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Internal Controls Gap Analysis. • Annual review of key unit internal control points. • Validates controls are in place. • Should be completed by.
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Presentation
Topics
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1
Slide
Financial
Statement
Fraud
Fraud
3
Intentional
deception
resulting
in
unauthorized
personal
gain
Asset
Misappropriation
86%of
Fraud Cases
Median
Loss
Median
Loss Statistics
from
of^ Certified
Fraud
Examiner’s
2020
Global
Study
on^ Occupational
the Association
Fraud
and
Abuse
10%of^
Fraud Cases
Who
Commits
Fraud?
4
who
had
been
with
their
company
longer
stole
twice
as
much
Behavioral
Red
Flags
of
Fraud
Living
Beyond
Means
Financial
Difficulties
Unusually
Close
Association
with
Vendor/Customer
Control
Issues,
Unwillingness
to
Share
Duties
Irritability,
Suspiciousness,
or
Defensiveness
“Wheeler
‐Dealer”
Attitude
of
fraudsters
were
male
of
frauds
were
committed
by
low
‐level
employees
of
perpetrators
were
between
the
ages
of
fraudsters
displayed
at
least
one
behavioral
red
flag
of
cases
they
exhibited
multiple
red
flags
and
in
Statistics
from
the Association
of^ Certified
Fraud
Examiner’s
2020
Global
Study
on^ Occupational
Fraud
and
Abuse
U
‐ M
Compliance
Hotline
Statistics
6
The
number
of
reports
to
the
Compliance Hotline
has
significantly
increased
over
the
past
years
Commonly
Reported
Concerns:
Financial
Mismanagement
Conflict
of
Interest
Data
Privacy
Issues
Hostile
Work Environment
Discrimination
-^
Theft
of
Services
or
Time
of
tips
were
reported
over
the
internet
In
of
tips
were reported
over
the
phone
of
tips
were
anonymous
594
667
844
FY
FY
FY
Standard
Practice
Guide
(SPG)
7
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-^
Standard
Practice
Guide
Overview
presentation
can
be
found
at
http://www.finance.umich.edu/controls/training
Annual
Internal
Controls
Certification
9
Designed
to
improve
awareness
and
accountability
related
to
fiscal
stewardship
and
internal
controls
Leverages
best
practices
from
Sarbanes
‐Oxley
Act
-^
-^
-^
-^
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-^
Key
Unit
Certification
Elements
/
Tasks
10
Review
internal
controls
of
financial
related
processes
‐^ Unit
focused
decentralized
environment
Internal
Controls
Gap
Analysis
Annual
review
of
key
unit
internal
control
points
Validates
controls
are
in
place
Should
be
completed
by
individuals
involved
in
process
Written
Procedures
Documentation
Clarify
roles
responsibilities
Ensure
process
is
happening
as
intended
-^
Help
with
employee
turnover
Management
Oversight
Reporting
Identifies
key
trends
exceptions
High
level
summaries
(by
month,
year,
etc.)
Many
with
drill
‐down
functionality
Dept Sub
‐Certification
(optional)
Provides
support
for
Dean
Director
Certification
Performed
at
the
department
level
Same
questions
as
Annual
Certification
The
Benefits
of
Documented
Procedures
12
-^
Clarifies
responsibilities
and
documents
expectations
-^
Improves
efficiency and
productivity
-^
Makes
it
easier
to
train
new
employees
-^
Assures
consistent
quality
and
performance
The
Written
Procedure
Templates
found
on
the
Internal
Controls
website
include:
Key
control
points
from
the
gap
analysis
tools
Links
to
related
training,
SPGs,
websites,
etc.
Units
can
customize
the
templates
as
appropriate
to
reflect
unit
specific
procedures
http://www.finance.umich.edu/controls/tools
Five
Components
of
an
Effective
Internal
Controls
Environment
13
Monitoring
Activities
Activities
used
to
monitor
processes
or
internal
controls
Information
&
Communication
How
management
communicates
the
culture
of
compliance
&
specific
policies
individuals
need
to
follow
Control
Activities
Procedures
and
internal
controls
put
in
place
to
mitigate
identified
risks
Risk
Assessment
All
of
the
processes
and
associated
risks
in
an
organization
are
assessed
based
on
level
of
risk
and
likelihood
of
occurrence to
determine
how
they
should
be
addressed
Control
Environment
Represents
the
culture
of
Internal
Controls
at
an
organization
(i.e.
a^
culture
of
discipline
&
compliance
or
a^ culture
of
lax
policies
&
procedures
‐^ This
culture
begins
with
the
actions
of
executive
management
‐^ "The
Tone
at
the
Top"
The
COSO
Framework
provides
a^
model
for
evaluating
the
effectiveness
of
Internal
Controls
In
an
effective
internal
control
system,
the
following
five
components work
to
support
the
achievement
of
an
entity’s
mission,
strategies,
and
related
business
practices