should evaluate the gaps in completeness, accuracy and/oravailability of the data required to issue the report.

    Who is responsible for developing and issuing thej]khgfkaZadalqj]hgjl7

    What are the key performance indicators and metricskmhhgjlaf_l`]j]hgjl7

    How does the company determine that the informationaf[dm\]\afl`]j]hgjlak[gehd]l]Yf\Y[[mjYl]7

    What controls are in place within the business to monitorl`]j]hgjl7

    What can be done to improve the accuracy and timelinessg^l`]j]khgfkaZadalqj]hgjlaf_hjg[]kk7

    Energy management audit The internal audit teamYkk]kk]kl`][gehYfqk[mjj]fl]f]j_qmkY_]Ylka_fa[Yfllocations, as well as their efforts to reduce energy usage.The internal audit team focuses on the companys energymanagement strategy, how it is implemented, the metrics usedlgljY[cmkY_]Yf\j]\m[lagfk$Yf\l`]jYea[Ylagfkg^gn]jY_]kand missed projections.

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    Customer

    While customers are clearly some of the most valued stakeholders

    of any organization, conversation related to customer risk is often

    limited to pricing compliance, sales commissions and rebates/

    marketing incentives versus broader operational and strategic

    concerns. The areas of customer can be compartmentalized as

    follows: customer strategy, customer experience and insight,

    and sales and marketing productivity. Below we touch on each of

    these areas and provide insight into how to broaden the typical

    customer-related audits and add value to the organization.

    Customer strategy

    Acquiring, maintaining and expanding relationships with customers

    are extremely competitive aspects of any business. There are

    ka_fa[Yfljakck^jgel`]\][akagflg]fl]jYeYjc]lYf\a\]fla^q

    its customers) to the decision to exit a particular product line or

    service that organizations must continually evaluate:

    Market effectiveness and return%on%investment In a

    stagnant economy, there is continued risk related to

    unproductive use of funds for marketing purposes and an

    inability to effectively measure return on investment. Internalaudit can help manage this risk by assessing ROI and the

    organizations processes to allocate marketing spend. This is

    in addition to more traditional marketing and advertising

    contract audits for potential cost recovery.

    Hricing strategy and improvement opportunities The lack of

    information to make pricing decisions (primarily total cost data),

    a disconnected pricing strategy and poor implementation of

    the pricing strategy through sales channels and contracting

    [j]Yl]ka_fa[Yfljakcoal`afl`]gj_YfarYlagf&

    Hroduct innovation and life cycle management As

    organizations focus on improving margin through customer-

    based product innovation, the risk that product innovation isdisconnected from the customer or not fully integrated with

    the necessary business functions emerges.

    Digital marketing strategy Marketing went digital long ago,

    but in todays rapidly evolving technological world, failure to

    keep the strategy up to date is a key risk. With social media

    emerging as a primary way for customers and organizations

    to connect, the risks related to customer, HR, legal and IT will

    continue to blur.

    Customer experience and insight

    With growing pressures on product margins, an increasingly diverse

    customer base, and rising costs to acquire new customers, more

    and more companies are differentiating themselves by gathering

    additional customer insight to improve their customer experience.

    Companies must be in tune with the real-time experiences and

    feedback of their customers, and the value of this informationmust be leveraged and capitalized on.

    Based on these focus areas, organizations need to consider the

    following risks:

    Failure to properly segment and understand customers

    Organizations may not truly understand the characteristics

    and needs of their customers, thus resulting in poor pricing

    Yf\eYjc]laf_kljYl]_a]kYf\Y\jghafhjglYZadalq&

    Customer support Poor customer support can quickly

    j]\m[][mklge]j[gf\]f[]Yf\]jg\]hjglYZadalq&

    Dack of proactive metrics to measure performance

    Identifying the right metrics to proactively provide management

    with an indication of performance is critical and often an area

    organizations struggle with.

    Sales and marketing productivity

    >gjegklgj_YfarYlagfk$Yka_fa[YflYegmflg^[YhalYdakkh]flgf

    sales and marketing to attract, retain and expand relationships

    with customers. Organizations must develop the appropriate

    metrics and reporting to monitor the effectiveness of their sales

    forces and marketing materials. There are a number of focus areas

    related to sales and marketing productivity that the internal audit

    department should be aware of:

    Sales productivity improvement This area includes developing

    and sustaining the right account strategy and opportunity

    sizing processes. This also includes understanding where and

    how members of the sales force utilize their time and how it

    aligns to the overall account and opportunity sizing process.

    Sales organization structure This relates to having the right

    sales force structure and span of control sizing to deliver on

    sales goals.

    Sales performance management To obtain the most from

    the sales organization, its important to have clear roles

    \]f]\Yf\Y^gjeYd[Yj]]jhYl`af_hjg[]kk&KYd]ke]lja[k

    and incentive compensation must be aligned to the overall

    organizational goals to drive the right behavior. This is a

    critical risk area for members of the sales organization.

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    This time its personal: from

    consumer to cocreator

    www.ey.com/GL/en Services/Advisory/This-time-its-personal--from-consumer-to-co-creator

    Jecommended reading

    The audits that make an impact Cey iuestions to evaluate during audit

    Marketing effectiveness and ROI review This audit includesreviewing the process to develop key marketing programs andthen assessing managements ability to measure the success.Also included in this audit may be an assessment of keycontracts with marketing and advertising vendors. This portionof the audit would be structured as a more traditional contractcompliance review.

    Are marketing programs developed and approved in[gehdaYf[]oal`[gehYfqhgda[a]kYf\hjg[]kk]k7

    Do program incentives drive customer behavior that is alignedlg[gjhgjYl]kljYl]_q7

    Are marketing and advertising providers delivering on[gfljY[lmYdl]jek7

    How effectively does the organization measure ROI associatedoal`ka_fa[YfleYjc]laf_hjg_jYek7

    Product innovation audit Evaluate the processes and controlsrelated to the organizations ability to innovate. This audit wouldYkk]kkl`]]^^][lan]f]kkg^l`]klY_]Yf\_Yl]khjg[]kk\]f]\and, most importantly, how well the innovation process isintegrated across business functions.

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    Corporate

    development

    In the ever-changing economic world, the corporate development

    function is more crucial than ever. Corporate development serves

    as the lifeblood for an organization by providing strategic advice to

    the board, actively managing the organizations portfolio, divesting

    non-core assets and pursuing acquisitions to deliver increased

    nYdm]lgl`]Zmkaf]kk&Afl`ak[gehd]pYj]Y$l`]j]Yj]Yka_fa[Yfl

    number of potentially material risks. In the following section, weidentify these risks and the audits that may be performed to deliver

    additional value to the business.

    Divestitures

    As organizations focus on preserving, optimizing and raising

    capital, they often use divestitures to strategically manage their

    portfolios. Deciding when and how to sell an operating unit can be

    ]plj]e]dq\a^[mdl&9k[gehYfa]k[gflafm]lgjYlagfYdar]l`]aj

    product portfolio based on internal and external factors, internal

    audit may play a role in enhancing managements credibility and

    preparedness. By focusing on the right areas, the internal audit

    team may assist in preserving the deals value and maximizing the

    after-tax proceeds for the organization. By remaining an active

    participant in the process, audit may help to mitigate the risks to

    the organization in the following areas:

    Carve-out nancial statements Being able to appropriately

    value the carve-out business requires the organization to have

    l`]f][]kkYjq\YlYYf\fYf[aYdaf^gjeYlagf&G^l]fl`akakY

    ka_fa[Yfl]^^gjl^gjl`]gj_YfarYlagf\m]lg`goalakk]lmh

    (e.g., systems, consolidation process).

    Tax analysis The structuring of the divestiture transaction

    `YkYka_fa[YflaehY[lgfl`]lYpaehda[Ylagfkg^l`]\]Yd&

    Most transactions involve businesses with operations in multiple

    countries, further complicating the process and enhancing therisk to both the organization and acquiring company.

    Buyer diligence After deciding to divest of a portion of its

    portfolio, an organization must have an approach to dealing

    with the buyer diligence process. Decisions on the amount and

    type of information to be shared, and at what point in the

    divestiture life cycle it will be shared, must be made prior to the

    a\]fla[Ylagfg^hgl]flaYdZmq]jk&

    Operational preparedness As a company or business unit is

    divested from an organizations portfolio, the remaining business

    must have the appropriate processes and controls in place to

    ensure that it is prepared to operate post-transaction close.

    Mergers and aciuisitions

    As the business landscape continues to become more and more

    competitive, organizations are looking for ways beyond organic

    growth to continue to meet and exceed their goals. In a recent

    survey of US companies, 76% believe the global economy shows

    no signs of improvement. Mergers and acquisitions are viewed as

    one route to help companys meet their targets and continue todeliver value to their shareholders. Organizations must be

    actively monitoring the M&A market in emerging markets. For

    instance, Brazil has seen year-over-year M&A activity increase

    16%. The acquisition and integration of a business or segment

    afngdn]kka_fa[Yfljakcl`jgm_`gmll`]hjg[]kkYf\emklZ]

    tightly monitored by the organization:

    Validate reiuirements and understand the issues for the

    transaction As organizations initiate the process to identify

    hgkkaZd]Y[imakalagflYj_]lk$l`]j]akka_fa[Yfljakca^l`]

    gZb][lan]kYf\_gYdk^gjl`]ljYfkY[lagfYj]fgl[d]Yjdq\]f]\

    at a detailed level.

    Herform due diligence of potential targets Organizations

    emkl`Yn]Y\]f]\YhhjgY[`lgh]j^gjeaf_\m]\ada_]f[]Yf\

    fYf[aYdYfYdqkakg^l`]a\]fla]\lYj_]lk&L`]qemkl`Yn]

    hj]nagmkdqa\]fla]\l`]af^gjeYlagfl`Yll`]qf]]\Yf\l`]

    process they want to go through in order to successfully

    evaluate the target.

    Jeview potential compliance and regulatory issues that may

    arise from aciuisition When considering a potential target,

    the company should be aware of and actively managing the

    compliance and regulatory issues that may arise as a result of

    the transaction.

    Continue ongoing support of the business and its integrationstrategy For the transaction to be truly successful, the

    gj_YfarYlagff]]\klg`Yn]Y\]f]\hdYf$hjg[]kkYf\[gfljgdk

    in place to assist with the transitioning of the target. The

    transaction is not truly complete until the target is operating

    like other segments of the organization.

    Would-be buyers should also perform anti-corruption due diligence

    YkYjklkl]haf[gfka\]jaf_\]YdkYZjgY\&L ak\m]\ada_]f[]k`gmd\

    Z]h]j^gje]\hjagjlgljY\alagfYdfYf[aYd\m]\ada_]f[]g^Y

    potential target. This is especially important given the potential for

    successor liability of an acquired organization, and is an area where

    afl]jfYdYm\al[YfZ]g^ka_fa[YflnYdm]lgl`]gj_YfarYlagf&

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    Jecommended readingwww.ey.com/US/en/Services/Transactions/Corporate-Development

    The audits that make an impact Cey iuestions to evaluate during audit

    Merger and acquisition process integration review

    This audit is focused on evaluating the organizations

    process to integrate operations, technologies, services

    and product lines after the transaction has closed. The internal

    audit team focuses on the policies and procedures in place tomake the transaction as seamless as possible. Additionally,

    l`]afl]jfYdYm\all]Yeoaddj]na]ol`]\]f]\c]qh]j^gjeYf[]

    indicators (KPI) for the integration, as well as the process

    to monitor the KPIs.

    O`YlYj]l`]\]f]\[gfljgdhgaflkafl`]afl]_jYlagfhjg[]kk7

    Who is involved in the acquisition integration process and what

    Yj]l`]ajjgd]k7

    What are the KPIs to determine whether the integration is

    km[[]kk^md7 How is the acquired organization transitioned to the companys

    hgda[a]kYf\hjg[]\mj]kafYlae]dqeYff]j7

    Are there any new reporting requirements or disclosures as a

    j]kmdlg^l`]Y[imakalagf7

    What is the process for assessing the culture of the target

    organization and identifying the steps necessary to assimilate

    l`]h]ghd]aflggmjZmkaf]kk7

    Business development/due diligence assessment The internal

    audit team will focus on the process and controls in place to

    manage the business development life cycle from the

    a\]fla[Ylagfg^lYj_]lgj_YfarYlagfklgl`]imYda[YlagfYf\

    offer process. Additional consideration is given to the strategicdecision-making process for the allocation of capital.

    What is the process and what are the controls for identifying

    Yf\imYda^qaf_Y[imakalagflYj_]lk7

    Who is responsible for monitoring the controls and how

    ]^^][lan]dqYj]l`]qgh]jYlaf_7

    O`]j]\gnmdf]jYZadala]kgj_Yhk]pakl7 O`YlakZ]af_\gf]lgj]e]\aYl]l`]k]_Yhk7

    Divestiture/carve-out review The internal audit team reviews

    the process and controls in the divestiture/carve-out life cycle,

    ^jgej]na]og ]paklaf_Zmkaf]kkmfalk'k]_e]flklgl`]imYda[Ylagf

    of potential buyers and the offer process. The team focuses on

    l`]hjg[]kkYf\[gfljgdkafhdY[]\mjaf_l`]a\]fla[Ylagf$YfYdqkak

    and potential sale/closing of the operations/business unit. A

    focus is placed on the carve-out life cycle, including strategic

    analysis, opportunity analysis, transaction development,

    negotiation advice and execution, and measuring and monitoring

    g^ljYfkY[lagf]^[a]f[qYf\]^^][lan]f]kk&

    Akl`][Yjn]%gmlda^][q[d] gjeYddq\]f]\Yf\Y\`]j]\lg7

    O`YlYj]l`]\]f]\[gfljgdhgaflkafl`]\an]klalmj]hjg[]kk7

    Who is involved in the process and what is their level of

    afngdn]e]fl7

    O`YlYj]l`]c]qh]j^gjeYf[]af\a[Ylgjklg\]l]jeaf]km[[]kk7

    Divesting for value

    Fairness opinions:

    the company is

    about to enter into a

    ka_fa[YflljYfkY[lagf

    Fairness opinionsAnessentialservice

    offeringfromErnst&Young

    InvestmentAdvisorsLLP

    The company is about to enter

    into a significant transaction.

    Yourshareholderswanttoknow.

    Themarketplacewantstoknow.

    Yourboardabsolutelymustknow.

    Certainly,youbelieveitmustbe,orelsethetransactionwouldnot

    beunderconsiderationormovingforward.

    Butwillboardmembers,boardsubcommittees,shareholdersor

    otherkeystakeholdersacceptyourexpertiseandobjectivityon

    faithandreputationalone?Furthermore,canyouorthecompany

    affordtheriskofbeingprovenwrongafterthefact?

    Is it fair?

    TransactionAdvisoryServices

    Divesting for value

    Opportunities for integrated audits between IT and operational audit Audit was frequently mentioned in survey of leading IA organizations

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    Navigating todays complex

    business risks: Europe, Middle

    East, India and Africa

    Fraud Survey 2013

    Fraud and

    corruption

    Companies must recognize that fraud awareness, prevention and

    mitigation are everyday issues that need to be a permanent

    plmj]gfl`]gj_YfarYlagfkY_]f\Y&;gehYfa]kemklZ]na_adYfl

    in ensuring their compliance with regulatory and legal issues. The

    Foreign Corrupt Practices Act (FCPA), enacted in 1977, prohibits US

    [gehYfa]kYf\l`]ajkmZka\aYja]k$g^[]jk$\aj][lgjkgj]ehdgq]]k

    ^jgeZjaZaf_^gj]a_fg^[aYdk\aj][ldqgjaf\aj][ldq!^gjl`]

    purpose of obtaining or retaining business. The FCPA has become

    an enforcement priority for regulators and a major compliance

    issue for US companies with global operations. The US Securities

    and Exchange Commission (SEC) and the US Department of Justice

    (DOJ) have stepped up their efforts to investigate and prosecute

    Zmkaf]kk[gjjmhlagf$ka_fa[YfldqjYakaf_l`]j]hmlYlagfYdYf\

    fYf[aYdjakcklg[gehYfa]k&Af*()($l`]K=;Yf\

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    The audits that make an impact Cey iuestions to evaluate during audit

    Supplier management review Evaluate the process

    management has put in place to qualify and accept suppliers,

    kh][a[Yddq^g[mk]\gf:JA;:jYrad$JmkkaY$Af\aYYf\;`afY!

    countries and other emerging markets (e.g., Africa). The internal

    audit team will focus on the controls for ensuring that companypolicies and procedures are in place and being consistently

    followed. Additional focus will be on the companys strategy to

    track and handle supplier management in the highrisk locations.

    This will include a review of supplier acceptance and the periodic

    supplier continuance review process.

    O`Yl`a_`jakceYjc]lk\g]kl`]gj_YfarYlagfgh]jYl]af7

    O`Ylakl`]hjg[]kk^gjY[[]hlaf_f]okmhhda]jk7

    O`gakafngdn]\afl`]hjg[]kkYf\o`YlYj]l`][gfljgdkafhdY[]7

    What is the process for validating continuing relationships

    oal`kmhhda]jk7

    FCPA program assessment The internal audit team would

    review the companys approach to FCPA compliance. A detailed

    review of the policy, procedures and internal controls in place to

    remain compliant will be a focus of the team. The internal audit

    team will review the companys training and education programs

    for employees and third parties. Also, the team will focus on the

    business approach to remaining up to date on all applicablelaws and regulations.

    O`ggofkYf\akj]khgfkaZd]^gj>;H9[gehdaYf[]7

    What is the organizations process for riskassessing the

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    What is the process for ensuring the FCPA compliance

    program remains up to date with any new legal or

    j]_mdYlgjqj]imaj]e]flk7

    Whistleblower audit The internal audit team would

    focus on the companys compliance program with an emphasis

    on the policies, procedures and internal controls of the program.

    The internal audit team will review the whistleblower hotline,

    managements response to new accusations and the process

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    Additional focus will be given to the controls in place to ensure

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    Who owns and is responsible for the companys compliance

    hjg_jYe7

    What is the process for a whistleblower to provide feedback

    lgl`][gehYfq7

    What controls are in place to ensure the program promotes

    [gf\]flaYdalqg^l`gk]o`g[gflY[ll`]o`akld]Zdgo]j`gldaf]7

    What is the process for following up on tips provided through

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    :mkaf]kkZja]f_2

    foreign corrupt practices

    act guidance issued

    November2012Fraud Investigation &Dispute Services (FIDS)

    Business briefing

    Foreign Corrupt Practices Act

    guidance issued

    The fight against corruptionis alawenforcementpriority oftheUnitedStatesandwe willcontinue to make clear thatbribingforeignofficialsisnotanacceptableshortcut.Lanny A. Breuer November 14, 2012Assistant Attorney General, U.S.Department ofJustice Criminal Division

    Investorsmust have faiththattheeconomicperformanceofpublic companiesreflectslawfulconsiderationsof markets, priceandproductratherthanamirageresultingfrombriberyandcorruption.Robert Khuzami November 14, 2012Director, U.S. Securities and ExchangeCommission Division of Enforcement

    OnNovember14,2012,theU.S.DepartmentofJustice(DOJ)andtheU.S.SecuritiesandExchangeCommission(SEC)jointlyreleasedAResourceGuidetotheU.S.ForeignCorruptPracticesAct,(Guide).TheGuidedemonstratestheirsharedcommitmenttofightingcorruptionthroughcontinuedvigorousenforcementoftheForeignCorruptPracticesAct(FCPA).

    Aftermanyyearsofrequestingadditionalguidance,thebusinessandlegalcommunitiesnowhaveacomprehensivedocumentsummarizingtheapproachandprioritiesoftheDOJandSECinFCPAenforcement.ThiswidelyanticipatedGuidedoesnthavetheforceoflawbutdoesrepresenttheevolvingviewsofDOJandSECfromyearsofenforcementactivityandreviewsofprivateandpubliccompaniesanti-corruptioncomplianceprograms.

    TopicsintheGuideinclude:

    Globalanti-corruptionandinter-agencyefforts Discussionofkeyanti-briberyelementsand

    accountingprovisions Affirmativedefenses Principlesofenforcement Penalties,sanctionsandremedies Hallmarksofaneffectivecorporatecompliance

    program

    FactpatternsandhypotheticalscontainedintheGuideillustratethegovernmentsinterpretationandapplicationoftheFCPAtocommonlyfacedcorruptionissues.

    Perhapsmostsignificantly,theGuideunderscorestheimportanceofacompanyscomplianceprogramto

    preventanddetectcorruptactivity.Thisviewisreinforcedthroughapracticalframeworkcompaniesofanysizecanusetoimplementrisk-basedanti-corruptionmeasures.

    Corporatecompl ianceprogram sTheGuideprovideshallmarksorelementsofaneffectivecomplianceprogram.Indoingso,itsetsforthprinciplesthatareperhapsmoredetailedbutverysimilartotheAdequateProceduresguidanceissuedundertheUKBriberyActandtheOrganizationforEconomicCo-operationandDevelopmentsGoodPracticeGuidanceonInternalControls,EthicsandCompliance.

    ManyprogramelementsintheGuidearesimilartoleadingpracticesadoptedbymanylargeglobalcompanies.TheGuideacknowledgesthatsmallandmedium-sizecompanieswillhavedifferentcomplianceprogramsfromlargemultinationalsandindoingsoimpliesthatcostandsizearefactorsinmeasurescompaniesshouldtaketoachievecompliance.

    Itendorsestheconceptofriskassessmentasfundamentaltodevelopingastrongcomplianceprogram,statingthat[o]ne-size-fits-allcomplianceprogramsaregenerallyill-conceivedandineffectivebecauseresourcesinevitablyarespreadtoothin,withtoomuchfocusonlow-riskmarketsandtransactionstothedetrimentofhigh-riskareas.1

    TenelementsofaneffectiveprogramaresetforthintheGuide:

    1. Commitmentfromseniormanagementanda

    clearlyarticulatedpolicyagainstcorruptionoftenreferredtoastoneatthetop,seniormanagementandboarddirectorsalikeareresponsibleforconveyingastrongmessagethatcorruptionwillnotbetolerated.

    2. Codeofconductandcompliancepoliciesand

    proceduresacodeofconductprovidesethicalguidelinesforthoseconductingbusinessonthecompanysbehalf.Acompanymayalsohavespecificanti-corruptionpoliciesandproceduresthataddressitsmostsignificantrisksandoutlineproperinternalcontrolsandmonitoringprocedures.

    3. Oversight,autonomyandresources

    responsibilityforthecomplianceprogramshouldbeassignedtoanappropriateseniorindividualorgrouptoprovidetheauthorityandautonomytooverseetheprogramandreporttothecompanysgoverningbody.

    4. Risk a ssessmentacompanyscomplianceprogramshouldbedesignedaroundandcommensuratewithitsuniqueriskprofile,takingintoaccountfactorssuchasitssize,structure,industry,geography,interactionswithforeigngovernmentsandinvolvementofbusinesspartners.Athoroughriskassessmentaddsefficiencyandcredibilitytoanti-corruptioncomplianceefforts.

    5. Trainingandcontinuingadvice acompanyshouldtakestepstoensurethatallemployeesareawareofthecompanysanti-corruptionpoliciesandprocedures,whichisoftenaccomplishedthroughperiodictraining.Certainkeyroles,suchasmanagement,sales,financeandbusinessdevelopmentpersonnel,mayreceiveenhancedtraining.

    6. Incentivesanddisciplinaryactionstoavoidtheappearanceofapaperprogram,thecorporatecomplianceprogrammustbeenforcedunequivocallythroughouttheorganizationwithcleardisciplinaryproceduresforviolatorsappliedtimelyandconsistently.Also,positiveincentives,bothfinancialandothermerit-basedrewards,mayreinforceacultureofcompliance.

    T

    FraudInvestigation&DisputeServices

    Forfurtherinformationplease contact:

    Brian Loughman,

    AmericasLeader

    +1 212 773 5343 | [email protected]

    Richard Sibery,

    AmericasFraud&InvestigationsLeader

    +1 212 773 6274 | [email protected]

    WilliamHenderson,

    AmericasAnti-CorruptionLeader

    +1 212 773 4389 | [email protected]

    Patrick OConnor,

    AmericasBusinessDevelopment Leader

    +1 212 773 4793 | [email protected]

    1AResource Guide to the U.S. Foreign Corrupt PracticesAct,Chapter5: GuidingPrinciples ofEnforcement,p.5.

    Audit was frequently mentioned in survey of leading IA organizations

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    Information

    security

    Traditional security models focus on keeping external attackers out. The reality is that

    there are as many threats inside an organization as outside. Mobile technology, cloud

    computing, social media, employee sabotage these are only a few of the internal

    threats organizations face. Externally, its not just about the lone hacker who strikes for

    kicks. Overall, the risk environment is changing. Often, security professionals complain

    that they are too busy reacting to immediate issues and have no time to anticipate what

    may be lurking around the corner. To have any hope of protecting your organizations

    critical assets, the business and security teams need to understand where youraf^gjeYlagfdan]k$afka\]gjgmlka\]&A\]fla^qaf_o`Ylqgmjgj_YfarYlagf[dYkka]kYkalk

    most important information and applications, where they reside and who has or may

    need access to them will enable the business to understand which areas of the security

    program are most vulnerable to attack.

    Although organizations have been dealing with opportunistic cyber attacks for years,

    eYfqfgof\l`]ek]dn]kl`]lYj_]lg^egj]kgh`akla[Yl]\Yf\h]jkakl]fl]^^gjlk&L`]k]

    attacks are focused on a single objective, often lasting over a long period of time and

    until the desired target is obtained. They leave few signs of disturbance because they are

    designed to remain hidden to acquire as much sensitive information as possible. In our

    experience, those at the greatest risk are information-intensive entities or organizations

    with intellectual property that is most attractive in emerging economies. Unfortunately,

    many organizations have no idea they are compromised until it is too late.

    In considering the audits below, IT internal audit can play a critical role in evaluating the

    organizations information security strategy and supporting program and partnering to

    improve the level of control.

    The audits that make an impact Cey iuestions to evaluate during audit

    Information security program assessment Evaluate the

    organizations information security program, including strategy,

    awareness and training, vulnerability assessments, predictive

    threat models, monitoring, detection and response, technologies

    and reporting.

    @go[gehj]`]fkan]g^Yfaf^gjeYlagfk][mjalqhjg_jYe]paklk7

    Is information security embedded within the organization, or is

    alYfALgfdqj]khgfkaZadalq7

    How well does the organization self-assess threats and mitigate

    l`]l`j]Ylk7

    Threat and vulnerability management program assessment

    Evaluate the organizations threat and vulnerability management

    (TVM) program, including threat intelligence, vulnerability

    a\]fla[Ylagf$j]e]\aYlagf$\]l][lagf$j]khgfk]Yf\

    countermeasure planning.

    @go[gehj]`]fkan]g^YLNEhjg_jYe]paklk7

    Is the TVM program aligned with business strategy and the risk

    Yhh]lal]g^l`]gj_YfarYlagf7

    Are the components of TVM integrated with one another, as

    o]ddYkoal`gl`]jk][mjalqYf\AL^mf[lagfk7

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    Business

    continuity

    management

    As organizations grow in size and complexity within the world of the extended

    ]fl]jhjak]$l`]aehY[lg^fgf%YnYadYZadalqg^Yfqj]kgmj[]k`YkeY_fa]\&@a_`%hjgd]

    events caused by natural disasters and technology infrastructure failures have increased

    awareness of the need to develop, maintain and sustain business continuity programs.

    Although these large-scale events such as the March 2012 Japanese earthquake and

    tsunami dramatically challenge the existence of some companies, there are smaller,

    less impactful but more frequent disruptions that cause many executives to question

    their organizations ability to react and recover. The big disasters, as well as these smaller

    disruptions, have prompted leading executives to hope for the best but prepare for the

    worst by investing in effective business continuity management (BCM).

    Effective BCM is rising in importance on the corporate agenda. Volatile global economies

    have shrunk margins for error. Companies that previously would have survived a

    ka_fa[Yfl\akYkl]jgj\akjmhlagfeYqfgof\l`]kYe]]n]flhmk`af_l`]aj[gjhgjYl]

    existence to the brink. Executives are realizing that effective BCM may be the only buffer

    between a small disruption and bankruptcy. Ernst & Youngs 2012 Global Information

    Security Survey found that BCM was once again viewed as the top priority in the next

    12 months by survey respondents.

    While BCM should be viewed as an enterprise-wide risk and effort, the reality is that it

    is often IT that is asked to lead critical planning activities and serve as lead facilitator. ITsystems and disaster recovery procedures are a cornerstone of the broader BCM plan,

    and thus, IT audit is well positioned to evaluate broader BCM procedures.

    The audits that make an impact Cey iuestions to evaluate during audit

    Business continuity program integration and governance

    audit Evaluate the organizations overall business continuity

    plan, including program governance, policies, risk assessments,

    business impact analysis, vendor/third-party assessment,

    strategy/plan, testing, maintenance, change management and

    training/awareness.

    Does a holistic business continuity plan exist for

    l`]gj_YfarYlagf7

    @go\g]kl`]hdYf[gehYj]lgd]Y\af_hjY[la[]7

    Akl`]hdYfl]kl]\7

    Disaster recovery audit Assess ITs ability to effectively

    recover systems and resume regular system performance in the

    event of a disruption or disaster.

    Are disaster recovery plans aligned with broader business

    [gflafmalqhdYfk7

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    20 Insights on governance, risk and compliance | May 2013

    Mobile

    Mobile computing devices (e.g., laptops, tablet PCs, smartphones) are in widespread use,

    allowing individuals to access and distribute business information from anywhere and

    at any time. With the increase in mobile device capabilities and subsequent consumer

    adoption, these devices have become an integral part of how people accomplish tasks,

    both at work and in their personal lives. The increasing demand for information from the

    mobile workforce is driving changes in the way organizations support and protect the

    gog^af^gjeYlagf&Oal`Yfql][`fgdg_a[YdY\nYf[]e]fl[ge]kf]o[`Ydd]f_]k^gjl`]

    enterprise, including:

    Potential loss or leakage of important business information

    K][mjalq[`Ydd]f_]k_an]fl`]jYf_]g^\]na[]k$gh]jYlaf_kqkl]ek$Yf\jeoYj]

    limitations and vulnerabilities

    Theft of the device due to the small size

    Compliance with state, federal and international privacy regulations that vary from one

    jurisdiction to another as employees travel with mobile devices

    Navigation of the gray line on privacy and monitoring between personal and company

    use of the device

    IT internal audits knowledge of the organizations mobile strategy needs to evolve as

    quickly as the mobile landscape. Evaluating these risks and considering the audits below

    oadd`]dhYm\alY\\nYdm]lgl`]gj_YfarYlagfo`ad][gfjeaf_c]qjakckYj]o]ddeYfY_]\&

    The audits that make an impact Cey iuestions to evaluate during audit

    EgZad]\]na[][gf_mjYlagfj]na]o Identify risks in mobile

    device settings and vulnerabilities in the current implementation.

    This audit would include an evaluation of trusted clients, supporting

    network architecture, policy implementation, management of

    dgklgjklgd]f\]na[]k$Yf\nmdf]jYZadalqa\]fla[Ylagfl`jgm_`

    f]logjcY[[]kkaZadalqYf\hgda[q[gf_mjYlagf&

    How has the organization implemented bring your own

    \]na[]:QG

    9j]l`]ja_`lhgda[a]k'egZad]kljYl]_a]kafhdY[]7

    9j]egZad]\]na[]keYfY_]\afY[gfkakl]fleYff]j7

    9j][gf_mjYlagfk]llaf_kk][mj]Yf\]f^gj[]\l`jgm_`hgda[q7

    @go\go]eYfY_]dgklYf\klgd]f\]na[]k7

    O`Ylnmdf]jYZadala]k]pakl$Yf\`go\go]eYfY_]l`]e7

    Mobile application black box assessment Perform audit using

    different front-end testing strategies: scan for vulnerabilitiesusing various tools, and manually verify scan results. Attempt to

    ]phdgall`]nmdf]jYZadala]ka\]fla]\afegZad]o]ZYhhk&

    O`Ylnmdf]jYZadala]k[YfZ]km[[]kk^mddq]phdgal]\7

    How do we respond when exploited, and do we know anafljmkagf`Ykg[[mjj]\7

    Mobile application gray box assessment Combine traditional

    source code reviews (white box testing) with front-end (black

    box) testing techniques to identify critical areas of functionality

    and for symptoms of common poor coding practices. Each of

    these hot spots in the code should be linked to the live instance

    of the application where manual exploit techniques can verify the

    existence of a security vulnerability.

    How sound is the code associated with the mobile applications

    mk]\oal`afl`]gj_YfarYlagf7

    O`Ylnmdf]jYZadala]k[YfZ]]phdgal]\oal`afl`][g\]7

    Recommended reading

    Mobile device security:

    understanding vulnerabilities

    and managing risk

    www.ey.com/GRCinsights

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    Cloud

    Many organizations are looking to cloud computing to increase the effectiveness of

    ALafalaYlan]k$j]\m[][gklg^af%`gmk]gh]jYlagfk$af[j]Yk]gh]jYlagfYd]paZadalqYf\

    generate a competitive advantage. This is attained by shifting to a user of IT services, as

    organizations no longer need to build and maintain complex internal IT infrastructures.

    Cloud computing is evolving at a fast pace, giving companies a variety of choices when

    looking to restructure their IT organization. However, like most technology changes,

    cloud computing presents its share of risks and challenges, which are too often

    overlooked or not fully understood by businesses that are quick to embrace it. Theserisks and challenges include:

    Providers not living up to service level agreements (SLAs), resulting in cloud

    architecture or deployment challenges

    Evolving cloud standards increasing the risk that a companys systems wont work with

    the providers

    Legal and regulatory risk in how information is handled in the cloud

    Af^gjeYlagfk][mjalqYf\hjanY[qjakckYjgmf\l`][gf\]flaYdalq$afl]_jalqYf\

    availability of data

    Cloud adoption and change management within an organization

    IT internal audit needs to understand how the organization is embracing cloud

    technologies and the risks the business faces based on the adopted cloud strategy.

    The audits that make an impact Cey iuestions to evaluate during audit

    Cloud strategy and governance audit Evaluate the organizations

    strategy for utilizing cloud technologies. Determine if the

    appropriate policies and controls have been developed to

    support the deployment of the strategy. Evaluate alignment

    of the strategy to overall company objectives and the level of

    preparedness to adopt within the organization.

    Akl`]j]YkljYl]_qYjgmf\l`]mk]g^[dgm\hjgna\]jk7

    Are there supporting policies to follow when using a cloud

    hjgna\]j79j]hgda[a]kafl]_jYl]\oal`d]_Yd$hjg[mj]e]flYf\

    ALhgda[a]k7

    Cloud security and privacy review Assess the information

    security practices and procedures of the cloud provider.

    This may be a review of their SOC 1, 2 and/or 3 report(s), areview of their security SLAs and/or an on-site vendor audit.

    Determine if IT management worked to negotiate security

    requirements into their contract with the provider. Review

    procedures for periodic security assessments of the cloud

    provider(s), and determine what internal security measures

    have been taken to protect company information and data.

    Has a business impact assessment been conducted for the

    k]jna[]kegnaf_lgl`][dgm\7

    Does your organization have secure authentication protocols^gjmk]jkogjcaf_afl`][dgm\7

    Have the right safeguards been contractually established with

    l`]hjgna\]j7

    Cloud provider service review Assess the ability of the

    cloud provider to meet or exceed the agreed-upon SLAs in the

    contract. Areas of consideration should include technology,

    legal, governance, compliance, security and privacy. In addition,

    internal audit should assess what contingency plans exist in

    case of failure, liability agreements, extended support, andthe inclusion of other terms and conditions as part of the

    service contracts, as well as availability, incident, and capacity

    management and scalability.

    What SLAs are in place for uptime, issue management and

    gn]jYddk]jna[]7

    @Ykl`][dgm\hjgna\]jZ]]fe]]laf_gj]p[]]\af_l`]KD9k7

    O`Ylakkm]k`Yn]l`]j]Z]]f7

    Does the organization have an inventory of uses of external

    cloud service providers, both sponsored within IT or direct byl`]Zmkaf]kkmfalk7

    Recommended reading

    Ready for takeoff:

    preparing for your

    journey into the cloud

    www.ey.com/GRCinsights

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    9kl`]ALjakchjgd]Yf\l`j]YldYf\k[Yh]jYha\dq[`Yf_]kYf\jakckaf[j]Yk]$[gehYfa]k

    need to change their mindset and approach toward IT risk to address a new normal. Now

    more than ever, IT issues are issues of importance to the C-suite. Boards of directors,

    Ym\al[geeall]]k$_]f]jYd[gmfk]dkYf\[`a]^jakcg^[]jkf]]\lgogjcYdgf_ka\]AL

    d]Y\]jkYf\af^gjeYlagfk][mjalqYf\hjanY[qg^[]jklg^mddqY\\j]kkl`]ajgj_YfarYlagfk

    risk management level of due care, approach and preparedness and to implement an IT

    risk management program that is adequate and effective in managing cyber risks. It iscritical that IT functions are able to effectively address the following questions:

    Can you articulate your strategy to identify, mitigate and monitor IT risks to the

    Ym\al[geeall]]7

    @go\gqgmcfgol`Ylqgm`Yn]a\]fla]\Yddc]qALjakckl`Ylogmd\hj]n]fll`]

    [gehYfq^jgeY[`a]naf_[gjhgjYl]kljYl]_a]k$gZb][lan]kYf\afalaYlan]k7

    How do you make sure your risk framework continues to be relevant and continues

    lga\]fla^qh]jlaf]fljakcklgc]]hl`][gehYfqgmlg^ljgmZd]7

    The Securities and Exchange Commission, other regulators and the audit committee have

    increased their focus on companies managing risks holistically. Company stakeholders/

    shareholders expect the company to focus risk management activities and resources on

    areas with the greatest impact. Internal audit is uniquely positioned to help drive growthand create value to the company through reviewing IT risk management activities.

    IT risk

    management

    Recommended reading

    The evolving IT risk landscape:

    the why and how of IT risk

    management today

    www.ey.com/GRCinsights

    Afka_`lk gj]p][mlan]k-Use governance, risk andcompliance technology to

    turn risk into resultsImproveyourriskmanagementprogramandnancialperformance

    Economicvolatility,shareholderdemandsandanincreasinglycompetitive

    marketlandscapeareforcingorganizationstorethinktheirapproachto

    risk.Moreandmore,companiesarerealizingthattheabilityto managerisk

    hasaveryreal impactontheirbottomline.Infact,arecentErnst& Young

    globalsurveyofmorethan250leadingorganizationsfoundadirectlink

    betweeneffectiveriskmanagementpracticesandimprovednancialperformance.

    However,forbusinessestoimplementeffectiveriskmanagement

    practicesandreapthenancialbenets,theyllneedacomprehensiveandsustainablegovernance,riskandcompliance(GRC)processandtechnology

    solution.

    ArobustGRCtechnologysolutioncanhelpembedriskmanagement

    requirementsandpracticesintodailybusinessactivities.Thiscanimprove

    thecompanysabilityto: Identifyandrespondtorisk

    Providegovernanceandoversight

    Coordinateriskfunctionsandrequirements

    Optimizeprocessesandcontrols

    Ofspecialinterestto

    Chiefexecutiveoffic ers

    Chieffinancial officersHeadofin ternalaudit

    Use governance, risk and

    compliance technology to

    turn risk into results

    www.ey.com/5

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    The audits that make an impact Cey iuestions to evaluate during audit

    IT risk management strategy assessment Assess the

    framework and process IT has embedded within the function to

    assess and manage risks. Evaluate the actions taken to mitigate

    risks and the level of accountability within the process.

    @goo]dd\g]kALa\]fla^qjakck7

    O`Ylak\gf]gf[]Yjakcaka\]fla]\7

    9j]ALjakceYfY_]e]flhjg[]kk]k^gddgo]\7

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    InsightsonITriskBusinessbrieng

    September2011

    Building condencein IT programsFacilitating success through

    program risk management

    Program complexity is increasing at a faster rate than companies can adapt. While

    companies have been cautious with investments over the last few years, investment

    portfolios are now being expanded to keep up with emerging trends (e.g., shared service

    centers, system implementations). As organizations continue to look for ways to take

    [gklkgmlg^l`]Zmkaf]kk$l`]qYj]mf\]jlYcaf_ka_fa[YflafalaYlan]klgj]\]ka_fYf\

    standardize business processes.

    Kh][a[lgAL$?Yjlf]jhj]\a[lkkh]f\af_oaddaf[j]Yk]YlYfYn]jY_]jYl]g -&+h]jq]Yjthrough 2015. Gartner also indicates that approximately 20% to 50% of a companys

    IT spending will be focused on programs and projects depending on an organizations

    initiatives. However, organizations continue to fail to deliver on their large IT programs.

    Approximately two out of three programs are not on budget, delivered too late and/or do

    fgl\]dan]jl`]]ph][l]\Z]f]lk&DYkldq$/(g^l`]eYbgj]fl]jhjak]j]kgmj[]hdYffaf_

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    O`ad][gehYfa]k`Yn]afn]kl]\ka_fa[Yfldqafaf[j]Ykaf_l`]ajcfgod]\_]Yf\

    capabilities in program and project management, this is not visible in the success

    rates. In our opinion, the lack of improvement is mainly due to increased complexity

    in business processes and the emerging technology landscape. Organizations are still

    failing to properly adapt their program approaches to this increased complexity. Research

    indicates a strong link between program maturity capabilities and program execution and

    eYjc]l[geh]lalan]f]kk&Afl]jfYdYm\al[YfhdYqYf]^^][lan]jgd]af[gfjeaf_l`]ja_`l

    processes are in place to manage programs and those processes and controls are being

    executed appropriately.

    Strategy deployment

    through portfolio

    management: a risk-

    based approach

    www.ey.com/GRCinsights

    Hrogrammanagement

    Recommended reading

    :mad\af_[gf\]f[]af

    IT programs: facilitating

    success through program

    risk management

    www.ey.com/GRCinsights

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    25Insights on governance, risk and compliance | May 2013

    The audits that make an impact Cey iuestions to evaluate during audit

    Project management methodology audit Assess the design

    of processes and controls in place to manage projects against

    leading practices.

    Are the right processes and controls in place to provide

    that projects are delivered on time, on budget and with the

    ja_`lj]kgmj[]k7

    9j][gfljgdkafhdY[]lge]Ykmj]Y[`a]n]\Z]f]lkY_Yafkl

    afl]f\]\Z]f]lkY^l]jhjgb][l[gehd]lagf7

    Project and program execution audit Evaluate common

    areas of high risk on programs (e.g., third-party contracting,

    business change, test strategy, data migration). Outputs provide

    [gf\]f[]lgeYfY_]e]fll`Yl`a_`%jakcYj]Yk`Yn]Z]]f

    af\]h]f\]fldq[`][c]\Yf\n]ja]\lgd]Y\af_hjY[la[]&

    Is project/program management methodology being

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    O`Ylak\gf]o`]fhjgb][lkYj]mf\]jh]j^gjeaf_7

    @goakhjgb][ljakcYkk]kk]\Yf\eYfY_]\7

    Portfolio risk review Review strategy, projects and

    programs to assess alignment. This review focuses on

    assessing the prioritization of the project portfolio in support of

    increasing value and reducing the risk that the transformation

    portfolio exposes.

    Do the right governance processes exist to provide that

    hjgb][lk'hjg_jYekYda_flg[gehYfqkljYl]_q7

    @goakl`]hgjl^gdageYfY_]\Yk[gjhgjYl]gZb][lan]k[`Yf_]7

    Shared service center review Evaluate the processes and

    controls related to a shared service center implementation.

    In-scope processes are assessed to verify that control points are

    in place and have also been optimized to leverage available

    technology (e.g., automated controls).

    O`Ylakl`]hjg[]kk gjljYfkalagfaf_lgl`]k`Yj]\k]jna[][]fl]j7

    O`Ylhjg[]kk]kYj]af%k[gh]7@Ykl`][gfljgd^jYe]ogjcZ]]f

    j]na]o]\YkhYjlg^l`]ljYfkalagfhjg[]kk7

    Akl`]j]Y[gfljgdkogjcklj]Ye^gjl`]aehd]e]flYlagf7

    O`Yll][`fgdg_qakZ]af_mladar]\YkhYjlg^l`]ljYfkalagf7

    Process redesign review Assess the businesss plan for

    redesigning its business processes as part of a major initiative

    (e.g., system implementation). The internal audit team focuses

    on the project plan, management structure and approach to

    redesigning the control framework for the in-scope processes.

    O`gYj]l`]hjgb][ll]Yee]eZ]jkYf\o`YlYj]l`]ajjgd]k7

    Akl`]j]Y\g[me]fl]\[gfljgdkogjcklj]Ye7

    What is the process for leveraging automation and system

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    Opportunities for integrated audits between IT and operational audit

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    With increased focus on cost reduction in a global economy struggling to recover, effective

    software asset management and IT asset management can have a very positive impact

    by helping to reduce license-related expenses, improve IT service management by more

    ]^[a]fldqeYfY_af_ALYkk]lafn]flgja]k$Z]ll]jeYfY_][gehdaYf[]%j]dYl]\jakcYf\

    ]n]faehjgn]gn]jYddgh]jYlaf_]^[a]f[a]k&D]Y\af_AL\aj][lgjkYf\l`][`a]^af^gjeYlagf

    g^[]jklgo`gel`]qj]hgjlYj]j]Ydaraf_l`Yl]^^][lan]dqeYfY_af_kg^loYj]Ykk]lk[Yf

    be a strategic advantage. For example, effective asset management: Potentially reduces liability risk by maintaining license compliance and avoiding

    related penalties

    Lowers potential costs by helping to avoid license and other IT asset overbuying

    @]dhklgegj]]^[a]fldqeYfY_]l`]gl`]joak]j]kgmj[]%\jYafaf_Yf\dYZgj%afl]fkan]

    compliance processes

    Limits potential reputational risks associated with license violations or compliance-

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    Software licenses currently account for about 20% of typical IT costs, and the already

    pervasive use of software continues to rise. At the same time, many IT directors are noticing

    that their software vendors have become more diligent in ensuring that their customers

    remain in compliance. IT leaders, members of the C-suite and shareholders have come to

    expect increasingly more from their investments, including those which rely on IT functions.

    As IT auditors, it is critical that software and IT asset management processes and controls

    are well understood. Its not just about cost management strong IT asset management

    processes affect the following, as examples:

    IT service management IT asset management is critical to effectively locate and

    service assets, replace and retire existing assets, etc.

    Information security Without a clear view of existing IT assets and software, its

    \a^[mdllghjagjalar]Yf\]nYdmYl]l`]Ykkg[aYl]\k][mjalqjakcg^l`gk]Ykk]lk&

    IT contract management It is understandable that without an effective way to manage

    Yfgj_YfarYlagfkALYkk]lk$aleYqZ]]imYddq\a^[mdllgmf\]jklYf\o`Yl[gfljY[lk]paklwith vendors for those assets, whether they are managed in a cost-effective manner and

    whether any violations from contracts may exist.

    Software'IT assetmanagement

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    The audits that make an impact Cey iuestions to evaluate during audit

    IT and software asset management process and control

    audit Assess the design and effectiveness of processes and

    controls that IT has deployed related to software and IT asset

    management. Review the impact of these processes on related

    IT processes such as IT service management, IT contractmanagement and information security.

    Do we have a comprehensive approach to IT asset and

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    @goo]dd\go]eYfY_]kg^loYj]da[]fk][gklk7

    Is there an IT and software asset management technology

    kgdmlagfafhdY[]lgkmhhgjll`]k]hjg[]kk]k7A^fgl$k`gmd\l`]j]Z]7

    Software license review H]j^gjeYj]na]og^ka_fa[Yfl

    software license agreements (e.g., ERPs) and evaluate the

    effectiveness of ITs software asset management process in

    practice. Assess opportunities for cost reduction from improving

    the management of software licenses.

    Are there opportunities to renegotiate software licensing

    agreements based on the way we actually utilize software

    n]jkmkl`]oYqgja_afYd[gfljY[lko]j]f]_glaYl]\7

    9j]o]nagdYlaf_Yfq]paklaf_[gfljY[lmYdY_j]]e]flk7

    IT contract management assessment Evaluate the IT

    organizations ability to manage contracts and how effectively

    IT and supply chain coordinate to manage costs and negotiate

    effective agreements.

    Are IT asset and software contracts planned, executed,

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    Are there shadow IT contractual agreements executed in

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    Effective software asset

    management: how to

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    www.ey.com/GRCinsights

    Recommended reading

    Opportunities for integrated audits between IT and operational audit

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    The social media elements that generate business opportunity for companies to extend

    their brands are often the same elements that have created IT-related risk. Like the

    borderless nature of social media itself, the various risks surrounding social media can

    be borne by multiple enterprise functions at the same time, challenging companies to

    understand how, when and where to engage their IT functions or plug risk coverage

    gaps. Legal, compliance, regulatory, operational and public relations issues are at the top

    of the list of potential IT-related social media risks that can ultimately cause erosion of

    customers, market share and revenue. For example, on most of the popular sites (Twitter,

    >Y[]ZggcYf\Dafc]\Af!$mk]jkYj]YZd]lg[j]Yl][gehYfqhjgd]kYf\[geemfa[Yl]gf

    behalf of the organization through social media channels. This can create marketplace

    confusion because of multiple messages and different audiences, policies and practices.

    Gl`]jegj]kh][a[`]Y\daf]%_jYZZaf_]pYehd]kg^kg[aYd%e]\aY%j]dYl]\jakckaf[dm\]2

    Employees involved in social media inadvertently leaking sensitive company information

    ;jaeafYd`Y[c]jkj]%]f_af]]jaf_[gf\]flaYdaf^gjeYlagf]&_&$dg_%afkYf\hYkkogj\k!

    based on information obtained from employee post

    Employee misuse of social applications while at work

    Hacked, faked or compromised corporate or executive Twitter or Facebook fan page

    or individual accounts Multiple platforms creating more access for viruses, malware, cross-site scripting

    and phishing

    Damage to a brand or company reputation from negative, embarrassing or even

    incriminating employee or customer posts, even those that are well-intended

    Failure to establish complete and fully compliant archiving and record-retention

    processes for corporate information shared on social media, especially in the health

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    IT is heavily relied on to enable social media strategies in coordination with marketing

    strategies. It is critical that IT audit has an understanding of the organizations social

    media strategy and the related IT risk and adds value by providing leading practice

    enhancements and assurance that key risks are mitigated.

    Social media

    risk management

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    The audits that make an impact Cey iuestions to evaluate during audit

    Social media risk assessment Collaborate with the IT

    organization to assess the social media activities that would

    create the highest level of risk to the organization. Evaluate the

    threats to the organizations information security through the

    use of social media. This audit may be combined with a sociale]\aY_gn]jfYf[]Ym\allgl`]f[gfjehgda[a]k`Yn]Z]]f

    design