CC3.3 COSO principle 8: Considers potential for fraud
Considers the potential for fraud in assessing risks to the achievement of objectives.
5
artefacts
0
held by a system
4
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- A fraud risk assessment considering fraudulent reporting, misappropriation of assets, corruption and management override of controls · Policy repository / GRC workspace
- Evidence the assessment considers fraud involving technology, such as unauthorised access, data theft and misuse of privileged access · Identity provider / directory
- Controls identified to address the fraud risks and evidence of their operation · Policy repository / GRC workspace
- Evidence of who performed the assessment and of its review by management or the board · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Analysis of incentives, pressures, opportunities and rationalisations relevant to the entity · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Fraud risk omitted entirely from the risk assessment, which is one of the most common exceptions against this criterion
- Fraud considered as financial only, with no consideration of insider misuse of system access
- Management override acknowledged as a risk with no control addressing it
- Assessment performed once at implementation and never repeated as the business changed
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetCC3.2 COSO principle 7: Identifies risks and analyzes to determine how managed · CC3.4 COSO principle 9: Identifies and assesses changes that could impact internal controls