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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.

Companies work like this too, and just like our own personal well-being, someone has to stop and evaluate what is important versus what is urgent. In a rush to chase the next big opportunity, get the books closed, or just keep up with the processing of so many transactions, companies lose site of what is important to keep up with what is urgent.

In this way, a controls or audit function seems to work like a wellness coach for corporate processes and structure, serving as an independent professional to help keep companies mindful of what is important. Segregation of duties simply defined by U of U means
that no single individual should have control over two or more phases of a transaction or operation. Management should assign responsibilities to ensure a crosscheck of duties.
Checks and balances, oversight. While processing business transactions or wrapping things up is urgent, being mindful that we all make careless mistakes is a duty we all have to the companies we support.

A simple challenge question to evaluating segregation of duties is this:
If I make an error in my work, will someone downstream of me detect it before it becomes a major issue for management and shareholders to read about?

By breaking apart tasks (approvals, recording, processing, reconciling results), companies increase the likelihood that they can detect unintentional errors in their results before it's too late.

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Wednesday, May 16, 2007

Where do You find Talent? New Inside Sarbanes Oxley Job Board

One of the things that I've not been quite satisfied with has been our jobs board these last few, uh, years. Originally new jobs were posted via the discussion board, and many folks had a hard time navigatintg the security to get jobs loaded up. A true discussion killer.

We've now rebuilt the Inside Sarbanes Oxley Jobs Board page using some very new tools and are offering an introductory rate on your job postings of $29 for 30 days - less than a dollar a day to get your jobs posted. (Short of going into full car-salesman mode, suffice it to say that I hope this fills a niche in your recruiting strategy).

I hope this is a value added feature for professionals seeking talent, and welcome feedback on this tool and the quality of the candidates you see through this jobs board.

Best,

Toby Lucich
Publisher, Inside Sarbanes Oxley

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