A)The accounting profession has invested significantly in
separation of duties because of the understood risks accumulated
over hundreds of years of accounting practice.
By contrast, many corporations in the United States found that
an unexpectedly high proportion of their Sarbanes-Oxley internal
control issues came from IT. Separation of duties is commonly used
in large IT organizations so that no single person is in a position
to introduce fraudulent or malicious code or data without
detection. Role based access controlis frequently used in IT
systems where SoD is required. Strict control of software and data
changes will require that the same person or organizations performs
only one of the following roles:
- Identification of a requirement (or change request); e.g. a
business person
- Authorization and approval; e.g. an IT governance board or
manager
- Design and development; e.g. a developer
- Review, inspection and approval; e.g. another developer or
architect.
- Implementation in production; typically a software change or
system administrator.
The IT function that should be segregated in large
companies:
- Authorizing a transaction, receiving and
maintaining custody of the asset that resulted from the
transaction.
- Receiving checks (payment on account)
and approving write-offs.
- Depositing cash and reconciling bank
statements.
- Approving time cards and having
custody of pay checks.
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Internal controls in accounting: Purchasing, payables and
payments (PPP)
This stream of transactions relates to all of the steps in the
process of purchasing, including the authorization of purchases,
the receipt of goods and services, and the recording of payables
and payments. The following are key areas where having internal
controls ensures oversight:
- Authorization for purchases: It is important that the
authorization for purchasing is clearly delineated, both in terms
of what types of goods a person is responsible for purchasing, as
well as the maximum dollar value that they can authorize
- Receipt of incorrect shipments: This can occur if a different
item (or quantity) is delivered than what was ordered. Goods that
are received should be compared closely to what was ordered and
invoiced
- Payment for goods not received: This may occur through error on
the part of the supplier, a loss in transit, or as the result of a
fictitious invoice. A control needs to be in place that ensures
invoices correspond with the receiving records before they are paid
(i.e., that the goods have been received). When goods are yet to be
received, there needs to be a process for ensuring that they do
arrive
- Errors in the amount paid: Payments should always be checked
against the invoice before they are sent. For example, if a
bookkeeper prepares several cheques, the person who signs them
should review the related invoices (or supplier statement).
Ideally, there would be a system of noting on the invoice that the
goods were received for the amount invoiced
Internal controls in accounting: Payroll
The payroll stream relates to all of the actions involving
payroll processing and will naturally overlap with some of your HR
functions. The following are key activities where having internal
controls ensures oversight:
- Preparing and reviewing timesheets: This is a key internal
control for supporting all employees’ time. It is especially
important for hourly employees and for supporting the amount of a
salary that is allocated to a project (this information may be
needed for funding purposes such as IRAP or forSR&ED tax credit
claims)
- Correctly calculating employee’s wages: This includes making
sure that the wages that are paid to an employee agree with the
amount that was authorized for that employee. It also extends to
ensuring that the payroll deductions are properly calculated. While
this process can be made easier by using a payroll provider, it is
important that the payments be properly reviewed
- Monitoring changes in payroll: It can be easy to base the next
payroll on the last, but when there are changes, it is essential
that they be properly communicated to the person in charge of
payroll
- Monitoring for non-employees: Employees who leave the company
and are not removed from the payroll system, or fictitious people
who are added to the payroll system, are a large risk to the
payroll stream. It is important that the pay register is reviewed
regularly by someone other than the employee normally in charge of
processing payroll, and that that person has knowledge of the
current employee list
Internal controls in accounting: Sales, receipts and
receivables
Similar to PPP, this stream deals with all of the transactions
related to the sale of goods and services. The following are key
areas where having internal controls ensures oversight:
- Incorrect/unauthorized sales prices, discounts and credits:
Where prices and discounts are flexible, there should be a range of
discounts that are allowed to be offered, with and without
management approval. Any discounts given and any credit memos later
applied should be compared to the allowable range
- Sales being incorrectly recorded or not recorded: In the case
where employees manually enter sales, have a process to ensure that
the sales are being recorded and that they are being recorded
accurately. If invoices are not being generated from a computer
system, using pre-numbered invoices (and ensuring that all invoice
numbers are accounted for) is a good start
- Payments not received: There is a risk that payments will not
be received. Therefore, a system is needed to ensure that
receivables are being collected and credited to the correct
customer’s account receivable