No Result
View All Result
SUBSCRIBE | NO FEES, NO PAYWALLS
MANAGE MY SUBSCRIPTION
NEWSLETTER
Corporate Compliance Insights
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe
No Result
View All Result
Corporate Compliance Insights
Home Featured

Don’t Lose Control During COVID-19

Supporting Your Control Environment in the Evolving Pandemic

by Chris Jeffrey
June 17, 2020
in Featured, Risk
illustration of figure walking highwire between two pillars

Baker Tilly’s Chris Jeffrey offers tips and practical advice for organizations on supporting the control environment and keeping operations running during the current crisis.

As the evolving COVID-19 pandemic brings uncertainties, organizations face immediate risks impacting their control environment or compliance with Sarbanes-Oxley (SOX) requirements. Here, I offer practical advice on informing and supporting your control environment while keeping your operations running. Management should consider the following internal control questions:

  • Have there been changes to the way controls operate as a result of COVID-19?
  • Has the level of risk changed due to COVID-19?
  • Has the frequency of the controls changed due to COVID-19?
  • Has the control owner or person responsible changed due to COVID-19?
  • Has decision-making changed as it relates to operations and organizational objectives?
  • Do policies and procedures need to be reviewed and revised to reflect any changes?
  • Are there contingency plans in place should someone become unavailable to execute controls?

In the context of the Committee of Sponsoring Organizations of the Treadway Commission’s (COSO) “Internal Control – Integrated Framework,” these risks may be heightened during COVID-19. Practical next steps are based on suggested best practices to help mitigate those risks.

Control Environment

Risks:

  • Remote-working arrangements may result in significant changes to the way internal controls are executed
  • Remote-working arrangements may result in reduced oversight and communication across the organization
  • Lack of continued education and training sessions may lead to miscommunication on how to consistently execute internal controls or apply organizational policies
  • Contingency plans are not in place for key personnel who execute internal controls
  • Noncompliance with organizational policies or applicable accounting standards, laws and regulations

Practical Next Steps:

  • Engage with team members via videoconferencing and calls to discuss changes in business operations and potential changes to all risk areas.
  • Consider using electronic/digital signatures to evidence reviews and approvals.
  • Deploy trainings to ensure all employees are informed on how to handle working in a remote environment.

Risk Assessment

Risks:

  • Increased pressures to meet organizational goals and targets (heightens the risk of fraud)
  • Failure to promptly assess and subsequently address the impact of changes caused by external environment factors
  • Failure to involve appropriate levels of leadership and stakeholders in the decision-making process could lead to inappropriate or rushed changes in processes and controls
  • Inconsistent oversight and communication increases the risk of management override of internal controls

Practical Next Steps:

Review previously performed risk assessments (e.g., enterprise risk assessments, fraud risk assessments, IT risk assessments, etc.), reassess risk rankings and modify mitigation plans.

Control Activities

Risks:

  • Confidential data (electronic or hard copy) is not adequately protected
  • New controls may not be implemented or current controls are not revised to account for remote workforces (e.g., increased access to systems or applications, etc.)
  • Increased user access or changes in employee job responsibilities may result in segregation-of-duties conflicts
  • Failure to promptly set policies and procedures or implement necessary corrective actions may lead to outdated or missing controls

Practical Next Steps:

  • Continue to maintain segregation of duties and other preventive controls when performing key activities.
  • Strengthen detective or monitoring controls.
  • Explore system capabilities and the ability to automate controls (ERP workflows, electronic signatures, etc.).

Information and Communication

Risks:

  • Significant changes may require disclosure in quarterly or annual financial statements; disclosures may not be accurately reflected or excluded from financial statements due to COVID-19 (risk factors, MD&A, asset impairments, valuation, loss contingencies, going concern, subsequent events)
  • Information may be delayed or unavailable due to operations in impacted countries or remote-working arrangements (delayed processes may impact the ability to execute controls or the accuracy of financial records)
  • Financial close or external reporting may be delayed or unable to be completed

Practical Next Steps:

Establish a communication platform and process to keep teams and the organization informed on a timely basis (e.g., daily updates, weekly departmental meetings, etc.).

Monitoring Activities

Risks:

  • Lack of business continuity or disaster recovery plans could lead to major disruptions in processes and controls
  • Heightened use of personal or public unsecured Wi-Fi networks increases the dependency of cybersecurity controls including: access security, system change control and data center/network operations
  • Increased use of mobile devices or organizational assets outside of the office heighten the need for monitoring IT general controls
  • Remote-working arrangements and changes to the overall environment may require changes to the frequency of control performance

Practical Next Steps:

Reflect on current processes, potential opportunities and lessons learned during these unprecedented times and continue to use them moving forward (updating business continuity and disaster recovery plans, communication protocols, more efficient and streamlined processes/controls, etc.)


Tags: COVID-19Internal ControlsMonitoringRisk Assessment
Previous Post

The Forgotten Fraud Risk on the Rise During COVID-19

Next Post

Ethics Suite Announces Strategic FCPA Investigatory Partnership with Polaris Corporate Risk Management

Chris Jeffrey

Chris Jeffrey

Chris Jeffrey leads Baker Tilly‘s central region risk advisory practice. He is part of a practice with more than 300 professionals who provide industry-specialized services to organizations within the manufacturing, higher education, real estate, technology, government contracting and financial services industries. Practice areas include cybersecurity, internal audit, risk assessment, financial and operational risk management, Sarbanes-Oxley compliance, technology risk consulting and organizational governance. Chris has nearly 20 years of experience and specializes in large, complex and global organizations. He has also published several articles and has spoken numerous times on the topics of internal audit, internal controls and compliance.

Related Posts

uvalde crosses

Will 2023 Bring More ‘Permacrisis’ Culture?

by Lisa Schor Babin
January 4, 2023

While 2022 had no shortage of chaotic events, ethics columnist Lisa Schor Babin shares her hopes for 2023 — and...

joining forces

Why ESG Programs Should Make Internal Audit an Ally

by Kapish Vanvaria
November 30, 2022

Recent research shows internal audit functions are rarely involved in setting strategy for ESG or even in reviewing how goals...

red flag warnings

Fostering Risk Transparency in the Organization

by Jim DeLoach
November 9, 2022

Serious risks to your company’s financial and reputational health probably aren’t going to walk up and introduce themselves. Protiviti’s Jim...

NAVEX regional whistleblowing hotline benchmark report_f

Navex 2022 Regional Whistleblowing Hotline Benchmark Report

by Corporate Compliance Insights
November 9, 2022

Explore benchmark data and regional comparisons for Europe, APAC, North America and South America. Regional Benchmark Report 2022 Regional Whistleblowing...

Next Post
man studying report with magnifying glass

Ethics Suite Announces Strategic FCPA Investigatory Partnership with Polaris Corporate Risk Management

Compliance Job Interview Q&A

Jump to a Topic

AML Anti-Bribery Anti-Corruption Artificial Intelligence (AI) Automation Banking Board of Directors Board Risk Oversight Business Continuity Planning California Consumer Privacy Act (CCPA) Code of Conduct Communications Management Corporate Culture COVID-19 Cryptocurrency Culture of Ethics Cybercrime Cyber Risk Data Analytics Data Breach Data Governance DOJ Download Due Diligence Enterprise Risk Management (ERM) ESG FCPA Enforcement Actions Financial Crime Financial Crimes Enforcement Network (FinCEN) GDPR HIPAA Know Your Customer (KYC) Machine Learning Monitoring RegTech Reputation Risk Risk Assessment SEC Social Media Risk Supply Chain Technology Third Party Risk Management Tone at the Top Training Whistleblowing
No Result
View All Result

Privacy Policy

Founded in 2010, CCI is the web’s premier global independent news source for compliance, ethics, risk and information security. 

Got a news tip? Get in touch. Want a weekly round-up in your inbox? Sign up for free. No subscription fees, no paywalls. 

Follow Us

Browse Topics:

  • CCI Press
  • Compliance
  • Compliance Podcasts
  • Cybersecurity
  • Data Privacy
  • eBooks Published by CCI
  • Ethics
  • FCPA
  • Featured
  • Financial Services
  • Fraud
  • Governance
  • GRC Vendor News
  • HR Compliance
  • Internal Audit
  • Leadership and Career
  • On Demand Webinars
  • Opinion
  • Resource Library
  • Risk
  • Uncategorized
  • Videos
  • Webinars
  • Well-Being
  • Whitepapers

© 2022 Corporate Compliance Insights

No Result
View All Result
  • Home
  • About
    • About CCI
    • Writing for CCI
    • NEW: CCI Press – Book Publishing
    • Advertise With Us
  • Explore Topics
    • See All Articles
    • Compliance
    • Ethics
    • Risk
    • FCPA
    • Governance
    • Fraud
    • Internal Audit
    • HR Compliance
    • Cybersecurity
    • Data Privacy
    • Financial Services
    • Well-Being at Work
    • Leadership and Career
    • Opinion
  • Vendor News
  • Career Connection
  • Events
    • Calendar
    • Submit an Event
  • Library
    • Whitepapers & Reports
    • eBooks
    • CCI Press & Compliance Bookshelf
  • Podcasts
  • Videos
  • Subscribe

© 2022 Corporate Compliance Insights

Welcome to CCI. This site uses cookies. Please click OK to accept. Privacy Policy
Cookie settingsACCEPT
Manage consent

Privacy Overview

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.
Necessary
Always Enabled
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
CookieDurationDescription
cookielawinfo-checbox-analytics11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional11 monthsThe cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-necessary11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance11 monthsThis cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy11 monthsThe cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.
Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
SAVE & ACCEPT