IT Audit Webinar: Your Questions Answered

By Gordon Braun, Managing Director
IT Audit

 

 

 

Following up on a recent blog post discussing the results of the 6th Annual IT Audit Benchmarking Study from ISACA and Protiviti, I want to revisit the subject by answering some of the audience questions we were unable to address live during the webinar, which I co-hosted with my Protiviti colleague David Brand and ISACA director Ed Moyle.

(I want to stress that we receive many great questions during our webinars but they may not always be answered in the limited window allowed by our webinar time constraints. I invite you to subscribe to our blog as we often follow up with these questions here.)

Q: How can growing organizations move from a reactionary approach to IT risk management to a more proactive approach and get ahead of emerging risk issues?

To be proactive, I think it is very important to invest in relationship-building activities with IT. Find a way to get invited to IT meetings and town halls and get added to key IT distribution lists. If you are not being included in those meetings, if you are not receiving IT organization announcements/distributions, and if you are not generally being considered a part of the IT “family,” you need to revisit your approach and take action to change your relationship status.

The goal should be to establish an ongoing dialogue so that internal audit knows what projects are in the pipeline and what technologies may be emerging in order to be appropriately  involved at the earliest stages of these projects. I’ve seen a lot of IT audit organizations struggle with this. It’s hard to see the risks around the corner if the IT auditor does not know in which direction IT is headed. Too often, IT audit is reacting well after the fact, and that’s not a good position to be in.

I also suggest that IT auditors partner with enterprise risk management to maintain a good understanding of the strategic direction of the company. An IT auditor needs to understand the direction of an organization in order to identify risks associated with the future demand for technology, as well as the technology skill sets likely to be required.

For IT, the most important incentive for building a strong relationship with IT audit is the value IT audit can bring to that organization, and IT audit should be able to communicate that benefit. IT auditors are not only good evaluators, but they are individuals that can help the IT organization be successful in achieving its objectives. When reporting on IT, it is important to consider the context in which IT is operating. How information is presented — whether it is perceived as collaborative and constructive — can have a significant impact on the IT / IT audit relationship.

Q: Do you see more IT audit shops leveraging continuous auditing to focus on some of the challenges highlighted in the survey?

I see the second line of defense doing more continuous monitoring and then IT audit shops allowing for flexibility in the IT audit plan to allow for a shift based on the findings of continuous monitoring activities. As issues are identified in the second line, top-performing audit shops are able to shift activities and focus on emerging or more urgent items that require attention.

Q: Should the IT audit director report directly to the audit committee?

Not usually. While we are seeing the IT audit director attend more audit committee meetings, the line of reporting is typically up through the chief audit executive.

Q: Where does the responsibility for IT risk assessment live with the IT organization or the IT audit function?

Certainly, IT has to be responsible for managing its own risk. But it is very common today to have a specific IT risk assessment process occurring through the internal audit organization. As technology, automation and digitization become a more integral part of our lives, boards and management are going to want more assurance around the tech environment, and that starts with an effective risk assessment process.

A coordinated or collaborative activity is the smart approach. It is best practice that IT does its own risk assessment. The trouble starts when there is a significant disconnect between the assessment results coming from IT and IT audit. Parallel assessments are perfectly legitimate and expected but there should be some effort to coordinate, collaborate and understand/reconcile any major differences.

Ultimately, you want to have an efficient risk management and IT governance process that delivers results that are easily understandable and interpreted by executive management and the board.

You can access the archived version of the webinar and more Q&As from it here.

Cyber Safety Tips for Private Equity Managers

By Michael Seek, Director
Internal Audit and Financial Advisory

 

 

 

Cybersecurity vendor FireEye, in March, reported an increase in fake emails targeting lawyers and compliance officers with malware disguised as a Microsoft Word document from the Securities and Exchange Commission. That, on the heels of a reported uptick in fake drawdown requests targeting private equity clients, prompted us to put together a list of ways private equity firms and portfolio managers can protect their clients from these increasingly sophisticated attacks. This list has applicability to other companies as well.

  1. Distributions – Protect investors (both internal and external) with controls requiring positive verification of the Investor’s identity prior to making any change to banking/wire instructions. The request should come directly from the Investor or from a contact that the Investor has provided written authorization to act on the Investor’s behalf. An independent email should be sent to the authorized email contact of record notifying them that a change was made and advising them to contact the firm if they did not request the change. This process should mirror those utilized by banks.
  2. Capital Calls/Drawdowns – Capital calls should be presented to Investors via a secure system or mechanism other than email. Note that hackers have been known to establish authentic-looking fake websites designed to capture LP account information. Protiviti recommends strong multifactor authentication routines (again, similar to banks) to thwart such efforts.
  3. System Security – Continuous monitoring for breach detection and a vigorously tested and rehearsed response/recovery plan have become the table stakes for operating any financial services business. If you have a proprietary system for investor distributions, that system should be secured on par with your ERP system.
  4. Deal Sourcing Data – At Protiviti, we emphasize the importance of knowing your “crown jeweIs” — that is, critical data that must be protected, such as investor account data. However, the protection of pipeline data, and information on target companies (e.g., potential deals), is at times overlooked. Data security must be established over systems, sites and network drives where confidential deal data is stored, including security over data rooms associated with due diligence activities. Additionally, employee communications should be monitored to ensure that no confidential information is being “leaked” via company networks.
  5. Board Members – Boards of directors need to ensure that the organizations they serve are improving their cybersecurity capabilities continuously in the face of ever-changing cyber threats. This point was mentioned in our recent Board Perspectives newsletter (Issue 90).That need also extends to the security of board emails and electronic communication of sensitive board materials. Of particular concern is the widespread use of “free” email services. Given the confidentiality of the information contained in many board emails, many organizations provide directors with in-house email addresses.

In a world rife with cyber crime, the incentives to commit it grow ever stronger as just about everything of value – whether an action or an asset – has a digital component. Vigilance continues to be the name of the cyber risk game – for private equity firms and portfolio managers in managing their clients, and for other sectors as well.

Fintech Perspective: Balancing Speed to Market With Sound Risk Management

 

 

Christopher Monk, Managing Director
Business Performance Improvement

and

Tyrone Canaday, Managing Director
Technology Consulting

 

As financial institutions develop innovative technology, in-house or by partnering with fintech companies, they need to carefully consider regulatory requirements for both third-party risk management and information security. Protiviti hosted a Fintech Innovation webinar on April 5, which addressed the need for banks and other financial institutions to balance sound third-party risk management with the desire for ensuring speed-to-market for new products and services in a bid to remain competitive in today’s marketplace. The attendees primarily consisted of traditional financial services companies (81 percent) – mainly banking organizations and some insurers. Fintech companies represented seven percent of the audience.

We want to highlight some of the results of the polling questions submitted during the webinar because they give insight into the current state of fintech innovation and the areas banking firms are most concerned about as they work to achieve a balance between innovation and sound risk management.

The collaboration is not without challenges. Of those saying they are facing challenges with their third-party risk management programs (a large majority), one-third consider coordinating activities and workflow between different groups in the organization responsible for managing parts of third-party risk, such as the business (the first line of defense), the vendor management office, procurement and the compliance and information security functions, to be the most difficult. Seventeen percent of respondents highlighted the difficulty in gaining coverage of all of the organization’s third parties across all of the lines of business in the enterprise. Other issues include understanding and keeping up to date with all of the evolving regulations, and managing the workload by enhancing the efficiency and scalability of the third-party risk management process.

Most significantly, almost half (44 percent) of all respondents indicated that their organization does not track the risks associated with fintech companies and other vendors effectively.

Addressing the challenges

For institutions that are just beginning their innovation journey, a good starting point is to ensure they understand what their current capabilities are, including those for actively managing third-party risks as well as data security and privacy risks. From there, firms can then begin to consider pushing forward with developing innovative products using a structured research and development (R&D) lifecycle. By layering the two efforts together, firms can ensure third-party considerations are addressed throughout the process, and the level of risk management rigor and scrutiny is increased as they progress through the R&D gates.

During our webinar, Protiviti experts guided attendees through the many ways in which fintech companies are disrupting the marketplace and offered a new third-party risk management framework that can help manage the risks inherent with partnering with smaller, startup firms and launching new technology products and services. You can access the free recorded version here, and we recommend a full listen.

For even more detail on how traditional financial institutions can balance the need for speed-to-market for new products with the need for information security and risk management compliance as best practices, refer to our newly published white paper: Enabling Speed of Innovation Through Effective Third-Party Risk Management.

Paul Kooney of Protiviti’s Security and Privacy practice contributed to this content.

Health Check on Emerging Growth Companies: PCAOB Reports High Incidence of Material Weaknesses

By Charles Soranno, Managing Director
Financial Reporting Compliance and Internal Audit

 

 

 

A new white paper from the Public Company Accounting Oversight Board (PCAOB) and an April increase in qualifying revenue limits have put emerging growth companies (EGCs) in the news recently.

The EGC designation, established under the Jumpstart Our Business Startups (JOBS) Act of 2012, makes it easier for small and growing businesses — specifically those on track for an initial public offering — to attract investors and access capital by relaxing regulatory requirements and cutting some red tape. There are a number of benefits to a registrant being classified as an EGC – see Protiviti’s Guide to Public Company Transformation for what they are.

The original law established a revenue cap of $1 billion for a company to qualify as an EGC, but provided for that cap to be adjusted every five years for inflation. The Securities and Exchange Commission (SEC) made the first adjustment in April 2017, raising the revenue cap to $1.07 billion.

Another provision of the JOBS act was a mandate for the PCAOB to report via white papers, semiannually, on the extent to which EGCs actually benefitted from regulatory relief, and any unintended consequences stemming from the more permissive environment. The purpose of the PCAOB’s white papers is to provide general data about EGCs to inform the analysis contained in PCAOB rulemaking releases regarding the impact of applying new standards to the audits of EGCs.

The latest white paper, published in March 2017, found that of 1,951 companies reporting as EGCs in the 18 months prior to the reporting period, more than half (51 percent), received an explanatory paragraph in their most recent auditor’s report expressing substantial doubt about the company’s ability to continue as a going concern. Equally important, within that group of 1,951 EGC filers, 1,262 provided a management report on internal control over financial reporting in their most recent annual filing, and 47 percent – nearly one-half of all EGC filers – reported material weaknesses.

Protiviti explores the findings in the PCAOB’s March white paper at length in a recent Flash Report, but I wanted to highlight a few of the takeaways here.

First and foremost, while certain regulatory exemptions and benefits may be attractive, they do not mean that EGCs should accept or minimize issues surrounding potential findings of material weaknesses. These deficiencies in internal control over financial reporting may undermine a company’s reputation and reduce company value, to say the least.

The risk is real and should be addressed proactively. Protiviti has developed a financial reporting risk profile (FRRP) to identify financial reporting issues in advance and manage them to avoid potential financial restatements.

An effective FRRP focuses on six areas: accounting principle selection and application, estimation processes, related-party transactions, business transaction and data variability, sensitivity analysis, and measurement and planning. The underlying objective is to identify the most likely areas of potential misstatements and apply the appropriate oversight and control.

Second, EGCs should take the steps necessary to document key business processes so that these processes are well-defined and repeatable, reducing reliance on ad hoc activity by key employees. These processes may include a fair amount of financial reporting; related policies and activities, such as those that aid in the preparation of financial schedules for external auditors in the support of audits; filings; executive compensation; and employee benefits. Pre-public companies should design and implement a process for documenting conclusions on reporting and accounting matters.

Internal controls and documentation are critical because they minimize the risk of material weaknesses in the organization’s financial reporting. Consider the effects of just one material weakness: erosion of shareholder confidence, potential share price reduction, a fair amount of distraction throughout the organization, reduced brand quality, and significant remediation costs.

The high incidence of material weaknesses among EGCs is disappointing but, in many cases, generally preventable. It is important not to wait until the first auditor attestation to address potential issues. Many of the preventive measures – governance protocols, fraud controls, internal controls over financial reporting – should be in place prior to the company’s first public filing (e.g., 10Q filings, 302/906 certifications), and others should be in place prior to the initial management assertion on the effectiveness of internal control over financial reporting, as required by Sarbanes-Oxley Section 404(a). If these areas have not been addressed and the first public filing is upcoming, the organization should prepare itself by putting in place a robust remediation program. See the Protiviti Flash Report for additional points and information.

 

The Role of the Business in Ensuring a Successful ERP Implementation

By Ronan O’Shea, Managing Director
Global ERP Solutions Practice Leader

 

 

 

As organizations implement new enterprise resource planning (ERP) systems as part of digitization, process improvement and platform modernization, it is becoming increasingly critical not just for IT, but also for the business units themselves, to understand their central role in the overall success of these initiatives. The implementation of an enterprise system, or any other major IT system, should never be viewed as just an IT project because, ultimately, it is a business project with business objectives.

Even when a project is supported by a strong system integrator, it is critical for business stakeholders to assume responsibility for key activities before, during and after the implementation. Failure to do so can lead to project delays, budget overruns, business disruption and low user adoption, among other things.

There are seven key responsibilities that businesses need to understand and accept in any successful system implementation. They are:

Program Management and Governance – Although most system integration firms provide project management capabilities, common gaps include oversight of internal business and IT resources, management of other vendors, and engagement with company leadership. Proper oversight requires a more robust approach, from the establishment of a project management office (PMO) structure and assignment of roles, to the establishment of a comprehensive program-wide plan and a “single source of truth” for program status.

Business Process Readiness and Solution Design – Systems integrators are usually technical experts, not business process experts. Businesses should define the vision and operational expectations of a new system with regard to each business process. Specifically, the business must ensure that the technical solution the system integrator proposes will satisfy the business process vision and future-state goals. To meet operational expectations, the business should design process models for the end-to-end future state of each business process that the new system will impact. This will help system integrators focus on blueprinting rather than designing future processes, which typically is not their core expertise.

Organizational Change Enablement – As the solution design is established, the organizational impact of system and process changes must be determined to ensure that the anticipated benefits are realized. Training alone is not sufficient. Ultimately, the goal is a change enablement plan that will raise awareness with key stakeholders, obtain their buy-in and ensure their commitment to support the changes and the performance improvement objectives of the initiative.

User Acceptance Testing (UAT) – The final and most important phase of system testing, UAT, is designed to ensure that the system does what it was designed to do and that it meets user expectations. UAT must go beyond prior functional and technical testing phases. UAT scenarios should cover all business processes end-to-end, include all critical real-life data variations and be validated by process owners.

Data Conversion – This critical aspect is often overlooked by the business, but it is one of the most critical implementation processes, and a common source of project delays. No two systems are alike, and data from one system will rarely map cleanly or directly onto a new system. Data quality issues in legacy systems can also cause delays. Realistic data is critical to UAT. The business, supported by IT, typically owns data conversion design, mapping, enrichment, validation and cleansing. Start the data conversion process early.

Data Governance – To ensure that master data and transactional data are employed appropriately and consistently throughout the organization from go-live forward, the business should develop a comprehensive data governance program that includes a framework of organizational roles, a “data dictionary,” defined metrics and documented policies.

Business Intelligence (BI) and Reporting – BI and reporting should not be left as an afterthought, with the presumption that they can be addressed after go-live.  For most users, the primary benefit of an enterprise system is ease and accuracy of reporting. Ensure that the BI and reporting requirements are fully incorporated into the design phase of the implementation and tracked throughout. The ease and flexibility of reporting is highly dependent on the quality of the architecture and design. The efficiency and integrity of the business process is dependent on the availability of information at the right time and place.

Enterprise systems can bring remarkable efficiencies and return on investment, or be massive failures – and the business, not the integrator or IT, is ultimately responsible for the outcome. For a more in-depth analysis of these and other implementation challenges, download our recently published white paper, Understanding the Responsibilities of the Business During an ERP System Implementation.

Cyber Vulnerabilities of Energy Companies’ Control Systems Can Be Addressed Safely and Successfully

 

By Tyler Chase, Managing Director
Energy and Utilities Industry Leader

and

Michael Porier, Managing Director
Technology Consulting – Security and Privacy

 

The realization is growing across the oil and gas industry that the major cybersecurity threats to upstream, midstream and downstream data and operations are often aimed at operational technology (OT) systems and equipment – usually older, legacy models – rather than at the information technology (IT) side. Those operational technologies typically include industrial control systems (ICS), supervisory control and data acquisition (SCADA) devices and other related technologies implemented at operational facilities, such as plants, pipelines, terminals and rigs.

A recent survey of more than 300 oil and gas companies found:

  • More than 60 percent of companies have suffered a security compromise in the past year, which exposed confidential information and disrupted OT systems and operations
  • Two-thirds of companies believe risks to OT systems have increased substantially in recent years, and 59 percent believe they face greater risks in OT than in IT
  • Only one-third of companies report that OT and IT are fully aligned in their organizations
  • Just 35 percent rate their readiness to address cyber threats as high
  • Close to half of all attacks on OT are going undetected

These survey findings appear shocking – but they are also consistent with Protiviti’s experience in performing cybersecurity assessments for energy and utility clients, particularly evaluating their OT systems. We often find unprotected field terminals with inadequate physical security of connection points, live ports that lack deterrents, and an absence of intrusion detection capabilities. We also commonly see flat networks that are not segmented to appropriately segregate the OT systems from the corporate network environment, making it easier for potential hackers to exploit vulnerabilities across the organization.

Obviously, OT systems with any of these shortcomings present significant cybersecurity risks for the energy and utilities industry. The threat is multiplied by the fact that energy and utilities organizations are deemed critical infrastructure, whose exploitation can have devastating effects to broad geographic regions affecting multitudes of people.

More and more ICS/SCADA technologies allow for the capability to connect (via IP) to the broader corporate network infrastructure. While this provides for certain efficiencies, it can also expose oil and gas systems to unprecedented risks that occur when the previously isolated OT systems are linked to sophisticated IT networks so data can be shared, managed and analyzed.

Despite this newfound connectivity, the industry has remained stubbornly reluctant to challenge legacy OT systems from a vulnerability perspective, for fear of creating interruptions or process errors. This reluctance often leads to a failure to adequately test or update systems to optimize security and minimize cybersecurity risks.

The concerns are legitimate, but only up to a point. In our experience, there isn’t sufficient justification to hold OT systems “off limits” for cybersecurity evaluation and upgrades, given the high potential for targeting by sophisticated opponents and the alarming numbers cited in the survey. To this end, assessments should still be performed, but they must incorporate a series of precautions designed to assure both operational continuity and a complete threat risk review. These precautions include:

  • Well-defined rules of engagement, including identification of the types of reports and system information to be compiled prior to conducting a vulnerability scan
  • Performing security evaluations in a test, rather than production, environment
  • Collaboration with both engineering and IT security personnel to define the scope of the review engagement
  • Reasonable limitations on initial tests so sensitive systems can be excluded if needed to allow for the development of workarounds
  • Establishment of clear lines of communications so any network or system irregularities are reported and evaluated during testing

Working within these parameters, the end goal of testing the security control environment of the ICS/SCADA environments should achieve the following:

  • Evaluate the key security risks prevalent in the ICS/SCADA network architecture
  • Identify the network vulnerabilities and test the connectivity to the enterprise network
  • Assist with the development of a vulnerability management program specific to the ICS/SCADA infrastructure

Ideally, what energy and utilities companies want is to ensure they have an ICS/SCADA environment that can function in a secure and effective manner, and that they can be highly efficient in detecting and responding to breaches and attacks. This requires technical expertise, collaboration between departments, appropriate planning, and leveraging vulnerability assessments to periodically test security.  Testing these systems requires more work, but it is not impossible, and it should not be considered “out of the question.” In fact, testing is an essential practice to preserving the integrity of any critical system.

DOJ Fraud Section Puts Boards of Directors on Notice Regarding “Conduct at the Top”

In February 2017, the U.S. Department of Justice (DOJ) Fraud Section published its latest guidance on corporate compliance programs with the release of the very useful document titled “Evaluation of Corporate Compliance Programs.”

While many legal and compliance scholars have rightly stated that this latest publication isn’t anything radically different than prior authoritative guidance issued by the DOJ and other organizations, what jumps out is the reframing of the well-worn expression, “tone at the top,” with the potentially more insightful, and arguably much scarier, “conduct at the top.” In a just-released Flash Report, we put forth questions and insights that illustrate the degree to which the DOJ is examining senior management and the board of directors while evaluating a corporate compliance program.