How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

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Malware

In the past, viruses were created with the sole purpose of wreaking havoc on the infected systems. A large fraction of today’s malware, on the other hand, are designed to generate revenues for the creator. Spyware, botnets, and keyloggers steal information from your system or control it so that someone else can profit. In other words, the motivation for making them is now more attractive than before.

Keyloggers can reveal your usernames, passwords, PIN numbers, and other authentication information to their creators by recording your key strokes. This information can then be used for breaking into various accounts: credit cards, payment programs (like PayPal), online banks, and others. You’re right, keyloggers are among the favourite tools of individuals involved in identity theft.

Much like the viruses of old, most present day malware drain the resources, such as memory and hard disk space, of contaminated systems; sometimes forcing them to crash. They can also degrade network performance and in extreme cases, may even cause a total collapse.

If that’s not daunting enough, imagine an outbreak in your entire organisation. The damage could easily cost your organisation thousands of euros to repair. That’s not even counting yet the value of missed opportunities.

Entry points for malware range from optical disks, flash drives, and of course, the Internet. That means, your doors could be wide open to these attacks at this very moment.

Now, we’re not here to promise total invulnerability, as only an unplugged computer locked up in a vault will ever be totally safe from malware. Instead, this is what we’ll do:

Perform an assessment of your computer usage practices and security policies. Software and hardware alone won’t do the trick.
Identify weak points as well as poor practices and propose changes wherever necessary. Weak points and poor practices range from the use of perennial passwords and keeping old, unused accounts to poorly configured firewalls.
Install malware scanners and firewalls and configure them for maximal protection with minimal effect on network and system performance.
Implement regular security patches.
Conduct a regular inspection on security policy compliance as well as a review of the policies to see if they are up to date with the latest threats.
Keep an audit trail for future use in forensic activities.
Establish a risk management system.
Apply data encryption where necessary.
Implement a backup system to make sure that, in a worst case scenario, archived data is safe.
Propose data replication so as to mitigate the after effects of data loss and to ensure your company can proceed with ‘business as usual’.

Once we’ve worked with you to make all these happen, you’ll be able to sleep better.

Other defences we’re capable of putting up include:

Why Spreadsheets can send the Pillars of Solvency II Crashing Down

Solvency II is now fast approaching and while it may provide added protection to policy holders, its impact on the insurance industry is not all a bed of roses. Expect insurance companies to restructure, increase manpower, and raise spending on actuarial operations and risk management initiatives. Those that cannot, will have to go. But what have spreadsheets got to do with all these?

Well, spreadsheets aren’t really the main casts in this blockbuster of a regulatory exercise but they certainly have a significant supporting role to play. Pillar I of Solvency II, which calls for improved supervision on internal control, risk management, and corporate governance, and Pillar II, which tackles supervisory reporting and public disclosure of financial and other relevant information, both affect systems that have high-reliance on spreadsheets.

A little background about spreadsheets might help.

Who needs an IT solution when you can have spreadsheets?

Everyone in any organisation just love spreadsheets; from the office clerk to the CEO. Because they’re so easy to use (not to mention they’re a staple in office computers), people employ them for processing numbers and as an all-around tool for planning, forecasting, reporting, complex modelling, market data analysis, and so on. They make such tasks faster and easier. Really?

You probably haven’t heard of spreadsheet hell

Unfortunately, spreadsheets do have certain shortcomings. Due to their inherent structure and lack of controls, it is so easy to commit simple errors like an accidental copy paste, an omission of a negative sign, an incorrect data input, or an unintentional deletion. Such shortcomings may seem harmless until your shareholders discover a multi-million discrepancy in your financial report.

And because spreadsheet errors can go undetected for a long time, they are constant targets of fraudsters. In other words, spreadsheets are high risk applications.

Solvency II Impact on Spreadsheet-based Financial and IT Systems

Regulations like Solvency II, are aimed at reducing risks to manageable levels. Basically, Solvency II is a risk-based system wherein a company?s capital requirements will depend on its measured riskiness. If companies want to avoid facing onerous capital requirements, they have to comply.

The three pillars of Solvency II have to be in place. Now, since spreadsheets (also known as User Developed Applications or UDAs) are high-risk applications with weak control features and prone to produce inaccurate reports, companies will have a lot of work to do to establish Pillars II and III.

There are at least 8 articles that impact spreadsheets in the directive. Article 82, for example, which requires firms to ensure a high level of data quality and accuracy, strikes at the very core of spreadsheets? weakness.

A whitepaper by Raymond Panko entitled ?Spreadsheets and Sarbanes-Oxley: Regulations, Risks, and Control Frameworks? mentioned that 94% of audited real world operational spreadsheets that were included in his study were found to have errors and that an average of 5.2% of all cells in the audited spreadsheets had errors.

Furthermore, many articles in the directive call for the enforcement of better documentation. This is one thing that’s very tedious and almost unrealistic to do with spreadsheets because just about anyone uses them. Besides, with different ‘versions? of the same data existing in different workstations throughout the organisation, it would be extremely difficult to keep track of them all.

Because of spreadsheets you now need an IT solution

It is clear that, with the growing number of regulations and the mounting complexity of tasks needed for compliance, spreadsheets no longer belong in this era. What you need is a server-based solution that allows for seamless collaboration, data reliability, data consistency, increased security, automatic consolidation, and all the other features that make regulation compliance more doable.

One important ingredient for achieving Solvency II compliance is sound data risk management. Sad to say, the ubiquitous spreadsheet will only expose your data to more risks.

More Spreadsheet Blogs

Spreadsheet Risks in Banks

Top 10 Disadvantages of Spreadsheets

Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry

How Internal Auditors can win the War against Spreadsheet Fraud

Spreadsheet Reporting – No Room in your company in an age of Business Intelligence

Still looking for a Way to Consolidate Excel Spreadsheets?

Disadvantages of Spreadsheets

Spreadsheet woes – ill equipped for an Agile Business Environment

Spreadsheet Fraud

Spreadsheet Woes – Limited features for easy adoption of a control framework

Spreadsheet woes – Burden in SOX Compliance and other Regulations

Spreadsheet Risk Issues

Server Application Solutions – Don’t let Spreadsheets hold your Business back

Why Spreadsheets can send the pillars of Solvency II crashing down

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How to Improve Corporate Efficiency through IT

When revenues are low, what do you do to improve your profit? Obviously, those same revenues should at least remain the same. So, the objective would be to deliver the same products and services for less cost. More for less. Such is the essence of corporate efficiency.

There are many things that can make a company inefficient. There are outdated procedures, poor coordination between departments, managers? lack of business visibility, and prolonged down times, to mention a few. As a company grows, these issues get more severe.

You can overcome all these by deploying the right IT solutions. But don’t IT solutions increase spending instead? Au contraire. The last couple of decades have seen the rise of IT solutions that help companies’realise obvious cost savings in no time.

Streamline processes and keep departments in-sync

Company inefficiencies are largely due to outdated systems and procedures. These systems and procedures were not built for the dynamic and complex business environments of today that are being shaped by increasingly onerous regulations, fierce and growing competition, significant economic upswings and downturns, new battlefronts (like the Web) and logistical strategies (like outsourcing), and IT-savvy crooks.

So when your employees force outdated systems to meet today?s business demands, they’re just not able to deliver. At least not efficiently.

Another major cause of inefficiency is the discordance among departments, business units, and even individual staff members themselves. There are those who still use highly personalised spreadsheets and other disparate applications, which make data consolidation take forever and the financial close a perennial headache.

Costly devices like mobile phones, netbooks, and tablet PCs, which are supposedly designed to provide better communication, are not fully maximised. If these are subsidised by the company, then they also contribute to company inefficiency.

One way to deal with these issues is to deploy server based solutions. By centralising your IT system, you can easily implement various improvements that can pave the way for better communication and collaboration, stronger security, faster processes and transactions, and shorter down times for troubleshooting and maintenance. All these clearly translate to cost savings.

Gain better visibility

Corporate efficiency can be improved if your decision makers can make wise and well-informed decisions, faster. But they can only do this if reports they receive from people down the line are timely, accurate, and reliable. Basically, data should be presented in a way for managers to gain quick insights from.

If your people take too much time scrutinising, interpreting, and reconciling data, you can’t hope to gain a significant competitive advantage. Equally important to managing an ongoing project is the speed at which you make a go/no go decision to start or stop a project. A wise, quick decision will help you avoid wastage.

The same holds true when making purchases and investment decisions. It’s all about quickly eliminating waste and investing only on those that will give you fast, positive returns.

Clear business visibility will allow managers to allocate resources where they are most effective, to pinpoint what products and services being offered are more profitable, and to identify which customers are giving better business from an overall perspective.

These are all possible with business intelligence. We know, we know. You’ll say BI solutions will force you to break the bank. Not anymore. At least, not all. There are already two main types of BI solutions: on-premise and SaaS. The latter will generally cost you less.

Of course, each type has its own advantages, and you’ll really have to look into the size of your organisation, the number of source systems your decision-making platform is connected to, integration requirements, budget, etc. to make sure you get the most out of your investment.

But IT solutions cost an arm and a leg

Again, not anymore. These days, you can find IT products that are faster, more functional, and more powerful than their predecessors at a fraction of the cost. When it comes to getting more affordable IT products and services, you now have many options.

For example, you can turn to open source solutions to save on license costs. These solutions are typically backed by vibrant and helpful communities where you can find an extensive source of technical support – many of which are for free. With popular open source products, you can easily tap from a large pool of developers with affordable rates any time you want to make system enhancements or customisation.

On another front, virtualization solutions allow you to save on CAPEX and OPEX by eliminating certain expenses normally used for setting up infrastructure or buying hardware and maintaining them. Server virtualisation, for instance, will allow you to consolidate servers and put them together into just one machine, while desktop virtualisation will enable you to eliminate unproductive hours associated with desktop down times by allowing you to redeploy a malfunctioning desktop very quickly.

Closely related to those are cloud-based solutions like SaaS (Software as a Service), IaaS (Infrastructure as a Service), and DCoD (Data Center on Demand). SaaS and IaaS will help you realize savings in acquisition and maintenance costs for software and hardware, while DCoD?s scalable services allow you to request for additional capacity, power and storage only as you need them, thus making you spend only according to your current infrastructure requirements.

Like we said, there are many, many options out there just waiting to be tapped.