A Principles-based Approach for Auditing Board Reporting
Author: Jeffrey Houde, CAMS-Audit
Regulatory requirements and guidance around independent testing of Board of Directors (BOD) data gathering and BOD reporting processes is sparse, but applicable processes support key Bank Secrecy Act (BSA)/anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) governance activities. As such, it is incumbent on internal audit to understand applicable risks, process objectives and regulatory expectations and ensure their test programs drive sufficient testing of each. This is a challenging task that requires consideration of numerous factors. This white paper provides discussion of key factors and principles-based guidance to assist with test plan design and execution. By no means is the discussion or principles-based guidance conclusive. The white paper provides a snapshot of key factors and principles that I have found most helpful in my experience.