Use COSO to build a control stack, not a control pile

The move: stack controls across COSO, do not keep adding approvals. Control environment This is the tone and authority structure. If urgent revenue always beats procedure, fraud controls become optional. Risk assessment This is the forward look. Where could someone manipulate, conceal, or repeat a transaction? The answer changes as products, vendors, and systems change. Control activities These are the visible mechanisms: limits, approvals, segregation of duties, reconciliations, holds, and evidence checks. Information and communication A control only works when the person making the decision sees the relevant risk signal in time. Monitoring Controls age. Monitoring proves whether they still…

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