How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

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Telemetry and the Survival of the Human Species

Without moisture, plants die. Without fodder, the animal food chain collapses. This is why climate change is the greatest threat humankind faces. Crop management needs timely information regarding ambient conditions, and also in the soil itself. In dry areas, online knowledge of trends in rainfall, sunlight, wind speed, leaf moisture, air temperature, relative humidity and solar radiation are indicators of soil stress that can be deadly for plants, and everything that relies on them.

As climate change bites, the need to find solutions accelerates. Drones swoop across to monitor ambient conditions, while probes sunk into plants and the earth in which they grow transmit information to big data repositories for feedback to administrators. In Australia, a remarkable cattle farmer is applying the same approach to his herds.

Nuffield scholar Rob Cook has always been on the edgy side of things. He lost his mobility in a helicopter crash in 2008 patrolling farmland but that has not deterred him. If anything, it has freed his mind to explore the potential that telemetry offers farmers in Australia. He shared this potential with the young beef producers in Roma Australia recently, and here is a summary what he said.

Being wheelchair bound he had to shift from herding with cattle dogs to a more scientific approach. He bought a farm 230 miles / 370 kilometres inland from Brisbane in a warm, temperate climate with significant rainfall even in the driest months. He uses observant software that reports on critical issues like water levels indicating animal consumption, and supplementary water flows from a central irrigation channel.

He also monitors fodder sources for dryer months, and moisture levels in food stocks. Rob is committed to making every blade of grass count. ?We even have the ability to take a photo of the cattle when they are taking a drink of water,? he explains, and that provides valuable information regarding tick and fly infestation and overall condition.

None of this would be possible for Rob Cook without telemetry, which is the process of collecting data at remote points and transmitting it to receiving equipment for analysis. Independent farmers do not have equipment to fund these analytic resources on their own, and use big data resources in a cloud to obtain reports. ecoVaro is on top of current trends. Please speak to us when you need independent advice.

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The Better Way of Applying Benford’s Law for Fraud Detection

Applying Benford’s Law on large collections of data is an effective way of detecting fraud. In this article, we?ll introduce you to Benford’s Law, talk about how auditors are employing it in fraud detection, and introduce you to a more effective way of integrating it into an IT solution.

Benford’s Law in a nutshell

Benford’s Law states that certain data sets – including certain accounting numbers – exhibit a non-uniform distribution of first digits. Simply put, if you gather all the first digits (e.g. 8 is the first digit of ?814 and 1 is the first digit of ?1768) of all the numbers that make up one of these data sets, the smallest digits will appear more frequently than the larger ones.

That is, according to Benford’s Law,

1 should comprise roughly 30.1% of all first digits;
2 should be 17.6%;
3 should be 12.5%;
4 should be 9.7%, and so on.

Notice that the 1s (ones) occur far more frequently than the rest. Those who are not familiar with Benford’s Law tend to assume that all digits should be distributed uniformly. So when fraudulent individuals tinker with accounting data, they may end up putting in more 9s or 8s than there actually should be.

Once an accounting data set is found to show a large deviation from this distribution, then auditors move in to make a closer inspection.

Benford’s Law spreadsheets and templates

Because Benford’s Law has been proven to be effective in discovering unnaturally-behaving data sets (such as those manipulated by fraudsters), many auditors have created simple software solutions that apply this law. Most of these solutions, owing to the fact that a large majority of accounting departments use spreadsheets, come in the form of spreadsheet templates.

You can easily find free downloadable spreadsheet templates that apply Benford’s Law as well as simple How-To articles that can help you to implement the law on your own existing spreadsheets. Just Google “Benford’s law template” or “Benford’s law spreadsheet”.

I suggest you try out some of them yourself to get a feel on how they work.

The problem with Benford’s Law when used on spreadsheets

There’s actually another reason why I wanted you to try those spreadsheet templates and How-To’s yourself. I wanted you to see how susceptible these solutions are to trivial errors. Whenever you work on these spreadsheet templates – or your own spreadsheets for that matter – when implementing Benford’s Law, you can commit mistakes when copy-pasting values, specifying ranges, entering formulas, and so on.

Furthermore, some of the data might be located in different spreadsheets, which can likewise by found in different departments and have to be emailed for consolidation. The departments who own this data will have to extract the needed data from their own spreadsheets, transfer them to another spreadsheet, and send them to the person in-charge of consolidation.

These activities can introduce errors as well. That’s why we think that, while Benford’s Law can be an effective tool for detecting fraud, spreadsheet-based working environments can taint the entire fraud detection process.

There?s actually a better IT solution where you can use Benford’s Law.

Why a server-based solution works better

In order to apply Benford’s Law more effectively, you need to use it in an environment that implements better controls than what spreadsheets can offer. What we propose is a server-based system.

In a server-based system, your data is placed in a secure database. People who want to input data or access existing data will have to go through access controls such as login procedures. These systems also have features that log access history so that you can trace who accessed which and when.

If Benford’s Law is integrated into such a system, there would be no need for any error-prone copy-pasting activities because all the data is stored in one place. Thus, fraud detection initiatives can be much faster and more reliable.

You can get more information on this site regarding the disadvantages of spreadsheets. We can also tell you more about the advantages of server application solutions.

Maturing Into CMMI

 

In all likelihood, the reason why you landed on this page was because you were seeking CMMI experts to help you meet the demands of a growing number of potential clients who require CMMI compliance.

Whether or not you’re here for that reason, you might want to know why CMMI or Capability Maturity Model Integration is steadily becoming a common denominator among highly successful software and engineering development companies. If you stay for a while, we can show you how CMMI can substantially increase your organisation’s chances of:

  • reducing development costs;
  • acquiring new customers and retaining old ones;
  • beating deadlines;
  • bringing down development time;
  • increasing the overall quality of your products and services; and
  • improving the level of satisfaction of customers, employees, and all other stakeholders.

Surely, no organisation can be too small or too big to aspire for such benefits of attaining high levels of maturity and capability.

If you want to look beyond Maturity Level ratings, then you’ve come to the right place. We focus on introducing CMMI principles and blending them into your organisation’s culture to achieve a truly superior and sustainable business advantage. Compliance will then be an inevitable offshoot of the actions you make.

Likewise, if you simply want to obtain a deeper understanding of CMMI and learn how it can be applied either to your entire organisation or to specific projects, we’d be happy to assist you in that regard as well.

Finally, when you’re ready, we can also conduct CMMI appraisals either for benchmarking purposes or simply for determining how well your process improvement initiatives are going.

CMMI Consulting

Are you worried that implementing CMMI might entail an overhaul of your current processes? Don’t be.

CMMI is all about improving current processes, not replacing them. Ideally, the final result of all process improvement activities should be hinged on your own business objectives and context, so we’ll make sure it remains that way when we work with you.

We rely on our extensive knowledge and experience in CMMI, engineering, software development, and technologies as well as in change and project management in providing model-based process improvement services. Whether you’re gearing up for an appraisal or simply want to employ CMMI-based practices, these are the things we can do for you.

  • Help you interpret how CMMI can be implemented in relation to your business.
  • Assist in convincing sponsors and stakeholders to support your CMMI implementation initiatives.
  • Introduce the necessary training to all individuals who need to undertake them.
  • Conduct a Gap Analysis to find out where your company’s current processes stand relative to their CMMI specifications.
  • Assemble a process group that will champion your process improvement initiatives. We’ll facilitate effective collaboration among its team members, transforming them into a cohesive force designed to carry out plans and motivate everyone else down the line.
  • Introduce tools and practices that will improve the efficiency of our process improvement initiatives.
  • Carry out periodic evaluations and produce reports to provide sponsors and stakeholders a clear picture of our progress.

CMMI Training

Still not convinced CMMI is right for you? There’s only one way to fully grasp the benefits of implementing CMMI – take the Introduction to CMMI course. Although what happens next is entirely up to you, we’re pretty sure you’ll make the right decision after passing it.

Do you need to include people from your organisation in a SCAMPI (Standard CMMI Appraisal Method for Process Improvement) team? They’ll have to undergo this course too. The Introduction to CMMI is for systems and software engineering managers and practitioners, appraisal team members, process group members, and basically anyone who want to grasp CMMI fundamentals.

This is what you’ll be able to do after going through 3 days of lectures and exercises:

  • Gain a deeper understanding of the various components of CMMI-DEV models and their relationships.
  • Discuss the process areas in CMMI-DEV models.
  • Extract and interpret aspects in the model relevant to your own organisation’s processes.

We also offer highly specialised training and workshops such as those for:

  • Achieving High Maturity Levels
  • Top Executives
  • Team Building in Preparation for Appraisals

CMMI Appraisal

An organisation new to CMMI will want to know first how far their current processes are relative to the implementation of model-based improvements in order to determine the resources and time that have to be spent to get there.

Similarly, an organisation already well acquainted with CMMI and has begun taking steps in improving processes, will eventually want to know how close it has come to the Maturity Level it has aimed for.

In both cases, these organisations will have to be assessed by a qualified CMMI appraiser to obtain an accurate picture of their current status. We can perform appraisals on either your entire organisation or on specific projects/practices within a process area. Our appraisers can conduct the following SCAMPI (Standard CMMI Appraisal Method for Process Improvement) appraisals:

  • SCAMPI Class A – This is what you’ll need if you’re aiming for a level rating.
  • SCAMPI Class B – You may want to use this for process reviews or for preparing for a SCAMPI Class A.
  • SCAMPI Class C or Gap Analysis – We typically conduct this for organisations who have yet to implement CMMI-based initiatives so that they can design the most cost-effective road map for the implementation proper.

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