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How can you ensure your IT infrastructure complies with SOX?

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The Sarbanes-Oxley Act (SOX) is a federal law that aims to protect investors from fraudulent accounting practices by publicly traded companies. SOX also requires companies to establish and maintain effective internal controls over their financial reporting, including their IT infrastructure. If you are responsible for managing or overseeing the IT systems that support your company's financial operations, you need to ensure that they comply with SOX standards and regulations. Here are some steps you can take to achieve SOX compliance for your IT infrastructure.

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Emma K.

Defining the future of governance with ACTIVE GOVERNANCE for identities, processes, and technology. Helping…
Nadia Zaman, FCA, ACMA (UK), CGMA, CPA (Aust.)

Head of Internal Control Office, Risk Management at GrameenPhone Ltd
Adama TRAORE, CFE, CRISC, Certifié CFA IIA

Expert - Risk | Fraud | Compliance | Internal Control | Cybersecurity Analyst Professional | Bank & Fintech | ISO 37301…

1 Assess your current IT environment

The first step is to conduct a comprehensive assessment of your current IT environment, including hardware, software, network, data, security, and policies. You need to identify the IT components that are relevant to your financial reporting and audit processes, and document how they are configured, managed, and monitored. You also need to evaluate the risks and vulnerabilities that may affect the integrity, availability, and confidentiality of your financial data and systems. You can use frameworks such as COBIT or COSO to guide your assessment and align your IT objectives with your business goals.

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Néstor Martínez

Contador Público con experiencia en Auditoría, Control Interno y Contabilidad
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Primero hay que considerar lo que detonó la creación de la Ley SOX y fue el fraude de la empresa ENRON donde los directivos se "auto-autorizaban" prestamos a diestra y siniestra y por otra parte la información financiera fue falseada sin que nadie la validara hasta que los reporteros comenzaron a investigar. Mi sugerencia es que en la infraestructura exista al menos lo siguiente: - Asignación de perfiles limitados. - Una correcta segregación de funciones. - Una adecuada estrategia de liberación para las compras. - Un continuo monitoreo Lo anterior no va a prevenir que se cometa un fraude pero podrá identificarse inmediatamente porque dejará un rastro de quien o quienes fueron los responsables de las malversaciones.

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2 Implement IT controls and policies

The next step is to implement IT controls and policies that address the risks and gaps identified in your assessment. IT controls are the procedures and mechanisms that ensure your IT systems perform as intended and prevent unauthorized access, modification, or deletion of your financial data and records. IT policies are the rules and guidelines that define the roles, responsibilities, and expectations of your IT staff and users regarding the use and maintenance of your IT systems. You should design and implement IT controls and policies that cover areas such as access control, change management, backup and recovery, incident response, encryption, logging, and testing.

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3 Monitor and test your IT controls and policies

The third step is to monitor and test your IT controls and policies regularly to verify their effectiveness and compliance. You should establish and follow a schedule and methodology for monitoring and testing your IT systems, data, and activities, and document the results and findings. You should also use tools and software that automate and simplify the monitoring and testing process, such as log analyzers, vulnerability scanners, audit trails, and dashboards. You should also review and update your IT controls and policies as needed to reflect changes in your IT environment, business requirements, or SOX regulations.

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4 Train and educate your IT staff and users

The fourth step is to train and educate your IT staff and users on the importance and requirements of SOX compliance for your IT infrastructure. You should provide them with the knowledge and skills they need to perform their IT tasks and responsibilities in accordance with your IT controls and policies. You should also communicate and reinforce the benefits and consequences of SOX compliance for your company, such as improved financial transparency, accountability, and performance, as well as reduced risks of fines, penalties, or lawsuits.

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5 Collaborate and coordinate with your auditors

The fifth step is to collaborate and coordinate with your auditors, both internal and external, who are responsible for evaluating and verifying your SOX compliance. You should provide them with the necessary information and documentation they need to conduct their audits, such as your IT assessment reports, control descriptions, test results, and policies. You should also cooperate and respond to their inquiries, requests, and recommendations, and implement any corrective actions or improvements they suggest. You should also maintain a good relationship and communication with your auditors, and seek their feedback and guidance on how to enhance your SOX compliance.

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Adama TRAORE, CFE, CRISC, Certifié CFA IIA

Expert - Risk | Fraud | Compliance | Internal Control | Cybersecurity Analyst Professional | Bank & Fintech | ISO 37301 Système de gestion de la conformité
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- Identify and assess risks related to these assets, such as unauthorized access, malware, system failures, and data loss. - Implement IT controls to mitigate these risks, such as access controls, regular backups, penetration testing, and disaster recovery plans. - Document all changes made, including the reason for the change, the date, and approval. - Manage access and permissions. - Ensure data protection and privacy. - Monitor and log events. - Conduct security awareness and training.

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6 Here’s what else to consider

This is a space to share examples, stories, or insights that don’t fit into any of the previous sections. What else would you like to add?

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Emma K.

Defining the future of governance with ACTIVE GOVERNANCE for identities, processes, and technology. Helping organizations solve complex control challenges with advanced automated control solutions.
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Section 404 focuses on auditing a company’s internal controls, including the controls that govern its IT assets with access to financial data. SOX ITGC audits focus on four critical areas: ? Access controls like Segregation of Duties ? IT Security controls like password policies, security password policies across the enterprise, timely review and remediation of identities, device protection policies including encryption. ? Change management controls establish guidelines for updating systems and records with an audit trail of changes made. These include maintaining a log of changes to system configurations, patches, reports, workflows, interfaces and other programs that support your financial reporting. ? Backup controls

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Nadia Zaman, FCA, ACMA (UK), CGMA, CPA (Aust.)

Head of Internal Control Office, Risk Management at GrameenPhone Ltd
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In addition to this some crucial areas are: - Business Continuity Plan - Incident Management - Review of Access rights - Change Management - Perimeter Security and Vulnerability Management - Configuration Management

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Zia Rezvi

Compliance Project SME | GRC Consultant | Start-up and Non-profit Advisor | Growth Mindset Career Coach | Data Analytics Mentor | ACMA | AI Enthusiast and Champion | Porftolio Career | NED
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Some additional points I would like to add: 1. Appoint a Compliance Officer: Designate a Compliance Officer or team responsible for overseeing and enforcing SOX compliance within your organization. This role is essential for coordinating efforts across different departments, including IT. 2. Secure Data: Protect sensitive financial data by implementing encryption, firewalls, intrusion detection systems, and other security measures. Regularly monitor and audit data access and security events. 3. Remediate Issues: Promptly address any identified issues or deficiencies in your IT controls. Document the remediation process and its effectiveness.

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Fernando Cruz

IT Governance Manager
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Use COBIT and ISO27K as a method to measure and audit IT control. COBIT, more specifically from version 5 onwards, helps in the execution of IT controls, both in risk assessment, in control activities, as well as in monitoring mechanisms. On the other hand, the ISO27k family, more specifically ISO27001, presents several security controls, thus covering controls related to organizational structure (physical and logical), human resources, information technology, supplier management, among others. Therefore, the recommendation is to use a combination of COBIT, ISO27K and COSO.

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How can you ensure your IT infrastructure complies with SOX?

1

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3

4

5

6

1 Assess your current IT environment

2 Implement IT controls and policies

3 Monitor and test your IT controls and policies

4 Train and educate your IT staff and users

5 Collaborate and coordinate with your auditors

6 Here’s what else to consider

Information Systems

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How can you ensure your IT infrastructure complies with SOX?

1

2

3

4

5

6

1 Assess your current IT environment

2 Implement IT controls and policies

3 Monitor and test your IT controls and policies

4 Train and educate your IT staff and users

5 Collaborate and coordinate with your auditors

6 Here’s what else to consider

Information Systems

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