IIARF RESEARCH REPORT

Evaluating Internal
Control Systems
A Comprehensive Assessment Model (CAM)
for Enterprise Risk Management
Carolyn Dittmeier, CIA, CRMA
Paolo Casati, CIA, CRMA

Copyright 2014 by The Institute of Internal Auditors Research Foundation (IIARF). All rights reserved.
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ISBN-13: 978-0-89413-879-9
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CONTENTS
Introduction

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Fundamentals of Risk Management and Internal Control . . . . . . . . . . . . . . . . . . . . . . . . 10

A Single Defined Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Strong Communication of Business and Governance Objectives . . . . . . . . . . . . . . . . . 11
Evaluating Risks: A Comprehensive, Cross-Functional Approach. . . . . . . . . . . . . . . . . 13
The Comprehensive Assessment Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Scope and Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Risk-Based Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Risk Mitigation/Control Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Attributes and Characteristics of Internal Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Complementarity with the COSO Models . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Assessing Risk-Based Internal Controls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Overview of the Assessment Criteria. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Criteria to Assess the Design of Internal Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Performance or Effective Functioning of the Internal Control System . . . . . . . . . . . . . . 38
Evaluation of the Cost-Benefit Factor of Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
Control Assessment Methodology. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
Objective Assessment through Quantitative vs. Qualitative Approach. . . . . . . . . . . . . . 47
Assessment Methodology for Each Internal Control . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Evaluation of the Internal Control System of an Overall Business Process . . . . . . . . . . 50
Expressing an Opinion on the Internal Control System of a Full Process. . . . . . . . . . . . 52
Business Case . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53
Enterprise-Level Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
Notes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60
The IIA Research Foundation Sponsor Recognition. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
The IIA Research Foundation Board of Trustees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
The IIA Research Foundation Committee of Research and Education Advisors . . . . . . 64

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LIST OF EXHIBITS
Exhibit 1.1:

Business and Governance Objectives Tailored to Process Objectives . 12

Exhibit 1.2:

Exemplary Risk Model. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Exhibit 1.3:

Internal Risk Categories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Exhibit 2.1:

Risk Mitigation and Control Objectives. . . . . . . . . . . . . . . . . . . . . . . . . 16

Exhibit 2.2:

Risk Weight. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

Exhibit 2.3:

Control Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Exhibit 3.1:

Comprehensive Assessment Model (CAM) . . . . . . . . . . . . . . . . . . . . . . 21

Exhibit 3.2:

Assessment of Internal Control. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Exhibit 3.3:

Internal Control Case Study. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Exhibit 3.4:

Level of Discretion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Exhibit 3.5:

Discretion Example . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Exhibit 3.6:

Segregation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Exhibit 3.7:

Level of Segregation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Exhibit 3.8:

Segregation Example. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Exhibit 3.9:

Level of Independence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Exhibit 3.10:

Independence Example. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Exhibit 3.11:

Integrative Control Factors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Exhibit 3.12:

Integrative Control Example . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Exhibit 3.13:

Level of Automation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Exhibit 3.14:

Automation Example. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Exhibit 3.15:

Level of Adaptability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33

Exhibit 3.16:

Adaptability Example. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Exhibit 3.17:

Level of Traceability. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Exhibit 3.18:

Traceability Example . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Exhibit 3.19:

Control Performance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Exhibit 3.20:

Level of Timeliness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Exhibit 3.21:

Timeliness Example. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Exhibit 3.22:

Level of Coverage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

Exhibit 3.23:

Level of Availability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

Exhibit 3.24:

Assessing Criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

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Exhibit 3.25:

Level of Compliance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Exhibit 3.26:

Measuring Residual Risk. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

Exhibit 3.27:

Cost-Benefit Factor. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

Exhibit 4.1:

Control Strength . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

Exhibit 4.2:

Assessment of Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Exhibit 4.3:

Control Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

Exhibit 4.4:

Overall Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

Exhibit 4.5:

Overall Process Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

Exhibit 5.1:

Standard Production Time. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Exhibit 5.2:

Control Production Time . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Exhibit 5.3:

Internal Control Production Standards . . . . . . . . . . . . . . . . . . . . . . . . . 56

Exhibit 5.4:

Internal Control Annual Review. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

Exhibit 5.5:

Inadequate Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

Exhibit 6.1:

Assessment Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

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INTRODUCTION

The Comprehensive Assessment Model (CAM) is an innovative methodology that provides for integrated assurance. This assurance is based on the evaluation of control and risk management processes,
considering all pertinent business and governance objectives, through a unified and unique assessment approach.
The CAM approach is both objective and structured, providing the internal audit profession with
the particular advantage of promoting full integration of entity objectives. Once fully implemented,
CAM will allow for entity-level opinions useful for audit committee assurance as well as for corporate
governance reporting required under international stock exchange regulation and recommendations.1
Todays audit committee wrestles with the need to ensure complete and efficient oversight over
internal governance. Oversight is frequently fragmented between compliance, reporting, and operational objectives. For this reason, internal audit planning is often divided into several types of auditing
(management, fraud, IT, operational, financial). Thus, assurance over the enterprise risk model framework is also fragmented.
By its nature and mission, internal audit is intended to provide assurance for the overall adequacy
of the internal governance system and may be the primary user of CAM. Presenting the criteria of this
model to the audit committee or board propels the profession forward by providing a solid, reliable foundation for ensuring effective oversight.
In the authors opinion, CAM is fully aligned with the Committee of Sponsoring Organizations of
the Treadway Commissions (COSOs) enterprise risk management (ERM) and internal control models.
It is also intended to be one of the primary measures supporting the three lines of defense model.2
CAM offers innovative ideas for the internal audit profession in truly applying The Institute of
Internal Auditors (IIAs) definition of internal auditing as an independent, objective assurance and
consulting activity designed to add value and improve an organizations operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve
the effectiveness of risk management, control, and governance processes. In support of this, the key attribute
of CAM is its objective, systematic approach. Parameters may be flexible while maintaining structure
and consistency in application. For this reason, this methodology guarantees true objectivity in the assurance activity.
The methodology provides a way to measure internal controls. It does so in a way that is strictly in
correlation to the risk mitigation/control objectives that support the relevant business and governance
goals of the process.
Eleven business and governance objectives encompass all ERM goals:
1.

Market share or growth

2.

Client satisfaction

3.

Volume

4.

Cost containment

5.

Quality

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6.

Innovation and technology

7.

Profitability

8.

Information reliability (i.e., accounting or management)

9.

Legal

10. Security
11. Social responsibility
These objectives can be drilled down to process level, and the risk mitigation objectives can be
categorized so that all risks can be completely identified. The objectives may be weighted accordingly,
based on risk-assessment techniques.
While the objectives are established in a top-down approach, the subsequent assessment of the
internal controls calls for a bottom-up approach. The methodology is also aligned to the valuable
internal audit approach of evaluating risk management and internal control systems on a process basis.
It thereby cuts across the various business units, following the various sub-phases necessary to achieve
the process deliverables.
CAM makes a firm distinction between assessing the systems architecture or design and its effective
performance or functioning. The overall assessment is a combination of both; however, the evaluation of
an internal control systems effective performance must be based on its design assessment. If the design
is inadequate, it may not even be appropriate to proceed with the performance assessment because of
cost-benefit factors. Alternatively, performing compliance audits based on formal procedures without a
structural design analysis allows for a clear risk of error and audit risk, which is unacceptable for overall
assurance goals.
In addition, CAM provides clarity on the important and essential components of an internal control.
A control must have:
Some sort of expected result, whether a formalized standard or a
managerial expectation
A way to gather information about the actual situation
A way to compare the actual with expectations
A way to react to deviations
This simple definition is fundamental in considering whether controls are effective. It is demonstrated further in the models assessment criteria.
The following criteria are measured to assess the internal control systems design. First, it measures
the degree to which the assigned controls are:
Relevant or capable of responding to specific business and governance objectives
Capable of mitigating the intended risks
Reflective of control process completeness, as previously defined

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Next, it considers:
Degree or extent of set expectations
Process/existence of situational data collection
Review, comparison, and correction process
Criteria that indicate a fault in the internal control systems design include, but are not limited to:
Information without indication of a true correction process
Control based on poor/no standards
Control that captures just partial information about a defective process
Additional evaluation criteria include:
Level of coverage of all risks associated with the identified business and
governance objectives

Note: This criteria brings out the value of an integrated assessment model.

Strength of the selected controls based on several factors, including:

Independence of those accountable for the control activity
Independence of information sources used for control
Segregation of roles
Extent of IT automation
Traceability
Ability to guarantee the control, even in fluctuating volumes of activity

Note: These are illustrated in detail in this report.

Timeliness of the controls in responding to negative events, which further assesses

the ability of the control to correct a problem prior to worst-case scenario (e.g.,
promptly address quality control after customer complaint, preventing customer
loss; IT control address security attack in real time rather than after loss/infection)
The following elements should be assessed to evaluate the effective performance of internal controls:
Availability of resources needed to perform the controls (for example, financial
[available budget], technical [available/maintained tools], and human resources
(HR) [allocated employees])
Compliance with the established control design
Note: While this concept is well understood in traditional auditing, it represents a
fraction of the significant control criteria presented in this report.
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 Activities to monitor residual risks

Controls are not intended to eliminate risks, but rather mitigate them. As such, residual risk levels
must be monitored to ensure that they are consistent with acceptability and tolerance levels identified in
the original control design. When risk levels are disproportionate, the design elements themselves must
be revisited.
Finally, the balance of cost and benefit is considered when evaluating the economic/efficiency factors
of internal controls. An internal control system that effectively and efficiently presides over the mitigation of risk depends on the ability to select optimal control solutions among multiple alternatives.
However, optimization can only be evaluated if the cost of control is properly measured. It must be based
on direct and indirect cost factors. It should also consider whether the organization has an adequate risk
measurement process in place to analyze benefit, opportunity, and risk.
CAM is flexible, as it facilitates the development of personalized guidelines for implementing the
above criteria. This may evolve over time, even with the maturity scale of the models implementation.
The model incorporates risk weightings to account for the relative significance of the underlying business
and governance objectives, as well as the related potential risks that may impact the process.
In summary, the CAM provided in this report encompasses the concept of combined assurance by
truly taking into account all ERM objectives in an integrated manner. It uses an all-inclusive, comprehensive set of criteria and assessment methodology from process level to entity level.
One of the businesses that successfully tested the implementation of CAM is Poste-Italiane, a
large, diversified enterprise operating in financial services, logistics, communication, and IT services.
Its diversification strategy led to nomination as a Fortune Most Admired Company in 2013. However, it
is a challenge for any internal audit department to provide global assurance with limited resources. The
audit universe consisted of multiple selling channels and multiple products that converged into a business process model of approximately 300 major processes. The processes were identified at group level
and then classified under business, governance, support, and resource management categories.
In this business case, 26 risk mitigation objectives were identified against the 11 previously
mentioned business and governance goals. Internal audit was trained in the methodology. Additionally,
a support system was implemented for mapping processes containing risk mitigation objectives and the
models control assessment criteria. Assessment guidelines were formed and implemented for all audits
following the models pilot stage.
In the initial phase of each audit, management collaborated to determine the process subjects
pertinent business and governance objectives. This clearly established relevant risk mitigation/control
objectives for the assessment that follows.
Audit reports produced an overall assessment of the process internal control
system on a scale of 1 to 5. The systems strengths and weaknesses were readily
understandable and analyzed through the models inherent structure.
Process consolidation and full implementation took place over two years. The
evaluation of the internal control design allowed for the creation of efficient and
effective audit programs to be implemented on a standardized basis (through the
wide retail network) to test its effective functioning of controls as well as residual
risks identified.

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The progressive coverage allowed for overall assessments of broad processes and led to the
entity-level assessment process, which was successfully presented to the audit committee. From this and
other business cases shared with chief audit executives (CAEs), we believe that CAMs potential contribution to the internal audit profession, as well as to board governance, is enormous.

FUNDAMENTALS OF RISK MANAGEMENT

AND INTERNAL CONTROL

Before entering into the specific methodology of the CAM, it is important to highlight what are considered to be the essential macro-organizational elements behind sound internal governance. Consideration
of these elements helps the board, audit committee, and management understand:
The positioning of the organization within the maturity scale of governance
The overall internal environment, as contemplated by ERM
Attributes of the organization, which will be useful for the specific analyses
within CAM
The following three elements are intended to ensure an integrated, effective, efficient, and cost-effective internal governance:
1.

A single, defined framework for the risk management and internal control system
of the enterprise

2.

Strong communication of business and governance objectives, which allow for

the definition of appropriate and balanced risk mitigation or control objectives for
each process

3.

A comprehensive cross-functional approach to evaluating risks and controls

In addition, the evaluation of the risk management and internal control systems on an integrated,
objective basis is essential. This includes considering all business and governance objectives at both the
process and entity levels.
The methodology presented in this report allows the audit committee and internal audit to provide
global assurance of the overall risk management and internal control systemin an objective manner
which is strongly aligned with the objectives set by the organization.
A SINGLE DEFINED FRAMEWORK
While risk management and internal control frameworks have been developed successfully3
on a conceptual basis, they have only been partially implemented. Such frameworks are useful for
providing a conceptual structuring of the internal control system components. It is essential that the
board and the organization adopt an overall framework. It should be the premise for the specifications
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10

of formal procedures, frequently cited as requirements within legislation and regulations. A framework
allows for uniformity of governance terminology, as well as a top-down approach to risk management; it
officially breaks down the paradigm of control through procedures.
The ERM4 framework is intended to guarantee a structured approach for identifying and measuring
effective risk levels in all areas of an organization (e.g., from strategic to operational, from compliance
to business, etc.). However, based on the corporate governance reports of listed companies, the ERM
framework has not been widely adopted globally.
To be successful, the framework must be implemented to the point that risk management policies
and control objectives are progressively embedded in the control activities at all levels. Those objectives
must be defined strategically and drilled down to process level. This should include the organizations
incentive/disincentive management system.
The subsequent sections of this report provide a way to measure the controls in correlation to
the risk mitigation and control objectives5 that drive the specific business and governance goals of the
process. While the objectives are established from a top-down approach, the subsequent assessment of
internal control is generally performed bottom-up.
The foundations of the risk management and control environment, as well as general governance
mechanisms (referred to as the internal environment in the ERM framework), are also represented by
processes (e.g., HR, organization, strategic planning), which should be subjected to the same evaluation
methodology. This helps capture all critical elements (e.g., strength, timeliness, coverage, etc.).
STRONG COMMUNICATION OF BUSINESS AND GOVERNANCE OBJECTIVES
As expressed in the ERM framework, the communication of objectives is essential to an appropriately functioning internal control system. At top level, this includes developing an explicitly objective
strategic plan with an integrated, top-level risk management process.
Without adequate communication of objectives, the priorities of the individual departments or
functions that contribute to the process may differ or conflict. For example, the accounting functions
objective of accuracy may conflict with the necessary availability of information for customer relations
management. Likewise, the priority of cost containment within the purchasing department may hamper
or preclude the equally important objective of timeliness with regard to the organizations purchasing
and investment needs.
Exhibit 1.1 shows an example of how business and governance objectives at the enterprise level are
tailored to the process objectives. From there, risk assessment, mitigation, and control objectives can be
defined appropriately.

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Exhibit 1.1: Business and Governance Objectives Tailored to Process Objectives

Process-Level
Manufacturing

Enterprise Level

Process-Level
Financial Services

Business Objectives:
1. Volume

1. Capacity planning

1. Increase transaction volume

2.

Cost Containment

2. Cost containment

2. Minimize overhead

3.

Process Effectiveness

3. Production quality

3. Servicing capability

4.

Customer Satisfaction

4. Time to market

4. Minimize customer claims

5. Profitability

5. -

5. Profitability of financial service

product

6. Innovation/Technology

6. Plant technology

6. Information systems

7.

7. -

7. Increase customer base

Market Share

Governance Objectives:
8.

Information Reliability

8. Reliable control reports

8. Reliable accounting and

management reporting

9.

Legal Compliance

9. Compliance to bid regulation

9. Compliance to financial sector

regulations

10. Security

10. Workers safety

10. Information security

11. Social Responsibility

11. Pollution containment

11. -

Thus, the organization promotes clarity in objectives by referencing a defined goal model. It sets
the stage for appropriate risk assessment in strict correlation to the objectives and ensures full consideration of:
The business objectives in terms of maximizing revenues, cost containment,
product or service quality, retention or increase of market share, customer
satisfaction, etc.
The governance objectives such as legal compliance, reliability of information,
employee welfare, environmental safety, and other social values
In turn, without an explicit understanding of these objectives, risk management is hampered.
As mentioned, risk management and control objectives for a given process can sometimes conflict.
Therefore, a balanced approach toward diversified objectives must be found through risk assessment,
weighting control objectives accordingly.

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12

EVALUATING RISKS: A COMPREHENSIVE, CROSS-FUNCTIONAL APPROACH

As a key element of the governance processes, risk assessment must:
Guarantee full coverage of the organizations significant risks
Adopt approaches to identifying risks, which ensure a clear correlation to the
organizations objectives, both business and governance
Promote an appropriate and proportionate allocation of resources to control
activities and the control functions dedicated to monitoring risks based
on importance
Thus, the models applied in identifying risks must be exhaustive. They must not be conditioned
by excessive focus related to regulatory or other specialized issues. Regulations have sometimes focused
attention on single-risk areas (e.g., business sector, legal, etc.), responding to regulatory pressures and
negative business events. This focus, however, can result in disproportionate attention and allocation of
resources to such risks with respect to other nonregulated risk areas.
Of course, risk assessment differs from one organization to the next. Furthermore, prioritizing the
allocation of resources to control those risks is subject to legal regulation. If that regulation is not considered in a comprehensive framework, it can impede the overall risk management of the organization and
cause inefficiencies in resource management. The end result is an imbalanced risk management process.
As a simple reminder of the broadness of risk categories, an exemplary model is illustrated in
exhibits 1.2 and 1.3. However, any model can be associated with the strategic, compliance, operational,
and financial objectives called for under the enterprise risk framework.
Exhibit 1.2: Exemplary Risk Model (strategic, compliance, operational, and financial)
External Risk Categories
Negative financial and macroeconomic conditions
Negative market trends
Negative customer trends
Competing emerging technologies
Legal or regulatory changes
Natural events
External attacks

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Exhibit 1.3: Internal Risk Categories

Internal Risk Categories
Conflicting or defective strategic or operational objectives
Poor quality of human resources (lack of commitment, fraud, etc.)
Lack of resources (financial, human, technological)
Errors

Thus, the process for assessing the risks must take place at entity level. Single organizational functions dedicated to the assessment of specialized risks must be placed within a single enterprise risk process.
This process must also prioritize risks based on their correlation to the entities objectives, considering:
The extent to which the combination of risks potentially impacts each objective
Or, alternatively, the impact of certain risks on multiple entity objectives
The need for a cross-functional approach to evaluating risks generally calls for a delineation of the
organization by end-to-end processes based on the organization. Business process models create the
basis for cross-functional risk management and offer the appropriate basis for audit universe and strategic audit planning.
The organization should evaluate the risk management and internal control systems process by
process across the various business units and through process phases/activities. The primary basis for
evaluating the internal control and risk management systems should not be the evaluation of the appropriate function of single units and control responsibilities.

THE COMPREHENSIVE ASSESSMENT MODEL

SCOPE AND BENEFITS

An efficient and effective internal control system, which presides over the mitigation of risk,
depends upon the ability to analyze numerous options and ultimately select the control solutions that
optimize cost and benefit.
The cost of internal control systems is an increasingly vital issue. Therefore, a single, consistent,
and comprehensive way to evaluate internal controls must be found. The approach presented here for
evaluating internal control systems, including the risk management processes, is innovative. It has been
successfully tested within complex business environments6 and is based on the following foundations:
a. The evaluation of internal control must make a firm distinction between assessing
the architecture/design of the system and measuring the effective performance/
functioning of the system. The overall assessment of the internal control system
will be a combination of the conclusions in both areas.
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b. A system that is poorly designed leaves more room for undesirable residual risks
than a well-designed internal control system, after taking into account the risk
appetite and risk management strategies. For this reason, if a systems design is
inadequate, it may not be cost-beneficial to proceed assessing its performance until
it is revised and strengthened.
c. The evaluation of the architecture or design of the internal control system should
consider all pertinent risk mitigation/control objectives. It should evaluate the
controls designed to achieve the objectives, process by process, including:
The relevance of existing controls, their capability to preside over the specific
business and governance objectives, and the means to identify deviations from
expected results and correct the process
The completeness of coverageby the controlsof identified risks in relation
to the specific business and governance objectives
The timeliness of the controls in responding to negative events
The strength of the selected controls, based on several factors
d. The evaluation of the effective performance of the system will depend upon:
The availability of resources needed to perform the controls
Compliance with the established control design
Activities to monitor residual risks
e. The evaluation of the economic and efficiency factors of the controls
RISK-BASED APPROACH
As mentioned, the methodology of evaluating an internal control system is founded on risk-based
concepts. It calls for the identification and preliminary assessment of external and internal events that
threaten entity objectives (strategic, operational and reporting, compliance, etc.).
We do not discuss the development of risk concepts and related activities to analyze, quantify, and
assess risks in this report. However, it is important to note that risk management policiesprimarily risk
measurement (probability and impact), as well as risk appetite, tolerance, and acceptance levelsare
fundamental in determining the prioritization of risk mitigation or control objectives.
RISK MITIGATION/CONTROL OBJECTIVES
The risk mitigation or control objectives (hereafter referred to as control objectives) of a given
process must be defined strictly on the business and governance objectives. This must be done on a
comprehensive basis to guarantee a balanced, consistent approach in the design of the internal controls.
The prioritization (or weighting) of a control objective can be based on the number of risks it is
mitigating or the dimension/importance of those risks. Control objectives of a given process can apply

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to any one of several sub-objectives of business or governance goals. Exhibit 2.1 shows examples of risk
mitigation/control objectives, identifiable from broader entity goals.
Exhibit 2.1: Risk Mitigation and Control Objectives
Business or
Governance Objective

Examples of Control Objectives

Respect time standards or ensure general timeliness of the activities.
Ensure quality of product from production processes, per standards.

Ensure quality of
product or service

Ensure the availability of the service and its business/operational continuity.

Meet contractual standards for the service or product.
Guarantee the proper identification and need of buyer/customer.
Ensure financial and legal viability of supplier.

Ensure valid contractual obligations.

Ensure partnership/key
Guarantee reliability of supplier performance.
supplier performance
in support of business Ensure service level (qualitative or quantitative) in line with expectations/needs.
objectives
Ensure optimize cost at required quality standards.
Guarantee technological updates in line with market and legislative context.
Guarantee adequacy of skill base.
Ensure resources
necessary to support
processes

Ensure alignment of quantity of adequate resources with requests.

Ensure services received consistent with services requested.
Achieve timely resource renewal/replacement to avoid business interruption.
Ensure information use and access in conformity with standards to ensure
respect of privacy.

Ensure full respect/

compliance to laws
and regulations

Ensure client identification for purposes of anti-money laundering regulations

(financial sector).
Ensure acquisition of proper client risk profile as the basis for marketing financial
products (banking sector).
Ensure restricted access to ward against illicit acts by outsiders or employees.

Safeguard assets

Protect physical assets from natural events.

Ensure employee security.
Ensure confidentiality of information.

Safeguard information

Guarantee information integrity.

Guarantee accessibility and usability of information.

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Exhibit 2.1: Risk Mitigation and Control Objectives (continued)

Business or
Governance Objective

Examples of Control Objectives

Ensure the substance of transactions backing the accounting entries.
Guarantee completeness of accounting registrations.

Ensure reliable
financial reporting

Guarantee accuracy of accounting entries (precision, ratification, valuation,

classification).
Ensure completeness and timeliness of financial information for management
needs.
Ensure the substance of the transactions backing the financial or management
reporting information.

Ensure the reliability

of management
information, bases for
decision making

Ensure the completeness of information reported to customers, management

reporting, and financial reporting.
Ensure the accuracy of information reported to customers.
Ensure the accuracy of information necessary for the operational process to be
performed.

From the process objectives to the control objectives, one proceeds to their association to risks
and to the actual controls in place. While macro-categories of such goals are fairly easy to identify at the
entity and process level, the definition of an appropriate set of specific control objectives is the key to
ensuring a complete analysis of risk coverage.
Exhibit 2.2 exemplifies this association. The risk weight is addressed later in relation to the methodology for assessing the overall internal control.
Exhibit 2.2: Risk Weight
Business or
Governance
Objective

Risk

Maximize
revenue from
selling activity

Incorrect pricing for

market conditions;
loss of customers

Ensure quality
of product
or service
provided

Customer dissatisfaction for poor

service or after sale
assistance

Ensure full
respect of
laws and
regulations

Penalties arising from

inadequate employee
safety measures

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Level7

Control Objective

Example of Control
Periodic review of the
adequacy of the pricing
model for new and existing products

Ensure product sale

at the highest possible
negotiated unit price

Control of e-learning test

Ensure that personnel are
results on certain aspects
adequately trained and
related to product
competent
knowledge

Guarantee employee
safety measures

Control by the supervisor

of the access to work
places using standard
safety equipment

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ATTRIBUTES AND CHARACTERISTICS OF INTERNAL CONTROLS

Based on the control objectives, controls in a multitude of forms basically perform in a threestep process:
Identification or measurement of a certain existing situation (e.g., behavioral,
informational, circumstantial, etc.), generically called input
Identification of a deviation from a defined standard or a desired/expected outcome
Activation of a corrective action to reach the desired outcome within a
reasonable level
Thus, any control must be analyzed based on the desired outcome, whether it is represented by a
standard or a more discretional comparative point of reference (e.g., managerial, manual, automated,
etc.). Exhibit 2.3 demonstrates the control process from input to output.
Exhibit 2.3: Control Process
Input

Standard

Identification/measurement of input

Comparison of input to standard

Correction

Output

Communication activities

Each of these control steps or components must be considered in the overall assessment:
Determining the standard or desired outcome and/or limits of
acceptable exceptions

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 Capturing the input (identifying the actual circumstances and how the information
is collected)
Ability to compare the input or the actual situation to the desired outcome
or standard
Type and timing of corrective actions in the case of a gap between standard
and actual
Information processes that support the communication of control results and
guarantee the control process in terms of information (e.g., verbal, written, data
processed, etc.)
Any control, whether simple or complex, manual or automated, can be analyzed based on the
combination of these components.
COMPLEMENTARITY WITH THE COSO MODELS
The previously mentioned characteristics and objectives of controlrisk basedare fully consistent with the models issued by COSO, both as to the internal control system (COSO I) and the enterprise
risk management framework (ERM or COSO II).
CAM places emphasis on a comprehensive process of defining entity and process control objectives. This is fundamentally aligned with the objectives-setting process of ERM (as well as the necessary,
practical application of the concepts of the COSO model governance objectives).
The assessment criteria of CAM captures all of the aspects contemplated in the component
Control Environment of COSO I. The CAM methodology covers both control activities and monitoring controls foreseen by COSO. It is also fully applicable to the control processes relevant to HR (e.g.,
incentive systems, etc.).
The key to assessing the internal environment of ERM is the evaluation of pervasive entity processes,
such as HR, strategic planning, and processes governing the allocation of resources. The evaluation of
risk identification, assessment, and response are ERM processes that also fall fully under the scope of the
CAM methodology. It completes the full assessment of the internal control systems within ERM.

ASSESSING RISK-BASED INTERNAL CONTROLS

When it comes to internal controls, effectiveness is determined based on two distinct areas:
The architecture or design of the system (control attributes) that encompass
the intrinsic characteristics of the process, as well as interrelationships with
other processes
The level of actual performance or functioning of the system, which may range
from partial to full execution of the controls as they were designed to be performed
The overall assessment of an internal control systems effectiveness is based on a combination of
these conclusions.
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Once the controls are identified across the process, in relation to control objectives, the first step is
to understand the components. This will help you:
Verify the completeness of the control
Understand the relationships between the various control components
The next step is to assess the adequacy of each control with respect to the control objective(s). The
aggregation of these analyses throughout the various activities of a process will allow the overall evaluation of the internal control system. However, the control analyses must be integrated with the necessary
evaluation of the cost-benefit factors. This collection, integration, and evaluation should be completed
for the key processes of the entire organizations internal control system.
The overall adequacy of internal controls is determined by:
Effectiveness, which is the capacity to guarantee the minimization of the
probability and impact of any risk event, within determined limits
Cost-benefit factor, which is the capacity to guarantee that the overall cost of the
control does not exceed the cost that will incur if the risk event takes place
Ample analysis can be conducted to seek maximum efficiency, which is intended as the optimal
balance between the effectiveness and cost-benefit factors of the controls. In general, the greater the
effectiveness of a control, the greater the cost; alternative control solutions can be deployed in search of
a positive marginal benefit (possibility to improve the effectiveness/cost-benefit factor ratio).
OVERVIEW OF THE ASSESSMENT CRITERIA
The control objectives of a given process have differing degrees of importance. The level of importance is based on the significance and number of the related business and governance objectives. It is also
measured in relation to the level of exposure to the related potential risks threatening their achievement.
The model proposed here maximizes the objectivity of the internal control systems assessment.
The various criteria are measured based on a quali-quantitative scale that minimizes discretional
judgment of the analyst. It is based on elements that are objectively identifiable, both by the process
owner and auditor.
This methodology fully satisfies the assurance objectives required by the audit committee. It does
so through the predefined criteria and the relations between the control, the comparison to an expected
outcome, the corrective remedies, and the objectivity foreseen in assessing the criteria.

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The criteria of CAM is illustrated in exhibit 3.1.

Exhibit 3.1: Comprehensive Assessment Model (CAM)

Business &
Governance
Objectives

Risk
Assessment
Control Objectives

Evaluation
Control

Direct measurement

Adequacy

Efficiency

Economic factor

Effectiveness

Control
design

Cost of
control

Control
performance
Resources
availability

Relevance

Timeliness

Coverage

Compliance
Strength

Discretionality

Integration

Independence

Cost of
resolution
Damage/
penalty

Residual
risk

Segregation

Automation

Adaptability

Traceability

CRITERIA TO ASSESS THE DESIGN OF INTERNAL CONTROLS

The evaluation of the adequacy of the architecture or design of the internal control system must be
conducted process by process. It should consider the relevance of addressed control objectives and the
attributes of the controls designed to achieve them.
As mentioned, the control objective is the fundamental base of analysis. For this reason, each
control objective of the activity or process under analysis should undergo its own assessment. Such an
approach may appear quite analytical at first; however, it will soon become clear that the benefits clearly
outweigh the cost of thoroughness.
In addition to the pure reliability of the methodology, the primary advantage of this approach is
the ability to make a true assertion of the adequacy of internal control. It does so in relation to a particular business objective and/or several associated governance objectives. This capability will satisfy the
specific assurance needs of the board, audit committee or other governing bodies, and top management.
For example:

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 The assurance provided on processes underlying the financial reporting objectives

will be of specific interest to the audit committee as well as the chief financial
officer and can be relied upon by the external auditors in planning their work.
The assurance provided in relation to product quality objectives intended to
mitigate several risk events (customer dissatisfaction, legal, competition, etc.) will
be of specific interest to the board, audit committee, executive committee, strategic
planning head, and so on.
The following list summarizes the assessment criteria for the design of internal controls, and a
complete explanation is presented afterwards.
a. Relevance: the level to which the control activity addresses the pertinent control
objective under analysis
b. Timeliness: how long it takes for controls to respond to negative events. This
element measures the ability to identify and correct a negative event, either by
elimination or limiting its impact on the control objectives. Measurement is
based on evaluating the controls responsiveness within a given time frame. This
measures the moment the negative event occurs and the time that the actual effects
or consequences arise, as a result.
c. Strength: the strength of a control is determined by a series of factors that influence
the probability of control effectiveness should related risks arise
c.1 Discretion: the level to which the control is discretional or subjective, that is, if
it is based on strict standards versus human judgment (who, what, and how the
control is performed)
c.2 Segregation: the level of control segregation that goes beyond the wellknown concept of separation of roles and duties between process activities,
which are typically focused on conflicts of interest promoting fraud. At
this level, it measures the degree of segregation found between the subjects
responsible for the different phases of the control itself (see exhibit 2.3) to
ensure the identification, diagnosis, and correction of any exceptions (errors,
irregularities, structural failures, etc.).
c.3 Independence: the independence element measures the capability of the control
owner to manage resources (technical, human, informational, economic) so
that the control is most effective, acquiring or integrating resources as needed
c.4 Integrative control factor (integration): the degree and manner in which the
control reinforces other control processes for the same objective
c.5 Automation: the degree to which control process are activated by automated
systems (information systems, mechanical devices) that reduce errors derived
from human behavior
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c.6 Adaptability: how adaptable the control is to fluctuating volumes of activity

(i.e., if the control is susceptible to the volatility of the controlled activities, it
is less effective)
c.7 Traceability: how traceable the control is, which allows it to be verified
subsequently in all respects
d. Coverage: the level in which all significant risks are addressed. In other words, the
level of coverage of multiple control objectives, which in turn are based on the
business and governance objectives of the process and related risks.
Relevance
Relevance measures the level to which the internal control process,in all its essential steps, addresses
the specific control objective under analysis. Relevance can be interpreted as:
The capacity of controls to fully or partially intercept negative events, given specific
means to identify and diagnose them
The ability to reduce exceptions to acceptable levels through specific corrective
actions without interfering with regular operations
For example, exhibit 3.2 provides an illustrative evaluation table to maximize objectivity in the
evaluation process.
Exhibit 3.2: Assessment of Internal Control
Assessment of Internal Control for Level of Relevance to Control Objectives8
Rating 1

The full control process (identification, measurement, standard setting, and correction) is
designed to address the specific control objective.

Rating 2

Either the identification/measurement process or the standard setting has not been
designed to address the specific control objective.

Rating 3

While the identification/measurement process and the standard-setting process has been
intended to address the specific control objective, the correction process has not.

Rating 4

Either the identification/measurement process or the standard setting has not been intended to address the specific control objective as well as the correction process.

Rating 5

The entire control process does not address the control objective (identification, measurement, standard setting, and correction).

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A practical case study applying this table is illustrated in exhibit 3.3.

Exhibit 3.3: Internal Control Case Study
Internal control
Control objective

Description

Ensure census/recording of existing customer base in marketing database.

Guarantee the completeness and accuracy of the customer database for marketing
activities.
The employee of the sales office verifies at the moment of a new contract that all
data regarding the customer has been correctly recorded in the system (address,
name, postal code, ID number). In the case of exceptions, query is made to the
accounting department.
Rating 5

Assessment of
the control criteria
of relevance

Performance of the information check is limited to the moment of contract stipulation. It does not capture variations in the client data without new sales activity. The
standard does not predefine aspects such as address (legal headquarters, shipping
address, etc.) for the future marketing campaigns, nor does it establish the means
for checking the address.
The response to exceptions does not necessarily ensure the resolution of the
problem.

Strength
The strength of an internal control is based on several criteria. Each requires an independent evaluation and contributes to an overall evaluation of the robustness or strength of the control. An example
of the overall assessment process of the strength criteria is illustrated later in this report.
The following list contains the seven factors that contribute to the evaluation of strength.

Discretion Factor
The level in which a control is nondiscretional is the extent that control activities are predefined
and objective. There are several areas where specific predefined rules can be defined:
When should the control be activated?
What should be subject to control (activity, data, documents, etc.)?
How is the control performed; in particular, with respect to what standard or with
what tools or resources (e.g., information system)?
What specific corrective actions are foreseen and how are the control
activities documented?
Who performs the control?
When is the control activated (what is the deadline, frequency, circumstance)?
A nondiscretional control activity must not be confused with the mere existence of procedures or
policies. Their existence does not guarantee that they actually describe the aforementioned information.
In certain situations, control systems are considered to be highly predefined simply because there
are few (or no) alternative ways that they can be performed. This can occur in a noncomplex environment,
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with a single accounting unit or a single information system, or in a production area where control must
be completed in a single, physical environment.
The level of discretion can also depend partially on the management level accountable for the
control. For example, high-level management controls are frequently discretionary in nature, in that the
standard or the types of response are based on subjective management decisions and judgment.
This can be quite acceptable in the case of nonrecurring circumstances. However, it should be
considered a weakness when the risk is recurring and frequent.
In the area of line controls, a high degree of discretion applied within control activities demonstrates a significant weakness, especially when segregation of the control processes is low. Exhibit 3.4
shows an example of an evaluation table for the level of discretion.
Exhibit 3.4: Level of Discretion
Assessment of Internal Control for Level of Discretion
Rating 1

The control standard and response time are strictly defined and the individuals who are
accountable for the control are clearly established.

Rating 2

The control standard and response time are strictly defined and the department/unit/
group of individuals accountable for the control is established.

Rating 3

The control standard and response time are discretional, but the individuals accountable
for the control are predefined.

Rating 4

The control standard and response time are discretional and the department/unit/group of
individuals for the control are predefined.

Rating 5

The control standard and response time are discretional and the individuals accountable
for the control are not predefined.

Exhibit 3.5 provides an illustrative application of this evaluation table.

Exhibit 3.5: Discretion Example
Internal control
Control objective
Description

Correct payment of receivables after due date is verified.

Ensure financial coverage for all services is provided to customers.
The employee accountable for administrative credit control verifies that the customers, automatically solicited for payment, have transmitted amounts due. In absence
of payment, the employee prepares and sends a second solicit.
Rating: 4

Assessment of
the control criteria
of discretion

The standard does not define the following aspects: when the control should take
place, which systems or documents should serve as reference for the identification
of the payment.
The response time (for example, one week after solicit) is also not predefined.
Instead, the standard does define the accountable person and the corrective
action.

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Segregation
Segregation is traditionally referred to as the separation of operational activities from control activities to ensure that exceptions or irregularities are actually captured. For this reason, it is typically related
to organizational aspects of attributing responsibility, which avoid conflicts of interest.
In this model, the segregation element assumes a broader sense. The more the activities within the
control process are separated, the stronger the control to prevent malfunctions of the control process
itself, not necessarily determined by conflicts of interest. For example, a separate responsibility could
be attributed to the person/function that establishes the standard of control (e.g., a quality department establishes a predefined quality standard that the operational control function uses in conducting
its controls).
If the standard of reference for the control process is designed by the same person who performs
the control itself, the risk of that control functioning incorrectly is greater. This risk can manifest itself
in the creation of a standard that is inappropriate, rendering the control ineffective by not capturing the
true anomalies of the operations. Exhibit 3.6 maps the segregation of activities within a control process.
Exhibit 3.6: Segregation
Segregation of activities
within a control process

Input

Standard

Identification measurement of input

Comparison of input to standard

Correction

Output

Another example, a lack of reaction in the correction phase, would be identified if a segregated function monitors the activity. An interruption in the measurement process would be caught by a separate
unit responsible for the comparison of operations to standards and/or correction.

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Segregation can be obtained with:

A separate person or function that gathers the relevant information to be
controlled. This may include IT processes that are separately defined/elaborated
from the controlling function.
Separate responsibility for the correction process from the control process
Separate responsibility for the communication of results
This is not to say that all phases of a control process must be segregated; it is simply to say that the
greater the segregation, the greater the degree of strength in assessing the control. However, if the control
objective is related to fraud prevention, then high levels of segregation should most likely be present.
Cost-benefit factors are relevant here, as segregation implicates higher cost for the control. Costeffectiveness requires saturation of resources used in the various control activities, while a high-probability
impact scale of the risk may justify the cost. Exhibit 3.7 provides an example of an assessment table for
segregation criteria.
Exhibit 3.7: Level of Segregation
Assessment of Internal Control for Level of Segregation

Rating 1

Those who are accountable for the control are different from those who perform the
related operational activity. All elements of the control process (input, standard, collection, comparison, and correction) are performed, or provided for, by different subjects or
systems of different groups/units/departments.

Rating 2

Those who are accountable for the control are different from those who perform the
related operational activity. Some elements of the control process (input, standard, collection, comparison, and correction) are performed, or provided for, by different subjects or
systems.

Rating 3

Those who are accountable for the control are different from those who perform the
related operational activity. All elements of the control process (input, standard, collection,
comparison, and correction) are performed or provided for by different subjects/systems
within the same group/unit/department.

Rating 4

Those who are accountable for the control are different from those who perform the
related operational activity. All elements of the control process (input, standard, collection,
comparison, and correction) are performed or provided for by the same subject.

Rating 5

Those who are accountable for the control are the same as those who perform the related
operational activity for all elements of the control process (input, standard, collection,
comparison, and correction).

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Exhibit 3.8 demonstrates an application of the control criteria of segregation.

Exhibit 3.8: Segregation Example
Internal control
Control objective

Description

Control to ensure that the purchasing request relates exclusively to the requirements or resources needed.
Ensure fair access to bidding to all eligible suppliers.
The purchasing department checks that the purchase requisition does not contain
restrictions as to the supplier nor indications that restrict or exclude the selection
of certain companies included in the approved supplier list (which is defined by the
supply strategy committee, headed by the legal affairs).
Should this be the case, the requisition is rejected and sent back.
Rating 2

Assessment of
the control criteria
of segregation

Those accountable for the control (purchasing department) are different from those
responsible for operations (department providing the request for purchase).
Part of the standard (approved supplier list) is defined by a subject outside the
purchasing department.

Independence
This element measures the degree to which the owner of the control is independent with regard to
the management of resources necessary for the execution of the control itself:
Informational: not dependent on information from sources outside the area to
exercise the control activity
Human: increasing or decreasing resources, as needed, for control
Financial: accessing monetary resources, as needed, for control
Technical: able to access or adapt technology and technical resources, as needed
If the owner of the control is not in a position to readily access such resources, the control may
be compromised. It may also be compromised if part of the control must be performed by acquired
resources, such as outsourcing, and financial resources are limited.
The independence element regards both qualitative (competencies, culture, capability) and quantitative factors (number, amounts). Thus, the independence element measures the capability of the process
owner of the control to manage resources so that the control itself is most effective. This includes the
acquisition or integration of resources, as needed. This may be associated with the managerial level to
which the control is attributed, as well as the organizational structure of the organization.
It is important to understand the difference between independence and adaptability, which will be
illustrated later. Independence refers to the level to which one can guarantee the availability of resources
to execute control activities. Adaptability refers to the degree to which the control is able to take into
account changes in the risk environment surrounding the control. Exhibit 3.9 provides an example of
the assessment of independence.

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Exhibit 3.9: Level of Independence

Assessment of Internal Control for Level of Independence
Rating 1

Independence of control with respect to means and timing of obtaining the necessary
resources for the control.

Rating 2

Independence of control with respect to means or timing of obtaining the necessary

resources for the control.

Rating 3

Dependency on either means or timing for the periodic establishment of necessary

resources (human, technical, financial).

Rating 4

Dependency on both means and timing for the periodic establishment of necessary
resources (human, technical, financial).

Rating 5

Continuous dependency on both means and timing for the establishment of necessary
resources (human, technical, financial).

Exhibit 3.10 demonstrates an application of the control criteria of independence.

Exhibit 3.10: Independence Example
Internal control

Automated control of waiting time at the customer counter of the bank.

Control objective

Ensure respect of standard for maximum waiting time in relation to quality customer
service.
Guarantee meeting expected customer service levels (including communication of
waiting time).

Description

The bank branch manager checks on a daily basis the status of waiting times for
each operation of the service windows, the number of persons in line, and the
number of counters open. On the basis of predefined time standards, (maximum 10
minutes) and the existing lines, the manager may decide to open additional service
windows, requesting back office personnel to service clientele.
Rating 1

Assessment of the
control criteria of
independence

The branch manager autonomously monitors the risk of excessive waits by customers and can procure resources from back office activities to compensate when
needed.
If the manager performed the control on the basis of a machine that calculates
waiting time, or is required to ask the human resources department for additional
manpower, the rating would be 3; this is due to the dependence of the control on
other tools or departments.

Integrative Control Factor

The integrative control factor (also called integration criteria) measures the capability of the control
in relation to a given control objective to reinforce and integrate, in a synergic manner, other controls
contributing to the overall level of effectiveness of the internal control system. In an ideal system, a single
control would be sufficient to preside over a given activity to reach the desired outcome.

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However, this theory fails in complex situations where 1) there are many people involved, 2) there
are relatively complex organizational structures, or 3) it is impossible to ensure complete segregation of
first-level controls at a cost-beneficial level.
In such cases, it is necessary to introduce multiple controls that work in conjunction with themselves. These integrative controls may be performed:
Consecutively, in conjunction with the initial control, through a second line
control, an audit verification, or a monitoring function
In parallel, often by some form of repetition of the control in a segregated area
and/or by different individuals or means (i.e., using summarized data versus an
analytical report, sample testing, etc.)
The consecutive type of integrative control is particularly useful when line controls are delegated
to a wide number of people or organizational units, or characterized by a high level of decentralization.
When this control represents a broader monitoring process, it may lose some relevance to the specific
control objective, but it still contributes to reinforcing the achievement of the control objective.
For an example of this, consider the verification of an authorizing signature by a separate department. This confirmation can ascertain that the control is appropriately authorized, though it is not
necessarily able to discern the validity of the underlying transactions.
Parallel controls, instead, are intended to directly mitigate risks related to the same control objectives of the first control. Partial duplication of the control reduces the risk of not achieving the control
objective but increases the cost of the control. Exhibit 3.11 illustrates an assessment table for evaluating
the integrative element of control.
Exhibit 3.11: Integrative Control Factors
Assessment of Integrative Control Factors
Rating 1

The second-level control fully checks the initial control for complete and correct execution,
including exception management (full duplication).

Rating 2

The second-level control checks the initial control for complete execution, as required, and
tests on a sample basis the correct management of exceptions.

Rating 3

The second-level control checks the initial control both for execution and identification and
treatment of exceptions on a sample basis.

Rating 4

The second-level control re-verifies only the identified exceptions.

Rating 5

The second-level control monitors general trends in identified exceptions.

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Exhibit 3.12 demonstrates an application of the criteria regarding integrative control factors.
Exhibit 3.12: Integrative Control Example

First-level control

An automated control on the quality of packaging of products, on a sample basis,

check on presence and resistance of packaging, adhesive closure, labeling, inclusion of warning labels regarding toxic ingredients; tests on actual toxic level are
made on the basis of a sampling process applying established statistical confidence levels.

Control objective

Ensures the quality of product (semi-finished, finished) in relation to defined quality

standards in the various manufacturing phases.

The operators of the quality department, in the case that packages do not pass the
Description of
first-level control, test the toxic content of the item and verify that the product does
second-level control not exceed established limits. The samples are retained and the data is used to
update statistics and quality standards.
Assessment of the
criteria regarding
integrative
control factors

Rating 4
The second control verifies toxic level only in packages already identified as at risk
from the first automated control.

Automation
Automation is the control assessment criteria that measures the use of automated means and
IT to execute the control process. Its complement is the dependence on the human factor to perform
internal controls.
Automation allows for errors or anomalies that are typical of the human factor to be eliminated.
The assessment must consider, however, the strength of the architecture and maintenance of the automated processes. In other words, controls for automated systems and IT represent a strong mitigation of
the risk of error, on the condition that the overall management of technical and IT resources (i.e., planning, development, maintenance, launch, and operations) is free of systemic defects.
This control element includes both hardware and software. Therefore, it is not limited to databases
that may support the communication processes of the control.
Should a low level of automation be present, it is still possible to mitigate risk through adequate
controls within HR management (e.g., processes for training, incentives systems, disciplinary systems,
control culture).

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Finally, obtaining a high rating of assessment for this criteria may not be possible in relation to
cost-benefit issues, which will not necessarily allow for the standardization and automation of the control
process. Exhibit 3.13 provides an example of an assessment table for evaluating the automation element
of control.
Exhibit 3.13: Level of Automation
Assessment of Internal Control for Level of Automation
Rating 1

All elements of the control process (delivery of information [input], measurement, standard,
comparison, and correction) are supported by automated systems or IT.

Rating 2

The control process with regard to input, measurement, and comparison is supported by
automated systems or IT.

Rating 3

The control process with regard to information collection and comparison is supported by
automated systems or IT.

Rating 4

The control process only with regard to information collection is supported by automated
systems or IT.

Rating 5

No phase of the control process is supported by automated systems or IT.

Exhibit 3.14 demonstrates an application of the control criteria of automation.

Exhibit 3.14: Automation Example
Internal control
Control objective

Description

Assessment of
the control criteria
of automation

Control of accuracy of the PIN security code on a debit or credit card.

Safeguard against unauthorized transactions and fraud.
The security procedure of the ATM performs an automatic check on the consistency of the data with respect to master data (card number, expiration, PIN, validity,
etc.). In case of exception after three attempts, the transaction is blocked and the
card is withheld.
Rating 1
All elements of the control process (input, measurement, standard, comparison,
and correction) are supported by automated ATM system.

Adaptability
The adaptability criteria of control strength measures the ability of the control process to adapt to
fluctuations in volume or any volatility of the underlying operations. This does not relate to changes in
business or governance objectives (affecting, in turn, the control objectives) or other structural changes
to the control environment or design. The control is measured rather for its ability to handle peaks and
changes in the related operations that may or may not be programmed or predictable (e.g., seasonal
versus business fluctuations).

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The adaptability criteria of a control considers:

Overall minimum and maximum time for execution of the control (see also the
criteria timeliness)
Volume of transactions or operations in a given period and types of associated risks
Average levels of exceptions handled
Quantity or resources foreseen (in the case of HR, this can translate to full-time
equivalent executing the control process)
The adaptability element can affect the control directly by not allowing the control to form correctly.
It can also affect the control indirectly by altering its timeliness (e.g., back logs, etc.). Diagnostic tools
can be deployed to measure this criteria (e.g., measurement of variability of volumes, frequency of fluctuations, etc.), depending on the critical nature of the underlying operational risk.
Legal issues that place time constraints on controls and resources can limit the strength of adaptability. Exhibit 3.15 provides an exemplary assessment table for this criteria.
Exhibit 3.15: Level of Adaptability
Assessment of Internal Control for Level of Adaptability
Rating 1

The control process is able to manage volumes in excess of average without impacting
negatively on the standard execution times.

Rating 2

The control process is able to manage volumes in excess of average with limited negative
impact on the standard execution times.

Rating 3

The control process is able to manage average volumes at standard execution times.

Rating 4

The control process is able to manage average volumes with some risk of timing in excess
of the standard.

Rating 5

The control process is able to manage volumes below the average.

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Exhibit 3.16 demonstrates an application of the control criteria of adaptability.

Exhibit 3.16: Adaptability Example
Internal control
Control objective

Description

Expenditure control
Ensure that personnel costs are paid only for appropriate corporate
expenditures.
The personnel office, at each monthly accounting closing, verifies every
expenditure report against attached supporting documents. In the case
of exceptions (lack of support, irregular documentation), the office refuses
authorization of payment.
The verification should require three minutes on average. A further minute
is added to the standard in the case of rejection in order to complete
communications.
Historical statistics evidences that expenditure notes number on an annual
basis from 1,500 to 3,200 requests.
The number of rejected expenditure notes average at 33 per year.
Time available by the one employee responsible for this control is no more
than 14 hours per month. Should time required exceed this, the employee reduces the time allocation to the separate area of monthly closing of
accounts.
Rating 3

The control process is able to manage average volumes within the standard
Assessment of the control time.
criteria of adaptability
While if the maximum volume is reached, resources are not available to
manage it, considering the normal level of exceptions experienced; the additional time required does not negatively impact the accounting close.

Traceability
Traceability is the degree to which the internal control system is able to verify the internal control
subsequent to its execution. This typically entails the availability of supporting documentation or
formalized verifiable actions.
The assessment can be affected by legal requisites. For example, formal authorizations may be
mandatory, data conservation may be specified legally, and type and timing of documentation may be
predefined to allow for outside inspection.
A time element is introduced in the assessment by considering how long the documentation is available. Some controls, however, may need to be traceable only up to the end of the underlying operational
cycle (e.g., production through to shipment).

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When the risk of untimely correction is significant, the time limit for traceability may increase in
relation to the need for integrating controls. Exhibit 3.17 provides an assessment table for evaluating the
traceability element of control.
Exhibit 3.17: Level of Traceability
Assessment of Internal Control for Level of Traceability
Rating 1

The manner in which the control process (input, measurement, standard, comparison, and
correction) is managed allows for a subsequent check or re-performance even well after
the operational cycle has been completed.

Rating 2

The manner in which the control process is managed allows a subsequent check or
re-performance within a certain operational period.

Rating 3

The manner in which the control process is managed allows a partial subsequent check or
re-performance within a certain operational period.

Rating 4

The manner in which the control process is managed allows a subsequent check or
re-performance only partially and/or in a very limited time frame.

Rating 5

The manner in which the information (input, standard, comparison, correction) of the
control process is managed does not allow a subsequent check or re-performance.

Exhibit 3.18 demonstrates an application of the control criteria of traceability.

Exhibit 3.18: Traceability Example
Internal control
Control objective

Description

Control of availability of funds in banking account to execute all requested

transactions.
Ensure transactions meet predefined financial limits.
The bank clerk interrogates the information system for fund availability of the client.
In case of insufficient funds or credit, the transaction is refused.
The system logs who accessed the system and when and is conserved for five
years while banking records have a 10-year retention period.
Rating 2

Assessment of
the control criteria
of traceability

The control is fully traceable and verifiable through the system log, which traces the
execution of the control performed by the specific clerk. However, the operational
period allowing traceability (five-year retention of logs) is below the 10-year legal
requirement for document traceability.

Timeliness
Timeliness is important when evaluating the adequacy of internal control. It measures the time to
act or react in relation to:
Collecting the control information and identifying exceptions or anomalies
Activating the correction phase of a control activity to eliminate or reduce the
impact of any exceptions or anomalies
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Both types of response times must be analyzed based on the overall timing and nature of the risks
that surround it, including the moment that:
The critical event emerges
The full risk impact actually takes place (e.g., losses, damages, penalties)
The combined analysis of all of the previous factors and considerations allows for defining specific
assessment rating criteria. An illustration of control performance from risk event to risk impact is shown
in exhibit 3.19.
Exhibit 3.19: Control Performance
Risk Event

Risk Impacts

Time

Risk hedging/splitting
controls

Case 1
Identification/Correction
1^ level controls

Case 2

Identification

Correction

Operating process monitoring systems

Case 3

Identification

Correction
Operating process monitoring systems

Case 4

Case 5

Identification

Correction

High-level monitoring
systems
Identification

Correction

The following cases demonstrate five time scenarios with identification of exceptions or anomalies,
as well as their correction, with respect to the actual risk.
Case 1: The first case regards controls that prevent or reduce the risk (i.e., preventive controls,
accounting provisions, insurance, and diversification) and actually limit the risk before it occurs or can
have full impact. This type of timeliness is appropriate when the related risk is high and the time between
the risk event and impact is short.
Case 2: The second case is typical of a line control that identifies the problem almost simultaneously
to its occurrence. Here, the response is timely enough to prevent the full impact of the risk event. For
example, interception of a defective lot during production with removal before shipping to the customer
results in loss due to the expenses incurred. However, it does not result in customer dissatisfaction. In
this scenario, careful attention must be paid to the timing of the correction, which may or may not be
achievable before the loss impact, depending upon the operational environment.

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Case 3: The third case is typical of monitoring systems over risks that, based on the speed of correction, are able to counteract the consequences of the risk event. They are particularly appropriate for
control systems over risks that are recurrent and significant with a low acceptance level.
Case 4: The fourth case is related to operational monitoring systems covering risks that are not
particularly frequent or significant. In this scenario, management accepts a certain amount of residual risk.
Case 5: The fifth case regards high-level monitoring systems that are typical of top management,
which enacts strategic changes, reorganizations, and investments in response to significant emerging
risks. These are integrative to lower-level operational controls.
Based on the previous scenarios, an exemplary tool for assessing the timeliness of a control response
is shown in exhibit 3.20.
Exhibit 3.20: Level of Timeliness
Assessment of Internal Control for Level of Timeliness
Rating 1

Identification and correction of anomaly simultaneous to the risk event.

Rating 2

Identification of anomaly simultaneous to the risk event and correction within the time of
full impact of the risk.

Rating 3

Identification of anomaly after the risk event and correction within the time of full impact of
the risk.

Rating 4

Identification of anomaly after the risk event and correction after the time of full impact of
the risk.

Rating 5

Identification of anomaly and correction after the time of full impact of the risk.

Exhibit 3.21 provides an illustrative application of the timeliness evaluation table.

Exhibit 3.21: Timeliness Example
Internal control

Semiannual monitoring of actual sales by product in relation to sales plan.

Control objective

Ensure control over business objectives regarding sales volume or income.

Description

Assessment of
the control criteria
of timeliness

The head of the sales department checks twice a year that sales are in line with the
plan using a detailed product line report. Based on this check, the next years sales
plan is adjusted.
Rating 5
The identification of the risk event (lower sales than planned) is subsequent to the
risk event itself and the correction takes place well after the impact (year after).

Coverage
Coverage does not have to do with the quality of the control; it represents the degree to which the
control covers multiple control objectives and related risks. A control process can address operational
control, reporting controls, security controls, etc. In fact, in an integrated and efficient control process,
the design of controls is improved when it is structured to address all or several pertinent objectives.

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Exhibit 3.22 demonstrates how coverage of control objectives is evaluated at overall process level, rather
than single control level.
Exhibit 3.22: Level of Coverage
Evaluation of Level of Coverage of Control Objectives
Rating 1

81100%

Rating 2

6180%

Rating 3

4160%

Rating 4

2140%

Rating 5

020%

PERFORMANCE OR EFFECTIVE FUNCTIONING

OF THE INTERNAL CONTROL SYSTEM
The evaluation of the performance or functioning of the system depends on:
The availability of financial, technological, or HR needed to perform the controls
Compliance to the controls as designed, assuming the controls are
considered adequate
The results of activities in place to monitor and measure possible residual risks; this
ascertains the degree to which control objectives are not reached (i.e., related either
to risk management policies or inadequate controls)
The results of evaluating the functionality of the internal control system determine the presence of
residual risks above and beyond acceptable levels.
How the systems actual performance is evaluated is directly linked to the evaluation of its design.
In fact, it is not possible to evaluate the true effectiveness of the internal control systems performance
without assessing its design.
Thus, evaluating compliance of internal procedures and external regulation is only part of the
internal control system performance assessment. Furthermore, compliance evaluation is only a fraction
of the overall evaluation of the adequacy of the internal control system.
This principle challenges many preconceived notions on control. In addition, verification regarding
the actual functioning of the internal control system is only possible when the design has been assessed
and found to be adequate. If not, the verification process should regard the assessment of the impact of
the residual risks resulting from a defective or inadequate system.
When internal audit verifies the effective performance/functioning of the system, the independence
element of this function reinforces the global risk management and internal control system. However,
this should not be confused with integrative control factors, such as second-level controls, which represent an integral part of the system itself.

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Availability of Resources Needed to Perform the Controls

Sufficiency of resources necessary for adequate control (e.g., financial, technical, and HR) is
required for an internal control system to perform as intended. This assessment is based on the assumption that the system has the appropriate allocation of resources to support all of its control elements.
Some of the control criteria are particularly sensitive to the appropriate availability of resources;
for example, adaptability (the ability to adapt to fluctuating volumes) and timelines. If resources are
inadequate, a positive evaluation of the conformity of the control system to the predefined procedures
and norms will not compensate for the lack of resources. The compliance level is measured at a specific
moment or time, while the adequacy of resources affects functionality over the long term.
As with the assessment of the design of the internal control system, specific criteria and assessment
tables can be developed for control performance factors. Exhibit 3.23 provides a sample assessment table
regarding the availability of resources for control.
Exhibit 3.23: Level of Availability
Assessment of Internal Control for Level of Availability of Resources
Rating 1

In the period considered, all resources (quantitative/qualitative) for the performance of the
control were available for all levels of activity.

Rating 2

In the period considered, resources were sufficient for the performance of the control,
including some activity above normal level.

Rating 3

In the period considered, resources were sufficient for the performance of the control for
the activity within normal levels.

Rating 4

In the period considered, resources were not always sufficient for the performance of the
control for the activity within normal levels.

Rating 5

In the period considered, resources were not sufficient for the performance of the control
for the activity within normal levels.

Compliance
Verification of compliance foresees tests performed by a partially or fully independent body or
function on a system that is sufficiently nondiscretional and traceable. Independence is measured by
the degree to which the controlling body is not involved in the management of the area or in making any
decisions to change the system.
A monitoring body may perform compliance checks to enact adjustments to the system. This is
perfectly acceptable from a management point of view, but it should not be construed as assurance over
the control system provided by bodies such as internal audit. If the system is highly discretional in the
nature of its controls, it may be very difficult to verify its appropriate functioning, even if accountability
is strong.
In some ways, the various phases of the control (e.g., input, comparison to standard, correction,
etc.) can be too judgmental for an auditor or compliance officer to assess. Yet, in the same manner, if
controls are not traceable, they may not be verifiable. Several factors can affect the traceability of information necessary to determine control compliance:

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 The documentation produced after the control was not appropriately conserved
The established time limits for retention of documentation have been exceeded
Inability to access the information9
The significance of the compliance verification results depends upon the test methodology applied
(sampling techniques, etc.). A test of conformity or compliance must be structured so that it fully verifies
the control in all phases (e.g., input, comparison to the standard or expected result, correction). It must
also verify the accountability of the control and the timing as established in the control systems design.
For example, an inventory manager must perform a monthly control on the reliability of inventory
data for raw materials. Through comparison of data provided by the delivery documents and the quantities recorded in the inventory systems, the inventory manager obtains:
The transport delivery receipts and the internal documents produced at the
moment inventory is withdrawn for production. The inventory manager produces a
sheet of totals (i.e., beginning balance, movements, ending balance), then signs and
files it.
The report of inventory produced by the accounting department and transmitted to
the inventory manager by email.
After comparison, if there is a difference, the inventory manager informs the accounting department. Accounting will, in turn, correct the data and provide confirmation to the inventory manager.
Exhibit 3.24 demonstrates the importance of all control phases in assessing criteria.

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Exhibit 3.24: Assessing Criteria

Reminder!
All control phases are
important in assessing any
criteria.

Input

Standard

Identification/measurement
of input

Comparison of input to standard

Correction

Output

Verification of this control asserts that it is effectively functioning and achieving the objective of
providing reliable managerial data and physical inventory. The verification process requires testing of all
six of the following criteria:
The inventory managers ability to receive documents (input) from the purchasing
department, as well as dispatch documents from the production department
Correct preparation of the summary sheet of inventory quantities, based on
purchasing and dispatch data, and direct comparison to the accounting report
The effective communication of differences by merchandise code
The correction of the system records
Consistency of the actual correction with the requested correction
The appropriate and complete filing of documentation
It should be noted that the characteristics of this control are strong in terms of traceability and
nondiscretion. This allows for effective compliance testing. Exhibit 3.25 provides an assessment table
for level of compliance.
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Exhibit 3.25: Level of Compliance

Assessment of Internal Control for Level of Compliance
Rating 1

The test demonstrated full conformity to predefined control procedures for the period
examined.

Rating 2

The test demonstrated full conformity to predefined control procedures for the period
examined, with some exceptions as to the manner or timing of performance.

Rating 3

The test demonstrated partial conformity to predefined control procedures for the period
examined.

Rating 4

The test demonstrated partial conformity to predefined control procedures for the period
examined, with exceptions as to the manner or timing of performance.

Rating 5

The test demonstrated low conformity to predefined control procedures for the period
examined.

Measuring Residual Risks

This assessment criteria measures residual risks and ascertains the degree to which control objectives are not reached. This assessment process is typically performed by the audit activity and tests the
actual impact of a lack of controls (residual risks).
This activity is applicable under different circumstances:
When the design of the internal control system is defective, it replaces compliance
controls, which are not applicable
When the analysis of the systems design has not been fully completed and a full
knowledge of the controls is not available
When the design of the internal control system is available, but the cost of
compliance testing is excessive
The fact that the internal control is insufficient/incomplete for risk mitigation implies that it is not
possible to measure and manage risk events under continuous monitoring activities and ERM principles.
Low organizational maturity is implied by a pervasive need to apply techniques to identify residual
risks arising from incomplete control design, rather than from conscious risk acceptance processes. At a
higher maturity level, a process would be in place that periodically reviews the completeness of control
design. The process would serve to capture, measure, and correct risk events, as well as the risk strategy
applied. Such a process is also essential for updating applicable standards in the internal control system.
Residual risk testing is a one-time or occasional verification of events that directly or indirectly
measure the risk impact. Following are two examples of residual risk testing.

Illustration 1
Consider the control objective of customer satisfaction in the context of a nonstandardized customer
service process. In this process, significant risks are present for delays in service, errors in pricing, and
inadequate ways to gather customer needs.
Assuming the extreme case, in which no internal controls are in place to ensure timeliness of
customer service, residual risk testing would require finding a way to measure the level of effective
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customer dissatisfaction. For example, the residual risk testing might include one or more of the following
analyses: historical trend of complaints, average response time, invoicing patterns (reversals, etc.),
frequency of cancelled contracts, or number/significance of legal disputes.
The residual risk measurement in this example consists of gauging certain negative events and
correlating them to the associated risk of customer dissatisfaction. It can be performed by accessing and
examining data available from the organizations information systems.
This one-time exercise is clearly distinct from management control processes that would monitor
operational performance systematically. Therefore, it should be cleared by management for purposes
of obtaining an explicit acceptance of the residual risk emerging from the analysis. This may serve as a
launching board for management to introduce more sophisticated risk management techniques.

Illustration 2
An adequate internal control system has been defined for the verification of prices applied to
customers in the numerous sales points of an organization. Additionally, the sales function actively verifies the difference between standard sales prices and net sales cashed, with percentage limits. In this case,
it would be possible to perform a compliance test on the line controls of all (or a sample) of the many sales
points. Alternatively, the compliance test could apply to the monitoring activity performed centrally.
On the other hand, it may be more cost-beneficial to perform a test of residual risk. This could
be done by analyzing the entire database for the average error rate in the application of prices, then
comparing it to the acceptable error rate of the line or monitoring control. Exhibit 3.26 provides a sample
residual risk assessment table.
Exhibit 3.26: Measuring Residual Risk
Assessment of Internal Control for Measuring Residual Risk
Rating 1

The test did not evidence residual risk.

Rating 2

The test evidenced residual risk within limits of acceptability and tolerance levels.

Rating 3

The test evidenced residual risk that exceeds the limits of acceptable risk but lies within
related tolerance levels.

Rating 4

The test evidenced residual risk that exceeds the limits of acceptable risk and related tolerance levels.

Rating 5

The test evidenced residual risk that was not contemplated in the internal control system.

It should be noted that the residual risk measurement process can be used to provide assurance on
the adequacy of the internal control system if acceptability and tolerance risk levels are defined. Without
such parameters, residual risk measurement is still useful for establishing risk identifiers or key risk indicators. The internal control system grows stronger when these key risk indicators are transferred to the
process owner, creating integrative control factors.

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EVALUATION OF THE COST-BENEFIT FACTOR OF CONTROLS

In general, evaluation of the controls cost-effectiveness should be subsequent to the assessment of
the design and performance. Its main objective is to determine the reasonableness of the overall balance
between effectiveness of controls and the cost of control.
The cost of control is measured based on fixed and nonfixed costs (e.g., dedicated resources, operational costs, costs of maintaining the information system, etc.) as well as external costs through partners
of insurers. This cost should be compared to that of managing residual risk:
Losses, damages or penalties, and/or lost income arising from risk events
Cost of the resolution of risk events, which varies in relation to the actions needed
to limit the impact of negative events that occur. These include internal costs to
restore a situation (for example, reprocessing costs and advertisement investments
to recover from reputational damage).
Illustration of Cost-Benefit Analysis of Internal Controls
A practical example is the case of an internal control system intended to provide a warning to
the banking regulatory agency of all suspect financial transactions. In many countries, regulation
anticipates penalties in the case of incomplete or incorrect information reported by financial institutions regarding financial transactions for clientele, which are later identified as related to illicit or
illegal activity.
As the number of possible circumstances around irregular/illicit activity is infinite, the
responsibility for identifying potential illicit activity falls on the financial institution, which is best
positioned to create the means for intercepting it. This puts the financial institution in a situation
where it is very difficult to eliminate all risks of incomplete identification, no matter what internal
control system is in place.
The intention of the regulation is not to transfer the difficult job of surveillance of illicit activity
from the authorities to the private entities, but rather to reduce the possibility that the entity can
enhance profits without due consideration of its legality. Therefore, one of the purposes of the
penalty, in a certain sense, is to nullify any opportunity for potential economic advantage from the
clients passive conduct around illicit financial activity. This is a very good case study for evaluating and understanding the considerations around the balance of costs and benefits of an internal
control system.
Full compliance consists of a system that identifies and immediately reports to authorities
any transaction over legal limits. It should substantially reduce, if not eliminate, the risk of penalties
for noncompliance.
Full compliance can also impact clientele. In some cases, clients must await authorization if their
requested transaction exceeds legal limits and must be reported. Should controls exceed competitor
systems, a certain level of business loss is possible.
Another extreme consequence of not putting an adequate internal control system in place, in terms
of cost benefit, would lead to not only penalties but also potential loss of business. Current regulation
allows authorities to halt business transactions.
Apart from these two extremes, there are numerous considerations around the evaluation of the
costs and benefits of an internal control system. An incorrect or incomplete assessment will result in
errors in risk management decision-making.
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Following are examples of elements that can contribute to the assessment:

Cost of full-time equivalents for HR efforts in the activities associated with
the process:
Review and reporting performed by bank tellers
Review of transactions that are nonrecurrent, out of normal standards for
reporting to authorities
Periodic updating of internal standards for reporting anomalies
Maintenance of related information systems
Training employees
Reviewing financial transactions, which are internally reported but should not
be subject to reporting to the authorities
Penalty costs for unreported transactions
Commission income review on reported transactions
These aspects are affected by the internal control systems design based on:
The predetermination of the standard, which may increase or decrease costs of
capturing exception transactions
The level of automation, which reduces the overall burden of HR and increases
reliance on IT systems
Level of integration of line controls, which impacts timeliness and completeness
of reporting
The level of systematic support processes (i.e., training of HR, IT development,
updating of standards and procedures)
Analysis of cost-effectiveness may be necessarily limited when control objectives are associated
with regulatory requirements. For example, it may be sufficient to conduct a general analysis of the
overall cost of the control solutions.
When it appears that there is a significant imbalance, a more analytical approach is called to determine opportunities to replace controls with more cost-effective solutions. Exhibit 3.27 provides a sample
assessment of internal control with regard to the cost-benefit factor.

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Exhibit 3.27: Cost-Benefit Factor

Assessment of Internal Control with Regard to the Cost-Benefit Factor
Rating 1

The overall cost of the internal control system (identification, measurement, correction)
is inferior to the potential losses derived from the risks, taking into account probability of
occurrence.

Rating 2

The cost of the internal control system (with regard to identification and measurement) is
inferior to the potential losses derived from the related risks, taking into account probability
of loss; however, costs associated with the correction process can cause overall costs to
exceed losses.

Rating 3

The cost of the internal control system in relation to measurement and correction exceeds
the potential losses derived from the related risks, taking into account probability of loss.

Rating 4

The cost of the internal control system (identification, measurement, correction) exceeds
the potential losses derived from the related risks, taking into account probability of loss.

Rating 5

The cost of the internal control system (with regard to identification and measurement)
exceeds the potential losses derived from the related risks, taking into account probability
of loss; however, costs associated with the correction process can cause overall costs to
exceed losses.

CONTROL ASSESSMENT METHODOLOGY

The control assessment methodology provides a straightforward process for assessing individual
internal controls. It uses appropriate rating systems designed for each of the criteria, as exemplified in
the previous section. However, assessing a combination of controls is clearly more complex.
The correlation of a variety of control objectives, risks, and processes requires developing a rationale that ensures a balanced and objective control assessment, with due consideration to several business
and governance objectives. Thus, any controls that respond to the needs of multiple control objectives
are particularly important, as is the combination of controls contributing to a single objective. In addition, the controls that preside over the entity process of resource allocation (strategic planning, HR,
etc.) will have a fundamental impact on the evaluation of the internal control system of many, if not all,
other processes.
It is important to respect the following conditions, regardless of how simplified or complex the
system of rules/criteria adopted:
The assessment rules should be explicit.
The assessment rules should be formulated with a top-down logic. At the top,
there are general rules or principles that can be agreed upon at the board or audit
committee level. More detailed rules follow thereafter.
The application of the assessment rules is a bottom-up approach, with aggregation
progressively reaching condensed information that is useful for presentation to top
management and board members.
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 The rules must be applied consistently and fully. If they are not initially sufficient
to express an opinion, it is possible to integrate them over time.
The application of the assessment rules must be documented to allow traceable
evidence of the conclusions.
OBJECTIVE ASSESSMENT THROUGH QUANTITATIVE
VS. QUALITATIVE APPROACH
The methodology in which the controls are identified and measured, in relation to the aforementioned criteria, is intended to provide an objective, nondiscretional approach to assessing the internal
control system of each process. This also allows a consistent bottom-up approach to combining process
control evaluations to reach an entity-level assessment of the internal control system.
Control measurement can be:
Quantitative, using quantitative variables by means of a systemic numerical scale.
For example, the cost factor of control may be considered in terms of full-time
equivalents occupied.
Semi-qualitative, whereby ratings are based on a discrete scale and the classification
is partially subjective/discretional
ASSESSMENT METHODOLOGY FOR EACH INTERNAL CONTROL
The overall evaluation of a control is based on the combined assessment of the criteria presented
in the previous section, using the predefined assessment rules. These rules consider a control attribute
that is not based on a subjective (high, medium, low) rating scale, but rather on objective factors. Those
factors can be observedor identified and consideredin a given scale from positive to negative.
Exhibit 4.1 shows a simple aggregation of assessment criteria for the evaluation of strength in internal
control design.
Exhibit 4.1: Control Strength
Exemplary Assessment of the Strength of a Control
(Rating: 1 optimal - 5 poor)
Criteria

Rating

Discretion

Integrative control factor (when applicable)

Independence

Segregation

Automation

Adaptability

Traceability

Strength (simple average)

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3.8 (= Rating 4)
47

The defined criteria for strength are commonly shared for each control objective to which the
control pertains. It is possible to enhance the rules for formulating an overall assessment of a control for
a given objective while maintaining a predefined logical approach. In addition to considering simple and
weighted averages of ratings, specific rules may be applied for certain criteria.
For example, in relation to the control objective of product quality, if the discretional control factor
rating is worse than three, it may be appropriate to maintain the overall assessment of the control at no
better than two. Discretion contributes to the inherent weakness of the entire system.
There are corrective rules in an overall assessment approach that can be predetermined to construct
an objective methodology. These rules allow for specific considerations and criteria to enter the evaluation process.
It is possible to introduce a risk factor to adjust overall assessment ratings to consider the underlying
risk, and thus priority, of a given control objective. Thus, the rules for formulating an overall assessment
of a control are based on a predefined, logical approach, which may consider average ratings as well as
given criteria.
Some examples follow:
If the control objective pertains to fraud prevention, the relative risk/priority is
high (due to potential high regulatory or reputational impact), and the segregation
control element is assessed at less than optimal (from two to five), the overall
evaluation of the control design cannot be better than three (the same rule could
apply to the traceability element).
If the risk related to the control objective is low in probability and high in impact
(e.g., disaster recovery) and the timeliness element of the control is assessed at
anything worse than one (two to five), the overall evaluation of the control cannot be
better than four.
If the control objective and related risk pertains to ensuring reliable reporting, and
the discretional element is assessed at anywhere worse than three (four to five), the
overall control evaluation cannot be better than four (the same rule could apply to
the traceability element).
This is related to the importance placed on the risk of manipulation as it pertains to
accounting or reporting activities.
If the level of the IT factor of the control is one, the overall evaluation of the control
should be at least three or better (one to three), but it should not exceed the level
of relevance.
Exhibit 4.2 provides an example of an evaluation of the design and performance of a control with
respect to various control objectives, taking into account the underlying risk through predefined risk
ratings. The guidelines noted provide the rationale in correcting the values to take into account the
risk weights.

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Exhibit 4.2: Assessment of Control

Control
objective 3
ensure legal
compliance

Strength

Rating

Adjusted
rating

Relevance

Rating

Adjusted
rating

Control
objective 2
reliability of
reporting

Rating

Control
objective 1
ensure service
quality

Adjusted
rating

Rules

Exemplary Assessment of a Control (Rating: 1 optimal - 5 poor)

Overall
evaluation

Assessment of design of control (rating 1-5, optimal to poor)

Timeliness

1.5

Overall rating of design

1.5

2.3

1.3

1.8

Assessment of performance of control (rating 1-5, optimal to poor)

Availability of resources

Compliance

Residual risk measuring

Overall rating of performance

1.5

1.5

Overall rating of control

2.25

2.25

1.25

Risk weight and overall

assessment

2.0

2.1

Assessment Rules:
Weighted half for control objective regarding quality; any assessment above three
within the production area is considered higher in relation to the importance of this
factors contribution to the time-to-market control objective.
Overall rating cannot be better than three if any element is rated worse than two;
otherwise, a simple average is calculated.
Compliance is not assessed and rated if the assessment of control design is rated
worse than two.
Residual risk measurement is not applied if design and compliance are rated better
than three.
Design and performance rating are given equal importance; thus, a simple average
is calculated.

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 Correction factor through risk weight. Higher risk and priority are applied through
risk management techniques. They have been attributed to the quality objective in
relation to potential reputational impact. Reporting reliability is considered higher
risk in relation to pervasive reliance on information for decision-making purposes.
Compliance, while considered essential, is also considered normal risk and priority.
Overall evaluation is the sum of (risk weight x rating)/sum of risk weights.
It should be recalled that the assessment of coverage (of control objectives) is analyzed only at
process or sub-process level.
EVALUATION OF THE INTERNAL CONTROL SYSTEM
OF AN OVERALL BUSINESS PROCESS
Once the various controls have been individually assessed, it is now possible to combine results and
consider the overall evaluation of the business process. By assessing the design of the internal control
system of an entire process under this methodology, the auditor is able to express an opinion on the
internal control system with maximum objectivity and diligence.
It also serves as advisory service to management, as its analytical nature can demonstrate effectively why and how residual risks are present, allowing management to consciously determine their
acceptability. This evaluation phase allows for further weighting of control objectives and results based
on risk analysis.
At the process level, the overall assessment of the internal control design is based on the quality
of the controls identified within the processs phases, rather than the quantity. Moreover, the adequate
controls illustrated:
Relevance of each control in relation to the business and governance control
objectives associated with the process
Completeness of coverage of all associated control objectives
Strength (consisting of its various critical elements)10
Timeliness of the controls in responding to negative events
Functioning of the controls
A cost/benefit relationship of the controls
The assessment of the process is once again based on predefined rules. For example:
If the evaluation of any of the primary factors of control (i.e., coverage, relevance,
strength, or timeliness) is worse than three, the overall evaluation cannot be better
than three.
If the coverage of risk/control objectives is less than 80 percent, the overall
evaluation cannot be better than three.
If the risk relates to illicit acts/fraud and the segregation of the internal control
system is worse than two (from three to five), the overall evaluation of the systems
design cannot be better than three (from three to five).
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First, it is necessary to assess the overall coverage of control objectives by the internal control
system. This is one of the primary factors contributing to the strength of the overall system; however, it
is examined and assessed only at process level.
Exhibit 4.3 provides an example of the overall evaluation of the internal control system of a single
process, with reference to the various relevant control objectives. It demonstrates an exemplary assessment of coverage of control objectives.
Exhibit 4.3: Control Objectives

Control

Rules

Process
phase

Coverage of Control Objectives

Control
objective 1
ensure service
quality

Control
objective 2
reliability of
reporting

Control
objective 3
ensure legal
compliance

Control
objective 4
guarantee
security

Assessment of relevance (rating 1-5, high to nonexistent)

A.1

Internal control 1

A.2

Internal control 3

A.2

Internal control 3

n/a

A.3

Internal control 4

n/a

A.4

Internal control 5

n/a

1.5

3.6

3.2

Overall relevance rating by

control objective

Risk weighting of control

objective
Overall assessment
of coverage of control
objectives

2.2

Assessment Rules:
A rating of one signifies that all phases of the control are relevant or pertinent to
the control objective; five signifies that no area of the control was found pertinent,
although the control was expected to be relevant to the objective.
Certain control objectives are not applicable to the control and are marked by n/a
(not applicable); overall assessment cannot be better than two if coverage of control
objectives is rated worse than one. Otherwise, overall assessment is the simple
average of the ratings.
Sum of (risk weight x rating)/sum of risk weights; essentially three of the four
control objectives are covered with high priority attributed to the quality control
objective, resulting in an overall positive assessment.

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Exhibit 4.4 demonstrates an exemplary assessment of the internal controls of the overall process.
Exhibit 4.4: Overall Process
Assessment of Internal Controls of Overall Process
Process Phase

Rules

Control

Assessment Rating

A.1

Internal control 1

2.1

A.2

Internal control 2

4.0

A.3

Internal control 3

1.5

A.4

Internal control 4

2.2

A.5

Internal control 5

3.5

Overall assessment of internal controls for

entire process

2.7

Overall assessment of coverage

2.2

Overall assessment of cost-benefit factor

Overall assessment of internal control system

of process

1.7
Rating 2

Assessment Rules:
No weighting of subprocess contribution to overall system (e.g., business vs.
support process) has been considered.
See previous table.
Not analyzed here.
EXPRESSING AN OPINION ON THE INTERNAL
CONTROL SYSTEM OF A FULL PROCESS
CAM allows you to express a succinct and comprehensible opinion to the process owner and
any other stakeholders. The predefinition of assessment criteria and methodology, as illustrated in the
previous paragraphs, allows the assessor to manage all levels of complexity for formalizing reasoning and
approach with appropriate rationale for any sharing or justification with third parties.
With experience, it is possible to further refine or develop the approach. It is also possible to allow
for the integration of additional rules under unique or particular circumstances. An example of an overall
scale for expressing an opinion is shown in exhibit 4.5.

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Exhibit 4.5: Overall Process Assessment

Overall Assessment of the Internal Control System of a Process
Rating 1

Adequate or sound control system: a system that achieves the control objectives
intended to mitigate the risks correlated to the business and governance objectives relevant to the process (based on risk acceptance strategy).

Rating 2

Adequate internal control system with some areas of improvement: a system that
achieves the control objectives intended to mitigate the risks correlated to the business
and governance objectives relevant to the process (based on risk acceptance strategy)
with evidence of some areas, though not critical, subject to improvement to meet the
requisites of sound controls.

Rating 3

Generally adequate internal control system, with some critical areas: the system
achieves, in general terms, the control objectives intended to mitigate the risks correlated to the business and governance objectives relevant to the process (based on risk
acceptance strategy). The characteristics of some of the controls, however, are not fully
consistent with requisites of sound controls (for example, lack of automation, of traceability,
of segregation, etc.).

Rating 4

Inadequate internal control system, subject to significant improvements: the controls

only partially achieve the control objectives intended to mitigate the risks correlated to the
business and governance objectives relevant to the process (based on risk acceptance
strategy).

Rating 5

Insufficient internal control system: the combination of controls is not sufficient to

achieve the control objectives intended to mitigate the risks correlated to the business and
governance objectives relevant to the process (based on risk acceptance strategy).

Of course, once an opinion has been expressed, it does not mean that the evaluation process has
ended. Changes in strategy, control objectives, legislative context, etc. can all change an assessment and
the related status of the internal control soundness. Internal changes can also call for a reassessment:
significant changes in accountability; significant IT system developments that alter the overall design of
internal controls; emerging risks; and impacts of cost reduction measures on controls.

BUSINESS CASE

This section illustrates the comprehensive assessment of the internal control system design of a manufacturing companys business process. Fresco Company produces fresh milk products and considers
product quality (its business objective) to be strategic to the organizations success.
Quality is generally defined by preset standards and regards two control objectives:
Ensure temperature standards for appropriate conservation
Ensure achievement of time-to-market production standards

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The process analysis reveals that an independent quality department is accountable for reviewing
the production departments operating reports to verify that the actual time of each product production
lot is within standard. If an exception arises, the quality department orders the production department
to destroy and replace the lot.
The quality department is performing its check against quality standards based on reports that are,
in part, automatically produced from the production departments operational systems. The other part
is based on manual input by production workers.
The quality standards are reviewed annually through statistical analyses. The review regards
average actual production times and frequency of lots identified outside of quality standards. This allows
for the systematic updating of internal procedures and standards. Exhibit 5.1 illustrates the control identified during the process analysis regarding the verification of standard production time.
Exhibit 5.1: Standard Production Time
Actual time
by production lot

Partially
automated input

Exceptions
recorded in IT
system for
standard-setting
analysis

Production time
standard

Production department
records temperatures
in the supporting IT
system at the end of
production phase

Production
IT system

Quality department check

reports against standards

For exceptions, order

destruction and
replacement of lot

Lot
Destruction
Order

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Production lot
authorized for
packaging

54

Based on the comprehensive assessment criteria, this internal control is evaluated positively. The
business objectives are met, ensuring time-to-market quality assurance and timeliness. The strength of
the control is considered adequate in relation to the mix of control elements as shown in exhibit 5.2.
Exhibit 5.2: Control Production Time
Assessment of control design: Control 1 - control of production time
(Rating: 1 optimal - 5 poor)
Criteria

Rating

Discretion

Integrative
control factor

n/a

Independence

The source of control information is the production department, which is not

independent from the area subject to control.

Segregation

The quality department is accountable for the control, which is independent

from the production department.

Automation

The data collection and reports analysis are partially automated, partially
manual.

Adaptability

The resources dedicated to control do not change with modifications or

peaks in volumes of production.

Traceability

The check performed is not fully traceable. Only the automated checks are
documented.

Overall strength
of control

2.8

The overall evaluation of strength of the control is based, in this case, on the
simple average of the individual criteria.

Relevance

The control is specific to the control objective. However, the input phase
and standard regard only production time and not the storage and shipment phase, which impact time-to-market objectives.

Timeliness

The control intercepts the exceptions immediately after production and

prevents the lot from being shipped to the customer.

Assessment of
overall design
of control

2.3

The IIA Research Foundation

Analysis
The comparison between actual and expected production times is based
on stringent nondiscretional standards. However, the method and the
frequency of periodic review by the quality function is not specified.
This control does not integrate other controls; therefore, not applicable.

The overall evaluation of strength of the control is based, in this case, on the
simple average of the individual criteria.

55

A second control that emerges from the process analysis is updating the standards annually. Exhibit
5.3 demonstrates the flow between annual production time analysis and development of new production
time standards.
Exhibit 5.3: Internal Control Production Standards
Time-to-market
and quality
requirements

Annual average
production time

Annual number of
lots out of
standard

Production
IT system

Head of quality department

produces statistics report
on annual basis

Head of production and

quality departments share
information informally and
evaluate adequacy of
standards vs requirements

Not explicitly
defined
Cost production
requirements

Legal
requirements

Definition of new
production time standards

New production time

standard

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The assessment of the controls strength is summarized in exhibit 5.4.

Exhibit 5.4: Internal Control Annual Review
Assessment of control design: Internal control 2 - annual review
of production time standards (1 optimal - 5 poor)
Element

Rating

Analysis

Discretion

Only the requirements related to legislative norms are predefined. Discretion

is exercised both for market requirements and production cost aspects.

Integrative
control factor

n/a

Not applicable. Although this control relates to the same control objective of
guaranteeing time to market, it does not integrate other controls.

Independence

The control is performed by the people responsible for each of the two
functions who are in a condition to independently manage all necessary
resources.

Segregation

The head of the production department is not responsible for the determination of the market requisites, and the head of the quality department is
not responsible for production cost containment. Both share the responsibility of compliance to norms and regulations.

Automation

Only the gathering of input data is supported by information systems.

Adaptability

The activity does not present variability in transaction volume to be

managed. The control is thus capable of covering maximum volumes
consistently.

Traceability

Only the input and output, if applicable, are recorded through information
systems and thus traceable.

Overall strength
of control

2.6

The overall evaluation of strength of the control is based, in this case, on the
simple average of the individual criteria.

Relevance

While the correction of errors is specific to the control objective, the standards and the identification of errors is limited to production times and do
not address storage or shipping aspects, which certainly impact the overall
time-to-market objective.

Timeliness

The standard set for the control is reviewed only annually on the basis of
specific needs or historical information.

Overall design
of control

3.2

The overall evaluation of strength of the control is based, in this case, on the
simple average of the individual criteria.

The overall evaluation of the internal control system design is adequate (rated at three) based on the
evaluation of the two controls identified. This evaluation is strictly in relation to the control objective of
ensuring compliance with time-to-market requirements.
However, it should be noted that the evaluation must be extended to the more general control
objectiveensuring product quality. This control objective includes both guaranteeing achievement
of time-to-market quality standards and conservation of the product at appropriate temperatures.
In this (extreme) business case, no internal controls were identified in relation to the second control
objective. This control objective is considered to be of equal risk and priority as the time-to-market
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objective. Thus, in assessing the coverage criteria at process level, the evaluation would result in a
rating of four because only one of the two control objectives is covered.
Such a situation would be unacceptable to an organization, which would expect full coverage of
quality control objectives. Thus, the overall evaluation could result in a rating of inadequate. Exhibit 5.5
demonstrates the assessment of an inadequate control system.
Exhibit 5.5: Inadequate Control
Control

Rules

Assessment rating
(1 optimal - 5 negative)

1. Control of production time

2.3

2. Defining production time standards

3.2

Overall assessment of single controls

Overall assessment of coverage

Cost benefit factor
Overall assessment of internal control system of the
process with regard to quality control

2.7

not analyzed
b

Assessment Rules:
Average; no adjustment factors were applied.
If coverage is rated worse than two, overall assessment cannot be better than four.
A rating of four is expressed as:
Inadequate internal control system, subject to significant improvements
The controls only partially achieve the quality control objectives intended to mitigate
the risks correlated to the business and governance objectives relevant to the production
process based on risk management strategy.

ENTERPRISE-LEVEL ASSESSMENT

The evaluation of internal controls using the criteria and methodology provided by CAM should be
applied consistently for each key process within the organizations business model. A full enterprise
assessment is possible due to the aggregation and overall analysis of the internal control systems by
key process.
The key to objectivity in the assessment process is using predefined criteria for establishing the
ratings at various levels of complexity: control, process, entity. Exhibit 6.1 demonstrates the process flow

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58

from direct measurement to rating assessment criteria through to the evaluation of adequacy and development of assessment rules.
Exhibit 6.1: Assessment Process
Assessment criteria

Rating 1

Direct
measurement
element

Rating 2
Rating 3
Rating 4
Rating 5

Guidelines

Indirect
measurement
element
Assessment Rules

Assessment Rules

Operational
and financial
processes
Adequacy of single
internal controls

Resource management
processes

Internal control system

adequacy by process

Assessment Rules

Governance
processes

Adequacy of enterprise
internal control system

The guidelines for enterprise-level ratings may introduce weighting factors or other rules according
to experience or additional information.
Examples of weighting factors for each process to be considered include:
Importance attributed to certain business or governance objectives associated to
the process
Presence of legislation or norms around certain control objectives
Number and significance of risks associated with the process
How recent the process assessment is
Other nonrisk context variables

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Once again, one of the greatest benefits of CAM is the objectivity and consistency of the criteria
applied, as well as its applicability at any level of complexity. The approach is formalized and readily
shared with interested parties. The complexity of the rules will develop based on accumulated experience and needs.

NOTES
1.

For example, European Union directives give the audit committee responsibility for overseeing
risk management, internal control, and internal audit. National Corporate Governance Codes
issued by stock exchanges or regulatory authorities consistently request reporting on the
adequacy of internal control and risk governance processes, and on corporate governance in
general, under the principle of comply or explain.

2.

See The IIAs Position Paper, The Three Lines of Defense in Effective Risk Management and
Control, January 2013.

3.

For example, the COSO framework on internal control provided by the Committee of
Sponsoring Organizations of the Treadway Commission, Committee on Control Criteria
(CoCo), etc.

4.

Enterprise Risk Management (ERM) Integrated Framework, Committee of Sponsoring

Organizations of the Treadway Commission, September 2004.

5.

For purposes of this paper, the terms risk mitigation objective and control objective are used
synonymously. Internal controls are risk-based and designed to provide reasonable assurance
regarding the achievement of objectives related to the business and governance objectives as
defined by COSO.

6.

This methodology is fully compliant with the requirements for a quality management system
defined by the International Organization for Standardization (ISO). ISO 9001:2000 promoted
the adoption of a process approach when developing, implementing, and improving the
effectiveness of a quality management system to enhance customer satisfaction by meeting
customer requirements.

7.

This is a purely exemplary rating from one to five consolidating probability and impact factors. As
noted, risk assessment techniques are not part of the scope of this document.

8.

The control components consist of the identification of actual negative events or circumstances,
its measurement, the comparison with the standard or desired outcome, and the
correction process.

9.

In the case of the internal auditor, this would, in principle, be in contrast with the auditors right
to full access of all records and information.

10. Discretion of control, segregation, independence, integration with other processes, automation,
adaptability, and traceability.
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Karin L. Hill, CIA, CGAP, CRMA, Texas Department of Assistive and Rehabilitative Services
Warren Kenneth Jenkins Jr., CIA, Lowes Companies, Inc.
Jie Ju, Nanjing Audit University
Brian Daniel Lay, CRMA, Ernst & Young LLP
David J. MacCabe, CIA, CGAP, CRMA
Steve Mar, CFSA, Nordstrom
Jozua Francois Martins, CIA, CRMA, Citizens Property Insurance Corporation
John D. McLaughlin, BDO
Deborah L. Munoz, CIA, CalPortland Cement Company
Jason Philibert, CIA, CRMA, TriNet
Charles T. Saunders, PhD, CIA, CCSA, Franklin University
Rui Bezerra Silva, Ventura Petroleo S.A.
Tania Stegemann, CIA, CCSA, Leighton Holdings Limited
Warren W. Stippich Jr., CIA, CRMA, Grant Thornton Chicago
Deanna F. Sullivan, CIA, SullivanSolutions
Jason Thogmartin, GE Capital Internal Audit
Dawn M. Vogel, CIA, CRMA, Great Lakes Higher Education Corporation
Paul L. Walker, St. Johns University
David Williams, Dallas County Community College
Valerie Wolbrueck, CIA, CRMA, Lennox International, Inc.
Douglas E. Ziegenfuss, PhD, CIA, CCSA, CRMA, Old Dominion University

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