Allen Keele is a certified fraud examiner, information security manager, information systems auditor and information systems security professional, among 20 other professional and technical accreditations. He shares over 17 years of experience in information security and risk management, including nine years of conducting professional advanced business lectures and seminars across the globe. Keele spoke to hilary okeke on a range of issues.
Training on Fraud Detection and Management
In information security, one of the most important things we have is not always having information security itself but having the internal control to be sure that we have information security. I wrote the text that most people use to prepare for Certified Information Systems Auditors (CISA) exams around the world. In that context, a lot of the controls that the internal auditors monitor have to do with controlling internal breaches and abuse. So, it would make logical sense to extend my auditors knowledge and expertise and interest into internal fraud detection and management. I was shocked to find in my younger days that 90 percent of frauds can be detected through the books. So many organizations tell you that they have no fraud problem but when you take a careful look, you find that there actually is a problem. People device all kinds of means to get money out their organizations without doing anything on the book. That was very concerning to me as an auditor. Fraud in itself is a disaster for an organization. It could lead to loss of market share if made public. Organizations need to be prepared for that kind of disaster just the same way they prepare for fire. So that is why we extended our training to business continuity, disaster recovery, as well as a new perspective on fraud. There are lots of folks out there who offer training on business continuity and disaster recovery, but what we are doing that is unique in the market is that we are not trying to project our best practices; we are teaching according to the new British standard – BS 25999. It is a new international standard designed to keep your business going during the most challenging and unexpected circumstances. It provides a basis for understanding, developing, implementing and managing business continuity within your organization and gives you confidence when dealing with stakeholders both within and outside your organization. BS 25999 has been developed by a group of experts representing a cross-section of industry sectors and governmental organizations which is reflected in its applicability. The standard is suitable for any organization, large or small, from any sector. It is particularly relevant for those that operate in a high risk environment such as the finance, telecommunications, transport, utilities and public sectors, where there is need for continuity. I have had a lot of organizations tell me they went for training a couple of years ago – the British standard may have existed a couple of years ago for training, but it just got ratified recently. There was no standard prior to BS 25999. So, this is a whole new world in terms of getting the certification to prove that your organization has the ability to manage fraud and disaster. Often times, organizations do things because regulators make them. Now more than ever, you have financial regulators requiring you to prove that you have strong control against fraud but you do not even have a fraud policy.
Best Security Strategy for an Organization
The best security strategy is first, to have one. Whether it is fraud, business continuity or information security; organizations have this odd tendency to casually appoint people within the organization to handle those areas. They point to the IT or compliance person – somebody who does not understand that area, and that person has to go and figure out what controls to put in place to get things working. So the problem is that currently, there is no strategy. Nobody has stopped to think “we need to be at 95 percent for fraud capacity at all times, no matter what.” They leave it up to the discretion of people who are not actually accountable for the business. That is wrong! Maybe you have an inexpensive web server that manages your brand new e-commerce that supports 90 percent of your business but because it was not expensive, your IT manager complains that it goes down all the time and that he is going to have it replaced in two weeks. Two weeks for e-commerce? That is why we said that the most important strategy is to have one. It is not just my idea, it is ISO 27001 standard for information security, which instructs that you get a strategy in place. I have always recommended that organizations should first have the right people that are actually accountable for that decision and have them make the decisions for a change. You can delegate responsibility but you cannot delegate accountability.
Networking and Telecommunication in Auditing, Internal Control
ICT has a very important role to play in internal control because auditors control access to information which IT does too. Auditors also control how information is used and how transactions are processed. Over the years, automated control organizes business functions and that has reduced loss of money. So, IT is able to put controls in place but then again, depending on how well it is managed, there might also be some vulnerability. In detecting and managing fraud, you need asset combination. I have often asked people in my classes if their organizations are committed to preventing, detecting and minimizing fraud. And they say yes, absolutely! I ask them to show me a policy that says: “Our organization does not want fraud, and this is what we are going to do to stop it.” They have no fraud policy! Shockingly, a policy is nothing more than a statement of management that states the way things are done within an organization. If you say that controlling fraud is a good objective, where is the policy that not only says it is wrong but also says here is who should be looking for it; here is who should be investigating it and here is what we do if we find it. A fraud policy is where senior managers say “not only am I going to accept responsibility, but I will accept accountability for something going wrong.”
Legal and Ethical Issues Facing IT Auditors
The legal and ethical issues are similar for IT auditors as they are for financial auditors. As an IT auditor, it is possible that you would be dealing with irregular or illegal acts. Towards that end, you have to be careful whom you release information to – there is always tendency for you to be exposed to sensitive information about an organization that you have to protect. As you are investigating issues, you have to be sure that you do not breach privacy laws. For instance, there are laws now that protect account information for people who have bank accounts. Imagine if during the course of an IT audit, the auditor compromised your account, and your account number and access code was made public. That auditor could be in for a lot of legal hassle.
