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Continuous Auditing &
 Control Optimisation

                                         Amit Gupta
                                         Partner, 3U
                                         FCA, GCWA, ISA (ICAI), CISSP, CEH
                                         Email:gupta_amitu@gmail.com
                                         M-+91-9313099056


Continuous Auditing and Controls Optimisation    1
Traditional Audit Model Is Becoming
Outdated
• Does it meet the needs of those who
  pay for it, rely upon it or provide it?

• Historical audits have not proven to be
  effective deterrents to financial fraud

• Sampling misses anomalies

• Need more timely audit results

• The cost of an audit may become
  prohibitive

• Public skepticism about corporate
  integrity has increased
Continuous Auditing and Controls Optimisation   2
Staying In Compliance
“What Most Companies Will Follow?”


  • Automate/optimize controls
  • Automate audit process through Continuous
    Auditing
  • Implement & maintain a process or structure to identify
    significant changes to your business & significant changes to
    your controls
  • Keep your process & control documentation current
  • Pass the test with your external auditors




 Continuous Auditing and Controls Optimisation   3
Expected Outcomes of Continuous
  Auditing & Optimization

 •     Clearly articulated tone at the top and stronger control
       environment
 •     Risk-based, top-down approach to determine “in scope”
       accounts
 •     Identification of key controls that will prevent or detect material
       errors
 •     Controls that are operationally efficient, cost effective, and
       integrated into daily operations
 •     Streamlined and clearly documented processes
 •     Streamlined testing, remediation, and monitoring approaches



     Stronger Internal Controls over Financial Reporting


       Decreasing levels of effort to sustain compliance



Continuous Auditing and Controls Optimisation   4
The Future with Continuous Auditing &
  Optimization
    Top-Down                                                                          Automate
Risk-Based Review                        Current                     Continuous       /Optimize         Future
                                          Effort        Reduce        Auditing         control          Effort

Significant
Accounts &                                 10%                                                          5%
Related Processes

Key Controls                               15%                                                         10%

Process Controls                           10%                                                        10%

Documentation                              40%                                                        20%

Testing                                    35%                                                        20%

                                        100%                                                            65%
                                                                                       Efficiency* 35%
    *For illustrative purposes only.               Actual efficiencies gained will vary based on individual
                                                organization circumstances.


Continuous Auditing and Controls Optimisation              5
Benefits of Continuous Auditing

• Process Owners react to problems/opportunities that are
  quantified
• Identification of business process improvement
  opportunities
• Improved likelihood of detecting material errors
• Timely identification of issues allows rapid resolution
• Better, more current information for decision making
• Easier compliance with regulations
• More comprehensive audit coverage
• Better quality data and processes
• Greater deterrence of fraud and other undesirable
  behaviors
 Continuous Auditing and Controls Optimisation   6
Key Continuous Auditing (CA) Milestones

Now   •   Management Committee endorsement
      •   Application of analytics to data
      •   Designation of CA partner
      •   Initial client value proposition statement
1M    •   Identification of pilot unit/area
      •   Audit policy development
2M    •   Development of client data acquisition system
      •   Development of advanced analytic engine
4M    •   Client trials of new technologies and audit methods
      •   Audit operational plans
8M    •   Roll out


      Easy                 Challenging                Really Hard
      Continuous Auditing and Controls Optimisation     7
Business Deliverables

• Short Term Offerings – Available now
       – Data quality assessment
       – Audit planning system
       – Expanded use of analytic techniques
         in ongoing audits


• Medium Term
       –    Deliver higher quality audit with reduced effort
       –    Reduce audit risk
       –    Delivering more value to business
       –    Change business model of audit


Continuous Auditing and Controls Optimisation   8
CONTINUOUS AUDITING
 FOR SEGREGATION OF
 DUTIES



Continuous Auditing and Controls Optimisation   9
Benefits of Improved Process


• Automated reports with audit trails identifying
  exceptions to controls and mitigation uses
• Reduced cost of monitoring controls
• Reduction of over 3,000 violations within a 60 day
  period
• Closed out 2 audit findings related to excessive access
  and monitoring
• Provided a common data set for Finance, IT Security,
  Business Controls, and SAP team to drive improvement




 Continuous Auditing and Controls Optimisation   10
Reduced SOD Violations by Two Thirds
        in Less than two Months

                    High Priority Segregation of Duties Violations
                                  Sept 27 to Nov 30
                        3,600

      3,500
      3,000
      2,500
      2,000
      1,500
      1,000                                                        427

          500
                0
                      Sept 27 Oct 10            Oct 31   Nov 15   30-Nov

Continuous Auditing and Controls Optimisation   11
Identifying opportunity for Automation


  • Implement automated workflow for role approval, on-
    boarding process and SOD waiver process:
           – Reduce high-cost co-sourcing support .
           – Reduce manual process such as Excel spreadsheet and .PST
             administration (for audit).




Continuous Auditing and Controls Optimisation   12
CONTINUOUS AUDITING
FOR FRAUD DETECTION




Continuous Auditing and Controls Optimisation   13
Identify Fraud using Continuous Auditing

       –    Fraud Analysis – A simple analysis of data such as payroll, employee, vendor,
            accounts payable, and accounts receivable can help determine if fraud is
            occurring.
       –    Payroll Fraud
               • Duplicates (i.e. payees on same date, same or similar names, SSNs, direct
                 deposit account numbers)
               • Paychecks being created for employees that have no time and attendance,
                 invalid SSN, no expenses, no vacation, little or scare personnel records,
                 etc
               • Wages inconsistent with job classification
               • Pay date precedes employment date
               • Terminated employees continuing to be paid


       –    Purchasing Fraud
               • Duplicate disbursement amounts
               • Duplicate invoice numbers/dates
               • Duplicate disbursements on same date
               • Disbursement to vendor not in vendor database
               • Vendor name/address/phone # same as employee name/address/phone #
               • Invoice’s “pay to” address different from address in vendor or contract
                 database
Continuous Auditing and Controls Optimisation   14
Fraud

           – Use Benford’s Law to identify anomalous transactions in:
              • Accounts payable and expenses
              • Accounts receivable and sales
              • Refunds
              • Payroll
              • Estimations in the general ledger

           – Invented, contrived, or manipulated numbers do not follow
             Benford’s Law

           – Doesn’t apply to all data sets
              • i.e. sets of data with numbers that have imposed
                ceilings or floors such as IRA contributions or hourly
                wage rates

           – Human analysis of anomalies is needed



Continuous Auditing and Controls Optimisation   15

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Continuous Auditng And Process Optimisation

  • 1. Continuous Auditing & Control Optimisation Amit Gupta Partner, 3U FCA, GCWA, ISA (ICAI), CISSP, CEH Email:gupta_amitu@gmail.com M-+91-9313099056 Continuous Auditing and Controls Optimisation 1
  • 2. Traditional Audit Model Is Becoming Outdated • Does it meet the needs of those who pay for it, rely upon it or provide it? • Historical audits have not proven to be effective deterrents to financial fraud • Sampling misses anomalies • Need more timely audit results • The cost of an audit may become prohibitive • Public skepticism about corporate integrity has increased Continuous Auditing and Controls Optimisation 2
  • 3. Staying In Compliance “What Most Companies Will Follow?” • Automate/optimize controls • Automate audit process through Continuous Auditing • Implement & maintain a process or structure to identify significant changes to your business & significant changes to your controls • Keep your process & control documentation current • Pass the test with your external auditors Continuous Auditing and Controls Optimisation 3
  • 4. Expected Outcomes of Continuous Auditing & Optimization • Clearly articulated tone at the top and stronger control environment • Risk-based, top-down approach to determine “in scope” accounts • Identification of key controls that will prevent or detect material errors • Controls that are operationally efficient, cost effective, and integrated into daily operations • Streamlined and clearly documented processes • Streamlined testing, remediation, and monitoring approaches Stronger Internal Controls over Financial Reporting Decreasing levels of effort to sustain compliance Continuous Auditing and Controls Optimisation 4
  • 5. The Future with Continuous Auditing & Optimization Top-Down Automate Risk-Based Review Current Continuous /Optimize Future Effort Reduce Auditing control Effort Significant Accounts & 10%   5% Related Processes Key Controls 15%   10% Process Controls 10%    10% Documentation 40%    20% Testing 35%    20% 100% 65% Efficiency* 35% *For illustrative purposes only. Actual efficiencies gained will vary based on individual organization circumstances. Continuous Auditing and Controls Optimisation 5
  • 6. Benefits of Continuous Auditing • Process Owners react to problems/opportunities that are quantified • Identification of business process improvement opportunities • Improved likelihood of detecting material errors • Timely identification of issues allows rapid resolution • Better, more current information for decision making • Easier compliance with regulations • More comprehensive audit coverage • Better quality data and processes • Greater deterrence of fraud and other undesirable behaviors Continuous Auditing and Controls Optimisation 6
  • 7. Key Continuous Auditing (CA) Milestones Now • Management Committee endorsement • Application of analytics to data • Designation of CA partner • Initial client value proposition statement 1M • Identification of pilot unit/area • Audit policy development 2M • Development of client data acquisition system • Development of advanced analytic engine 4M • Client trials of new technologies and audit methods • Audit operational plans 8M • Roll out Easy Challenging Really Hard Continuous Auditing and Controls Optimisation 7
  • 8. Business Deliverables • Short Term Offerings – Available now – Data quality assessment – Audit planning system – Expanded use of analytic techniques in ongoing audits • Medium Term – Deliver higher quality audit with reduced effort – Reduce audit risk – Delivering more value to business – Change business model of audit Continuous Auditing and Controls Optimisation 8
  • 9. CONTINUOUS AUDITING FOR SEGREGATION OF DUTIES Continuous Auditing and Controls Optimisation 9
  • 10. Benefits of Improved Process • Automated reports with audit trails identifying exceptions to controls and mitigation uses • Reduced cost of monitoring controls • Reduction of over 3,000 violations within a 60 day period • Closed out 2 audit findings related to excessive access and monitoring • Provided a common data set for Finance, IT Security, Business Controls, and SAP team to drive improvement Continuous Auditing and Controls Optimisation 10
  • 11. Reduced SOD Violations by Two Thirds in Less than two Months High Priority Segregation of Duties Violations Sept 27 to Nov 30 3,600 3,500 3,000 2,500 2,000 1,500 1,000 427 500 0 Sept 27 Oct 10 Oct 31 Nov 15 30-Nov Continuous Auditing and Controls Optimisation 11
  • 12. Identifying opportunity for Automation • Implement automated workflow for role approval, on- boarding process and SOD waiver process: – Reduce high-cost co-sourcing support . – Reduce manual process such as Excel spreadsheet and .PST administration (for audit). Continuous Auditing and Controls Optimisation 12
  • 13. CONTINUOUS AUDITING FOR FRAUD DETECTION Continuous Auditing and Controls Optimisation 13
  • 14. Identify Fraud using Continuous Auditing – Fraud Analysis – A simple analysis of data such as payroll, employee, vendor, accounts payable, and accounts receivable can help determine if fraud is occurring. – Payroll Fraud • Duplicates (i.e. payees on same date, same or similar names, SSNs, direct deposit account numbers) • Paychecks being created for employees that have no time and attendance, invalid SSN, no expenses, no vacation, little or scare personnel records, etc • Wages inconsistent with job classification • Pay date precedes employment date • Terminated employees continuing to be paid – Purchasing Fraud • Duplicate disbursement amounts • Duplicate invoice numbers/dates • Duplicate disbursements on same date • Disbursement to vendor not in vendor database • Vendor name/address/phone # same as employee name/address/phone # • Invoice’s “pay to” address different from address in vendor or contract database Continuous Auditing and Controls Optimisation 14
  • 15. Fraud – Use Benford’s Law to identify anomalous transactions in: • Accounts payable and expenses • Accounts receivable and sales • Refunds • Payroll • Estimations in the general ledger – Invented, contrived, or manipulated numbers do not follow Benford’s Law – Doesn’t apply to all data sets • i.e. sets of data with numbers that have imposed ceilings or floors such as IRA contributions or hourly wage rates – Human analysis of anomalies is needed Continuous Auditing and Controls Optimisation 15