C. Internal controls Flashcards
what is the definition of internal controls?
whole system of controls, financial and otherwise, established by the management in order to carry out the business of the enterprise in an orderly and efficient manner, ensure adherence to management policies, safeguard the assets, prevent and detect fraud and error, and secure as far as possible the completeness and accuracy of the records
a system for management to control certain risks and therefore help businesses achieve their objectives
who is responsible for internal control?
the board of directors
employees have some responsibility
what are the elements of a sound system of internal control according to the Turnbull Report?
an internal control system encompasses the policies, processes, tasks, behaviours and other aspects of a company that, taken together:
- facilitate its effective and efficient operation by enabling it to respond appropriately to significant risks
- help ensure the quality of internal and external reporting
- help ensure compliance with applicable laws and regulations
the system of internal control will include:
- control activities
- information and communications processes
- processes for monitoring the continuing effectiveness of the system
the system of internal control should:
- be embedded within operations
- be able to respond to changing risks
- include procedures for reporting failings or weaknesses
according to the Turnbull report, does a sound system of internal control eliminate human error?
no, reduces but cannot eliminate the possibility of poor judgement in decision making, human error
can be deliberately circumvented and occurrence of unforeseeable circumstances
reasonable but not absolute assurance
what is COSO?
Committee of Sponsoring Organisations
what are the 5 elements of COSO?
CONTROL ENVIRONMENT
-management’s attitude, actions and awareness of the need for internal controls -tone from the top
RISK ASSESSMENT
- need to identify and assess risks in respect of established objectives
- assessment should consider internal and external factors and distinguish between controllable and uncontrollable risks
CONTROL ACTIVITIES = internal control
-after identification, actual specific control actives can be undertaken to reduce those risks
INFORMATION AND COMMUNICATION
-to operate the internal controls, they need quality information
MONITORING
- if system not monitored it will be very difficult to assess whether it is out of control and needs amendment
- this element of an internal control system is associated with internal audit, as well as general supervision
how can management try to summarise their commitment to controls?
- behave with integrity and ethics
- maintain an appropriate culture in the organisation
- set up a a good structure
- set proper authorisation limits
- employ appropriately qualified staff and conduct staff training
what are typical control activity processes?
- having a defined organisation structure
- having contracts of employment
- establishing policies
- setting up a suitable discipline and reward system
- ensuring a system of performance appraisal and feedback
what does the Institute of Internal Auditors define the control environment as?
the attitude and actions of the board and management regarding the significance of control within the organisation
provides discipline and structure for the achievement of the primary objectives of the system of internal control
MOST IMPORTANT
what are the principles that underpin the control environment component?
- the organisation shows a commitment to ethical values
- the board has appropriate expertise and oversee the five competencies
- management must establish an appropriate organisational structure to help achievement of the objectives
- human resource policies and practices to help attract, develop and retain suitable talent
- accountability of employees for their areas of responsibility
what are the internal factors to consider during COSO risk assessment?
e.g. complexity of the organisation, organisational changes, staff turnover levels and the quality of staff
what are the external factors to consider during COSO risk assessment?
changes in the industry and economic conditions, tech changes
what are the principles that underpin the risk assessment component of COSO?
- clear objectives to allow risk assessment and identification
- that risk identification and analysis does take place across the entity
- the potential for fraud arising in pursuit of the stated objectives must be considered
- the internal controls system must be reviewed for changes in the external environment
what are control activities?
policies and procedures that ensure that the decisions and instructions of management are carried out
e.g. authorisations, verifications, reconciliations, approvals
what are the principles that underpin the control activities component?
- select appropriate controls to mitigate the risks to the achievement of objectives
- specifically controls over technology are included
- policies and procedures establish how the controls are implements
what are the 4 COSO categories of objective setting?
strategic, operational, reporting and compliance
what are the 3 operational features of a sound internal control system from the Turnbull guidance?
embedded within operations and not treated as a separate exercise
able to respond to changing risks within and outside the company
includes procedures for reporting control failings or weaknesses
what are some examples of details of controls?
SOAPSPAM
SEGREGATION OF DUTIES:authorisation, handling asset and recording transaction for purchase cycles
PHYSICAL CONTROLS:e.g. safe, inventory checks
AUTHORISATION AND APPROVAL
MANAGEMENT CONTROL:top level reviews and activity controls
SUPERVISION
ORGANISATIONAL STRUCTURE
ARITHMETIC AND ACCOUNTING:double checking
PERSONNEL CONTROLS: training, induction, selection
what 3 broad categories could controls be classified as?
- financial controls
- non-financial quantitative controls
- non-financial qualitative controls
what are financial controls?
controls express financial targets and spending limits
e.g. budgetary control, control over sales, purchases, payroll and inventory cycles
what are the objectives of controls in the sales cycle?
- sales are made to valid customers
- sales are recoded accurately
- all sales are recorded
- cash is collected within a reasonable period
what are the objectives of controls for bank and cash?
- cash balances are safeguarded
- cash balances are kept to a minimum
- money can only be extracted from bank accounts for authorised purposes
what might controls over human resources include?
- recruitment policies including the completion of an application form and the checking of relevant qualifications
- references being taken up prior to appointment
- continuous training
- eligibility to work in the country
- contract of employment
what are some examples of controls over the distribution department?
- HR controls
- signed goods received and goods despatches notes
- regular inventory counts
- monitored CCTV cameras around the distribution depot
- security guards at exits
- bag searches when staff leave their shift
what are non-financial quantitative controls?
controls focus on targets against which performance can be measured and monitored
e.g. balances scorecard targets and TQM quality measures
feedback loop essential
what is the feedback loop in non-quantitative controls?
- performance target
- actual result recorded
- compared with target
- control action taken
what are non-financial qualitative controls?
these form day-to-day controls over most employees in organisations
e.g. employee training, management control methods, physical controls. project management
what is the Bribery Act?
non financial control
1st July 2011 in the UK
bring UK in line with international norms on anti-corruption legislation
offences:
- give or receive a bribe
- failing to prevent a bribe
prosecuted by the Serious Fraud Office
can prosecute both domestic and foreign companies with UK presence
could face 10 years in prison and unlimited fine
What are the steps to developing an adequate control system?
- ascertain the objectives
- research regarding the current systems
- research new controls
- implement new controls
what are the costs of an internal control system?
time of management involved in the design of the system
implementation:
- costs of IT consultants to implement new software
- training all staff in new procedures
maintenance of system:
- software upgrades
- monitoring and review
what are the benefits of an internal control system?
reduction of the risks and achievement of business objectives
what are the limitations of internal control systems?
- over-reliance on any system
- can’t turn a poor manager into a good one
- at risk from mistakes and errors
- can be by-passed by collusion and management override
- controls are only designed to cope with routine transactions and events
- resource constraints in provision of internal control systems, limiting their effectiveness
what is fraud?
dishonestly obtaining an advantage, avoiding an obligation or causing a loss to another party
intentional act
what are some examples of fraud?
- theft of cash
- employee fraud against employers
- crimes against investors, consumers and employees:expense claims
- crimes against financial institutions:fraudulent insurance claims
- crimes against government:benefits fraud, tax evasion
- crimes by professional criminals : money laundering
- e-crime by people using computers e.g. spamming, copyright crimes
what are the prerequisites for fraud?
- dishonesty on the part of the perpetrator
- opportunity for fraud to occur
- motive for fraud
what 2 categories for fraud indicators fall into?
warning signs
fraud alerts
what are warning signs of fraud?
organisational indicators of fraud risk
- absence of anti-fraud policy and culture
- inadequate recruitment processes and absence of screening
- dissatisfied employees who have access to desirable assets
- poor physical security of assets
- rapid changes in information technology
what are fraud alerts?
specific events or red flags, which may be indicative of fraud
- anonymous emails
- emails sent at odd times
- discrepancy between earnings and lifestyle
- unusual behaviour
- alteration of docs
- subsidiary ledgers which don’t reconcile
- inappropriate use of journals
what are the 3 key elements of a fraud management strategy?
prevention
detection
response
together they result in fraud deterrence
what are some methods of fraud prevention?
anti-fraud culture
risk awareness
whistleblowing
sound internal control systems
WARS
how can you apply the COSO model to fraud prevention
control environment: management show active interest in prevention and detection
risk recognition and assessment:identify risk areas, activities where risk might be high e.g. cash handling, assess risk
control activities and procedures:
information:monitoring and reporting:info to the top so they can manage and investigate, revise controls
iterative process
what are some examples of fraud detection?
performing regular checks
warning signals/fraud risk indicators:
- failures in internal control procedures
- lack of information provided to auditors
- unusual behaviour by individual staff members
- accounting difficulties
whistleblowers
how are most frauds discovered?
accidentally
as a result of information received (whistleblowing)
what are some examples of fraud response?
response plan:
- internal disciplinary action
- civil litigation
- criminal prosecution
- responsibliities
what is the purpose of internal auditors investigating fraud ?
- establish the facts
- establish how the fraud occurred and initially went undetected
- consider whether anyone else might have been involved in the fraud
- establish or estimate the size of the loss
what recommendations might an auditor give in light of fraud findings?
- existing internal controls are not sufficient to limit risk so introduce stronger controls
- existing internal controls are sufficient to limit risk but applied inadequately or were ignored in the past
what is the definition of an internal audit?
independent appraisal activity established within an organisation as a service to it. It is a control which functions by examining and evaluating the adequacy and effectiveness of other controls
what is the context of an internal audit in the Turnbull report as a management review of controls?
- integral part of management’s role
- identification, evaluation and management of all key risks facing the organisation
- effectiveness of internal control- financial, operational, compliance and risk management controls
- communication of risk objectives
- action to be taken if weakness found
Risk management vs internal audit: what is being tested?
internal audit: testing and evaluating controls
RM: own entire risk management process
Risk management vs internal audit: what is the key activity?
IA: special investigations as directed by mgmt
RM: maintain risk register
Risk management vs internal audit: what support would the ream provide?
IA: support and assist senior mgmt in projects, some outside risk mgmt arena
RM: lead in developing risk response strategy
Risk management vs internal audit: what is the end result?
IA: contribute to risk identification
RM: provide training and development in risk management matters
who are the 3 different parties involved in the process review of internal audit?
risk management
managers
auditors
what factors affect the need for an internal audit department?
- the scale, diversity and complexity of the company’s activities
- the number of employees
- cost/benefit considerations
- changes in the organisational structures, reporting processes or underlying information systems
- changes in key risks could be internal or external in nature
- problems with existing internal control systems
- an increased number of unexplained or unacceptable events
how does the scale, diversity and complexity of the company’s activities affect the need for internal audit?
larger, more diverse and the more complex a range of activities is, the more there is to monitor
how does the number of employees affect the need for internal audit?
as a proxy for size, no/ employees signifies that larger organisations are more likely to need internal audit to underpin investor confidence than smaller concerns
how does the cost/benefit considerations the need for internal audit?
must be sure benefits outweigh costs
how does the changes in the organisational structures, reporting processes or underlying information systems affect the need for internal audit?
any internal (or external) modification is capable of changing the complexity of operations and, accordingly, the risk
how does the changes in key risks could be internal or external in nature affect the need for internal audit?
the introduction of a new product, entering a new market, a change in any of the PESt/PESYEL factors or changes in the industry might trigger the need for internal audit
how does the problems with existing internal control systems affect the need for internal audit?
any problems with existing systems clearly signify the need for a tightening of systems and increased monitoring
how does the an increased number of unexplained or unacceptable events affect the need for internal audit?
system failures or similar events are a clear demonstration of internal control weakness
what are the expectations of an internal audit?
- formal plan of all audit work that is reviewed by the head of audit and the board/audit committee
- the audit plans should be reviewed at least annually
- each engagement should be conducted appropriately
- progress of the audit should be monitored by head of internal audit
What are the IASB standards for internal audit work?
attribute standards:characteristics of org and the parties performing internal auditing activities
performance standards:nature of auditing activities and quality criteria
what are the attribute standards of internal audit?
INDEPENDENCE:free from interference
OBJECTIVITY: no bias, conflict of interest
PROFESSIONAL CARE:knowledge of the key IT risks and controls
what are the performance standards of internal audit?
MANAGING INTERNAL AUDIT
- head should manage the internal audit
- establish risk-based plans to decide the priorities
- plans reviewed at least annually and submitted for board approval
RISK MANAGEMENT
-identify and evaluate significant risk exposures and contribute to the improvement of risk management and control systems
CONTROL
-help maintain control system by evaluating the effectiveness and efficiency of controls, and by promoting continuous improvement
GOVERNANCE
-assess the corporate governance process and make recommendations
INTERNAL AUDIT WORK
- identify, analyse, evaluate and record sufficient information to achieve the objectives of the engagement
- conclusions should be based on suitable analysis and evaluation
COMMUNICATING RESULTS
-communicate the results of their engagement, including conclusions, recommendations and action plans
what are some structural measures in place to protect the independence of external audits?
- internal auditors should be independent of exec management
- head of internal audit should report directly to a senior director
- head of IA should have direct access to the chairman and the audit committee
- accountable to the A committee
- could outsource internal audit function
what are the advantages of outsourcing internal audit?
- greater focus on COST and EFFICIENCY of the internal audit function
- staff may be drawn from a broader range of expertise
- RISK of staff turnover is passed to the outsourcing firm
- SPECIALIST skills may be more readily available
- COSTS of employing permanent staff are avoided
- may improve INDEPENDENCE
- access to new market place TECHNOLOGIES
- REDUCED MANAGEMENT TIME in administering an in-house department
what are the disadvantaged of outsourcing internal audit?
- possible CONFLICT OF INTEREST if provided by the external auditors
- pressure on the INDEPENDENCE of the outsourced function
- risk of LACK OF KNOWLEDGE and understanding of the organisation
- the decision may be based on cost with the EFFECTIVENESS of the function being reduced
- FLEXIBILITY and AVAILABILITY may not be as high as with as in-house function
- LACK OF CONTROL over standard of service
- risk of BLURRING OF ROLES between internal and external audit
how can we minimise risks when outsourcing internal audit?
- controls over acceptance of internal audit contracts to ensure no impact on independence or ethical issues
- regular reviews of the quality of audit work performed
- separate departments covering internal and external audit
- clearly agreed scope, responsibilities and reporting lines
- performance measures, management information and risk reporting
- procedure manuals for internal audit
how can the efficiency of internal audit be assessed?
by comparing actual costs and output against a target, such as:
- the cost per internal audit day
- the cost per audit report
- the number of audit reports produced
how can the effectiveness of internal audit needs be measured?
identifying evidence of improvements in internal control
what might the contents of an internal audit report be?
EXEC SUMMARY
- main objectives
- scope of audit
- work performed in brief
- results
SCOPE
-detail methodology
OBSERVATIONS and RECOMMENDATIONS
- testing observations
- what to put in place
RECS GRADED BY IMPORTANCE
-difference levels
STATEMENT OF RESPONSIBILITY
- detail Auditing Standards
- sign off from auditor
internal vs external audit, role required by who?
EA: statute, for limited companies
IAL directors and shareholders, usually in larger organisations
internal vs external audit, appointed by who?
EA:shareholders or directors
IA:directors, via the Chief Internal Auditor