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A global Investment Bank was concerned with meeting the requirements of Sections 302 and 404 of the Sarbanes-Oxley Act (SOX). The client required assistance in documenting and supporting management’s assessment of the compliance risks across the Asset & Wealth Management (AWM) activities.

Client Challenge

  • Meet requirements of Sarbanes-Oxley Act, Sect. 302 and 404.
  • Demonstrate financial transparency and good corporate governance to investors.
  • Manage ongoing SOX compliance, with special focus on documentation of internal control environment.
  • Leverage the SOX initiative to document, assess and prioritise business areas for improvement.

Our Approach

  • Establish both global and local project governance and PMO structure.
  • Define project scope, identifying “in scope” processes using materiality criteria.
  • Utilise industry knowledge for detailed process mapping and control documentation.
  • Outline risks inherent in the given process and map the controls identified to mitigate these risks.
  • Assess existing processes and internal checks in place, and recommend feasible enhancements leading to compliance.
  • Identify key controls (using assessment criteria based on expectancy, financial impact and reputation risk) to be tested and maintained by the business in the future.
  • Assist the client in developing an approach for ongoing compliance with SOX.

Results

  • Documented critical processes including high-level control value chain.
  • Detailed process flows and narratives, risk control matrix and test scripts.
  • Performed gap analysis and assessment of internal controls.
  • Identified remediation actions, as well as control enhancement opportunities.
  • Enhanced self-assessment process enabling the client to identify gaps proactively and initiate required remediation on a timely basis.