CC3.3 Considering fraud risk (COSO principle 8)
The possibility of fraud is taken into account when risks to objectives are assessed. Points of focus: the assessment covers fraudulent reporting, loss of assets and corruption; incentives and pressures are weighed; opportunities for unauthorised acquisition, use or disposal of assets or for altering records are examined; the ways people might rationalise wrongdoing are considered; and IT-specific threats and weaknesses that come with using technology and reaching information are included.
Source: SOC 2 (2017 Trust Services Criteria), CC3.3. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open SOC 2 (2017 Trust Services Criteria) in the compliance library.
These are criteria, not controls: you design controls that meet them, and which criteria are in scope follows the categories your report covers (Security always; Availability, Confidentiality, Processing Integrity and Privacy only if chosen). A Type 2 report tests that the controls operated across the period, so the evidence asked for is samples across that period, not one copy.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Fraud risk assessment or fraud section of the enterprise risk assessment · Policy repository / GRC workspace
- Analysis of privileged access and data misuse scenarios · Identity provider / directory
governing documentDocuments that govern the control
- Anti-fraud policy and reporting channel · Policy repository / GRC workspace
- Actions taken to address identified fraud risks · Document repository
First move
Common gaps auditors find
- Risk assessment has no fraud component
- Insider misuse of IT access not considered
- Fraud risks identified but no mitigating control assigned
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 Identifying and analysing risks to objectives (COSO principle 7) · CC3.4 Identifying and assessing significant changes (COSO principle 9)