Design Controls That Leave Evidence

Controls become real when they produce evidence. Control Objective Start by naming the risk the control addresses. A refund review, vendor approval, access check, or gift pre-clearance should point to a specific compliance objective rather than a vague desire to be careful. Control Activity Define the trigger, the owner, and the action. The activity should be clear enough that two qualified people would perform it the same way. Monitoring Decide how someone will know whether the control is operating. Monitoring can be a sample test, an exception report, a dashboard, or a periodic certification, but it must look at evidence…

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