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Thursday, April 17, 2008

SOX Life Blog: Reader Question - Understanding & Evaluating Segregation of Duties

I appreciate when readers share their challenges in applying issues and concepts, as invariably there are an additional dozen people also struggling with this same topic.

One professional writes:
I am new at this and need to understand about SOX and SOD, do you have any other resources? I am looking for Purchases Orders to Negotiations for credit terms, to who enters the new vendor and who signs and who does Accounts Payable all the way through to Fixed Assets? Can you help or recommend a book on SOD or an inexpensive software solution?

This reader had already come across a few past entries (Explaining Segregation of Duties, SOD Part II), and was still struggling with putting the concept into application. An additional entry that is less apparent was on the access management challenges that organizations face when cleaning up business practices - a highly correlated discussion.

My best recommendation for a quick overview and orientation to control practices...

SOX Life Blog: Reader Question - Understanding & Evaluating Segregation of Duties

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Wednesday, April 16, 2008

Segregation of Duties Whitepaper: Minimizing the Cost and Complexity of Sarbanes-Oxley Compliance

Another resource available for those seeking to better understand and manage their SOD risks and issues.

Corporate and IT executives continue to feel the pressures of assuring
federal regulators, auditors, boards of directors, and stockholders that
corporate financial statements are accurate and precise. Additionally, they
must ensure that the personnel responsible for working with financial
information don't have inherent conflicts of interest. A critical element of
Sarbanes-Oxley compliance, known as avoiding Segregation of Duties conflicts
(SOD conflicts), will continue being a top concern. Furthermore, manual
management of SOD conflicts creates too high a risk – especially for global
businesses where hundreds of individuals are managing literally tens of
thousands of financial functions.

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Saturday, May 19, 2007

Segregation of Duties - Part II

From Free IT Solutions, a few links to conflicts of interest as described for SAP (but useful in their generic sense regardless of underlying system):
If you have lists you would like to share that are helpful for evaluating segregation of duties, please send to my attention and I'll be sure to post for public access. (I would particularly interested in matrices that map job titles and duties on the vertical and horizontal to plot incompatible duties).

Best,
Toby Lucich
toby.lucich@insidesarbanesoxley.com
Publisher

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Explaining Segregation of Duties

As a controls professional, I'm sensitive to any employee that has too much on their plate, and have to consider if proper Segregation of Duties are in place. They get burned out. They get tired. They feel rushed. They risk simply going through the motions.

But worst of all, they are at risk for creating justifications for less-than-professional performance. I'm not thinking about just fraud (though this attitude is very much at the heart of embezzlement and other acts of personal gain at the expense of the company), but about the impact to professional levels of service delivery.

When feeling overwhelmed, "what is best or important" gets put aside for addressing "what is urgent." Just looking to one's own personal life provides a rich series of examples where important is sacraficed for urgent - poor eating habits, less/no exercise, lack of sleep - all given up for things that feel urgent at the time, but have limited long-term value. We sometimes get sloppy and lose our focus. Not malicious, just a simple error.

Explaining Segregation of Duties

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Thursday, January 25, 2007

Former NBC Universal Treasurer Jung Indicted in Theft

The former treasurer of NBC Universal Inc. was charged with stealing $813,000 from the company to finance private jet trips to the Caribbean, a summer home in the Hamptons and catered meals featuring Veuve Clicquot champagne.

Victor Jung, 34, pleaded innocent to two counts of wire fraud today in federal court in Manhattan and was released on a $250,000 bond. His lawyer, Christopher Brennan, said Jung will ``vigorously'' fight the charges. Jung, who was indicted by a federal grand jury, faces as long as 20 years in prison.

Jung, of Manhattan, spent most of the stolen money on flights to ``places such as Miami, Antigua and Turks and Caicos Islands,'' U.S. Attorney Michael Garcia said in a statement. Jung and ``his travel companions consumed catered Veuve Clicquot champagne, Grey Goose vodka, Mondavi wine, and shrimp cocktails.''


Former NBC Universal Treasurer Jung Indicted in Theft

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