government and sox compliance for erp systems

38
1

Upload: dan-aldridge-twitter-danaldridge1

Post on 15-Jul-2015

934 views

Category:

Technology


2 download

TRANSCRIPT

Page 1: Government and SOX Compliance for ERP Systems

1

Page 2: Government and SOX Compliance for ERP Systems

•Dan Aldridge CEO Performa Apps

•e-mail [email protected]

•website www.inforln.com/wp

•linkedin Dan Aldridge

•twitter @Danaldridge1

Contact Information

Page 3: Government and SOX Compliance for ERP Systems

Agenda

Introduction DynaFlow

Governance Risk & Compliance / Enterprise Risk

Management

Segregation of Duties for Baan / LN

Impact on ERP implementation

Contact details:Aart de Glint

[email protected]

Phone +31 318 479712

Mobile +31 654 392046

3

Page 4: Government and SOX Compliance for ERP Systems

DynaFlow Profile

Main Facts:

Established in 1997

Private company HQ in Canada

Partners in USA, France, Netherlands, Norway, India, Thailand and Australia

Main mission:

To enable global companies to become “Simply in Control” by proactively

managing enterprise risks, demonstrating compliance and automating and

optimizing business processes.

Dedicated to provide its clients a fast ROI through a short and structured

implementation

Professional Services:

Implementation and Training

Compliance & Audit Support

Process Optimization

Solution Hosting Services

4

Page 5: Government and SOX Compliance for ERP Systems

DynaFlow: Makes it EZ for...

Page 6: Government and SOX Compliance for ERP Systems

6

Page 7: Government and SOX Compliance for ERP Systems

Cooking the Books

7

http://www.cbsnews.com/video/watch/?id=859384n

Mr. Ebbers (WorldCom), Mr. Lay (Enron), Mr. Kozlowski (Tyco)

Page 8: Government and SOX Compliance for ERP Systems

8

Page 9: Government and SOX Compliance for ERP Systems

Regulation - The Hot Potato

9

SOX

C-SOX

J-SOX

‘Euro-SOX’

SAS-70

Code Tabaksblat

Code Lippens

8th EU Directive

Clinger Cohen

21 CFR Part 11

IFRS

Basel-II

Loi sur La Sécurité Financière (LSF)

BilMoG

Page 10: Government and SOX Compliance for ERP Systems

Governance, Risk Mngnt & Compliance

Governancedescribes the overall management approach through which senior executives direct and

control the entire organization, using a combination of management information and

hierarchical management control structures. Governance activities ensure that critical

management information reaching the executive team is sufficiently complete, accurate and

timely to enable appropriate management decision making, and provide the control

mechanisms to ensure that strategies, directions and instructions from management are

carried out systematically and effectively.

Risk managementis the set of processes through which management identifies, analyzes, and, where

necessary, responds appropriately to risks that might adversely affect realization of the

organization's business objectives. The response to risks typically depends on their perceived

gravity, and involves controlling, avoiding, accepting or transferring them to a third party.

Whereas organizations routinely manage a wide range of risks (e.g. technological risks,

commercial/financial risks, information security risks etc.), external legal and regulatory

compliance risks are arguably the key issue in GRC.

Compliancemeans conforming with stated requirements. At an organizational level, it is achieved through

management processes which identify the applicable requirements (defined for example in

laws, regulations, contracts, strategies and policies), assess the state of compliance, assess

the risks and potential costs of non-compliance against the projected expenses to achieve

compliance, and hence prioritize, fund and initiate any corrective actions deemed

necessary.

10

Page 11: Government and SOX Compliance for ERP Systems

GRC/ERM Support at all levels

Le

ve

ls o

f GR

C m

od

el

Continuous monitoring as part of normal business process

Strategical

Tactical

Operational

•Policy

•Enterprise Risk Management (Strategic)

•Integrated Compliance Frameworks

•Consolidated Dashboards (Control Statements)

•Procedures

•Process Risk Analysis (Tactical)

•Process & Internal Control Design & Maintenance

•Review (workflow)

•Monitoring Efficiency of Internal Controls

•Embedded testing & test evidence

•Document Management System

•KPI/”In Control” reports

•Policy

•Enterprise Risk Management (Strategic)

•Integrated Compliance Frameworks

•Consolidated Dashboards (Control Statements)

PurchasingWarehouse

ManagementManufacturing

Sales &

Distribution

•Review

•Test

Page 12: Government and SOX Compliance for ERP Systems

Compliance – Why is this important

Corporate & Executive Responsibility & Liability

Policy Interpretation

Implementation Cost

Overhead

Tightened Credit Lines

Premium Insurance Fees

Fear for Reputation Damage

Audit Cost

Regulation

Page 13: Government and SOX Compliance for ERP Systems

From Regulation to Compliance

SOX

HIPAA

BASEL II

Etc.

ERM

COSO-II

COBIT

...

Regulations Implementation

Framework

Policy & Procedure

Implementation

Business Controls:

- Information delivery

- Resource acces and use

- Risk mitigation

- ...

Demonstratiopn

of ComplianceDemonstratiopn

of ComplianceDemonstration

of Compliance

Evidence

Collection

Audit

People Processes Technology Facilities Data

establish document test

Business Risks

Page 14: Government and SOX Compliance for ERP Systems

SOX Section 404 – Internal Control

Assessment of internal control

“The most contentious aspect of SOX is Section 404,

which requires management and the external auditor to

report on the adequacy of the company's internal

control over financial reporting (ICFR). This is the

most costly aspect of the legislation for companies to

implement, as documenting and testing important

financial manual and automated controls requires

enormous effort.”

14

http://www.heritage.org/CDA/upload/SOX-CDA-edited-3.pdf

Page 15: Government and SOX Compliance for ERP Systems

SOX Internal Control Requirements

15

Documentation

Detailed Process description

Process flowchart (preferable)

Business Risk Assessments

Risk Control Matrix (RCM)

Testing

Annual walkthrough of each process.

Testing of key controls.

Periodic Reviews

Review of process steps and controls

Updating of all documentation

Annual External IC Audit

Essentially external validations that yes you did 1 through 3 above.

The auditor would use a predefined “checklists

Page 16: Government and SOX Compliance for ERP Systems

Risk / Control Matrix

16

All

no

n-P

O in

voic

es

rece

ive

d a

t m

onth

en

d a

re e

nte

red

into

th

e s

yste

m w

ith

in 3

da

ys o

f m

onth

-en

d to

en

sure

pro

per

incl

usi

on

into

Acc

ou

nts

Pay

able

.

For

pro

duct

ion

invo

ices

, in

voic

es

can

on

ly b

e e

nter

ed

into

th

e s

yste

m f

or

auto

mat

ic m

atch

ing

if a

val

id P

O a

nd

rece

ipt

are

alre

ady

in t

he

sys

tem

. Th

e sy

stem

po

pu

late

s

the

invo

ice

pri

ce a

nd

du

e d

ate

info

rma

tio

n f

rom

the

PO

info

rmat

ion

.

All

un

ma

tche

d P

O in

voic

es a

re fo

rwar

ded

to

pu

rcha

sin

g

for

follo

w-u

p.

All

pu

rch

ase

ord

ers

and

no

n-P

O in

voic

es

are

revi

ewe

d,

incl

ud

ing

led

ger

acco

un

t co

din

g, a

nd

are

aut

ho

rize

d in

acco

rda

nce

wit

h c

om

pany

po

licy.

Cyc

le c

ou

nts

th

at

resu

lt in

a d

iffe

ren

ce f

rom

pe

rpet

ual

qu

anti

ty o

uts

ide

lim

its

set

by

com

pany

po

licy

are

revi

ewed

; ite

ms

wit

h a

var

ance

de

emed

to

be

mat

eri

al

are

reco

un

ted

.

Risk

RISK / CONTROL MATRIX

Auditor Assertion ACP-C01 ACP-C04 ACP-C16 PUR-C11 INV-C18

R007What ensures that purchases are recorded into the proper

accounting period?Completeness PC

R011What ensures that invoice prices, quantities and other valuation

information is correct?

Completeness,

E/O, M/VPC PC

R042What ensures that duplicate and/or fictitious purchases are not

recorded?

Existence/

OccurrencePC PC

R075What ensures that perpetual inventory records reflect proper

quantities and amounts?

Existence/

OccurrencePC DC

R079What ensures that perpetual-to-physical inventory adjustments are

correctly calculated and recorded?

Completeness,

Measurement/

Valuation

DC

R093What ensures that inventory counts, compilations and descriptions

are accurate?

Measurement/

ValuationDC

PC = Preventive Control

DC = Detective Control

Risk

Page 17: Government and SOX Compliance for ERP Systems

Enterprise Risk Management (ERM/GRC)

The key pains & challenges: Extra burden “on top” of running the company

Draining resources from critical projects

Absence of clear and documented guidelines

Absence of automation

Cannot be postponed (scheduled audits)

Cost (with NO tangible ROI)

The proposed approach & resolution: Leverage pre-defined knowledge via libraries

Avoid multiple partial systems (and integration burden)

Automate as much as possible tedious and large volume

tasks

Page 18: Government and SOX Compliance for ERP Systems

How DynaFlow supports ERM/GRC

18

Business Risks & Business Controls Library

2,500+ pre-defined Controls, Risks and relationships

Certified Best Practices / Benchmark

For all regional & industry specific regulations

(SOX, Basel-II, L262, FDA, HIPAA, IFSR, ISO, etc…)

To address all auditing/auditors requirements

Automated Business Control Execution

Testing Schedules with automated notification & testing

Real-time monitoring & alerts for testers and Mgmt

Evidence Collection & audit trail

Dynamic Risk and Business Control Monitoring

Key Performance & Risks Indicators Dashboard (+ mobile)

Audit Support

Combination of Solution, Libraries and Services

Page 19: Government and SOX Compliance for ERP Systems

19

Page 20: Government and SOX Compliance for ERP Systems

Segregation of Duties (SoD)

The key pains & challenges: Now a Critical Business Control for ALL organizations

Involves large volume of data

(i.e. Typical = 200,000+ authorizations in Baan alone)

Need to be done across Systems (ERP) and for ALL

access types

Is a recurring process due to constant changes

The proposed approach & resolution: Automation,

automation

and automation!

Page 21: Government and SOX Compliance for ERP Systems

Cross-Applications ERM & SoD

Page 22: Government and SOX Compliance for ERP Systems

Process

DiagramEmployees

User

RolesApplications

Access Mgmt

Business

Controls

Business

Risks

Compliance Mgmt

Business Processes & Controls Integr.

SoD

Business

Conflicts

Conflict

Resolution

SoD

Conflict

Rules

SoD Mgmt

Documents

Document Mgmt

Documents

Page 23: Government and SOX Compliance for ERP Systems

EZ-Compliance SoD Scan

Mapics

Hyperion

BPCS

Network Access

Facility Access

Security Badges

Mapics

Ceridian

Page 24: Government and SOX Compliance for ERP Systems

Master SoD Matrix

24

Page 25: Government and SOX Compliance for ERP Systems

Over 400+ SoD “zones” to be validated

25

Page 26: Government and SOX Compliance for ERP Systems

The LN / Baan SoD Rules Library

26

Introduced in 2005

Required 2 years initial development, and is updated

regularly

Content and design validated by CFO, Controllers, SOX

Senior Consultants, Baan Specialists, etc...

Covers all Baan versions (Triton, Baan IV, ERP-5, LN)

Compliant to Baan Tools and DEM authorizations

Verify 22,000+ Baan session combinations for SoD violations

(with violation rating) to validate 400+ SoD sensitive “zones”

Auditors such as E&Y, KPMG, D&T, PWC, Grant Thornton

validated the Baan SoD Rules completeness and accuracy

by successful certifying all EZ-Compliance clients to be

SoD/SOX compliant.

Page 27: Government and SOX Compliance for ERP Systems

EZ-Compliance Automated SoD Scan

Employees

Roles

Corp-wide

Applications

Business

Controls

Business

Processes

Import

Visio

DEM

Employee /

Applications

Access

List

Access

Scan

(1)

SoD

Conflict

Rules

SOX – SoD

Conflicts

List

Conflict

Scan

(2)

Resolution

Scan(3)

SoD

Resolution

Rules

Mitigated

Conflicts

List

Business

Risks

SoD

Library

Oracle

Mitigation

Controls

Import

LDAP

Import

ERP

Page 28: Government and SOX Compliance for ERP Systems

SoD Conficting Areas Matrix

28

Click to view

detailed business

functions &

conflicts found

Page 29: Government and SOX Compliance for ERP Systems

The automated SoD cycle

Import of updated authorizations from

all Enterprise Applications

Identification of SoD conflicts & related business

risks

Resolution of conflicts with

known patterns

Notification of new conflicts to internal audit team and/or process owners

Investigation, resolution and mitigation of

SoD risks

ERP

Import

Weekly

or

Daily

Result: 90%+ reduction of effort & cost

Page 30: Government and SOX Compliance for ERP Systems

How DynaFlow supports SoD

30

Access/Authorization Mgmt

Cross-systems authorizations (who is accessing what?)

Periodic Access Reviews

SoD Conflicts Identification

Detective validation (what accesses constitute risks?)

Preventive validation (what is the impact if we change …?)

SoD Conflicts Resolution

Automated resolution/mitigation using pattern rules

SoD Conflicts Monitoring & Alerts

Self-generated SoD Matrix with dynamic alerts

Key Performance & Risks Indicators Dashboard (+ mobile)

Page 31: Government and SOX Compliance for ERP Systems

Segregation of Duties (SoD)

What you gain with DynaFlow: Cross-ERP Integration (SAP, Oracle, Baan, Mapics, ...)

Bottled Best Practices:

Fully automated Segregation-of-Duties (SoD) Rules

Pre-Defined SoD Libraries available for Baan, SAP, Oracle,

etc...

In line with external auditors to secure successful

certification

Detective and also Preventative

Fully automated SoD validation

90% reduction on implementation cost & effort

50% reduction on auditing cost

100% Successful SoD Audit

Simplified insight in all user authorizations

Page 32: Government and SOX Compliance for ERP Systems

32

Page 33: Government and SOX Compliance for ERP Systems

Integrated Cycles

33

Document

Integrate Structure

Publish

Optimize

Validate

Define

Capture

Process

Knowledge

Review Certify

Risk Assessment

Control Environment

Control Activity

Publish

Regulations

(eg. SOX, ISO, ITAR

AS9100, HIPAA, ect)

Automate

Measure

Optimize

Route Definition

Workflow

AutomationExecuteMonitorAction

Objectives

Measure

Analyzes

Metrics

Page 34: Government and SOX Compliance for ERP Systems

DynaFlow Value Proposition

34

Document

Integrate Structure

Publish

Optimize

Validate

Define

Capture

Review Certify

Risk Assessment

Control Environment

Control Activity

Publish

Automate

Measure

Optimize

Route Definition

ExecuteMonitorAction

Objectives

Measure

Analyzes

Page 35: Government and SOX Compliance for ERP Systems

Financial (Oracle, etc)

ERP (SAP, Baan, Mapics, etc)

Process

Modeling

Process &

Knowledge

Publishing

Business

Controls

Definition

Business

Controls

Checks

Process

Automation

Automated

Alerts &

Notifications

Employee

Process

Dashboard

Modeler and

Auditor

Dashboard

Transaction

Systems

Base

Dynamic KCI

& Issues

Escalation

Process

Optimization

& Monitoring

Management

Dashboard

Dynamic KPI

&

BI Analytics

BP

MR

ep

ort

ing

Office Apps (MS, Email, VPN, etc)

DynaFlow Solution Overview

Page 36: Government and SOX Compliance for ERP Systems

Critical Capabilities Definition ERM & C

36

Audit ManagementSupports internal auditors in planning and scheduling audit-related tasks, time management, managing work papers,

risk assessments, control testing, remediation management and reporting.

Risk Management, General Supports risk management professionals with the documentation, workflow, assessment and analysis, reporting,

visualization, and remediation of risks. Analytics are mostly qualitative with a limited loss event analysis capability that

is not dependent on stochastic analysis. It does not include stochastic analysis, but it may collect data from stochastic

risk analytics tools to provide a consolidated view of enterprise risk management.

Risk Management, Stochastic Involves stochastic analysis, such as Monte Carlo simulation. Examples include banks that require highly specialized

capabilities for Basel II capital calculations and companies that must support project risk assessments of long-term

asset investments, such as mining and oil and gas. Only a few EGRC platform vendors directly support these

stochastic analysis needs organically or through an OEM partnership.

Compliance ManagementSupports compliance professionals with the documentation, workflow, reporting and visualization of control objectives,

controls and associated risks, surveys and self-assessments, testing, and remediation. At a minimum, EGRC

management not only will include financial reporting compliance (Sarbanes-Oxley compliance), but also can support

other types of compliance, such as ISO 9000, Payment Card Industry, industry-specific regulations, service-level

agreements, trading partner requirements and compliance with internal policies.

Policy Management Includes a specialized form of document management that enables the policy life cycle from creation to review, change

and archiving of policies; mapping of policies to mandates and business objectives in one direction, and risks and

controls in another; and distribution to and attestation by employees and business partners.

GRC ContentIncludes many different kinds of content relative to GRC activities. Examples include regulatory analysis and news

feeds, standards and frameworks, draft testing and risk assessments, and draft policies.

Business Analytics Supports the ability to analyze the impact of risks on business objectives, performance and processes.

Gartner, Inc: 30 November 2010/ID Number: G00208665

Page 37: Government and SOX Compliance for ERP Systems

DynaFlow simplification

SOX

HIPAA

BASEL II

Etc.

COSO-II

COBIT

......

Regulations Implementation

Framework

Policy & Procedure

Implementation

Business Controls:

- Information delivery

- Resource acces and use

- Risk mitigation

- ...

Demonstratiopn

of ComplianceDemonstratiopn

of ComplianceDemonstration

of Compliance

Evidence

Collection

Audit

People Processes Technology Facilities Data

establish document test

Business Risks

Business

Control

Libraries

Business Risk Libraries

Compliance

Program Mgmt.

Compliance

Change Mgmt.

Compliance

Issue Mgmt.

Compliance

Access &SoD Mgmt.

Audit

Trail

Document

Mgmt.

Web Portal

Cross-ERP

Integration

&

MappingOperational Risk

Monitoring

eBook

Generation

Page 38: Government and SOX Compliance for ERP Systems

38