When the IS auditor identifies a lack of segregation of duties

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Chinmay Kulkarni has asked people on LinkedIn a question that appears to be from the ISACA Certified Information Systems Auditor (CISA) exam. He posted (I have included the current poll results, with 941 voting):

CISA Question 3

As an IS auditor, what is the FIRST step you will take upon identifying lack of segregation of duties [“SOD”] within the organization?

Document as audit finding 18%

Implement SODs 7%

Review Compensating Controls 46%

Review Access Controls 30%

I am not a CISA, although I could have “grandfathered” into it when ISACA first set up the CISA certification.

One of my problems with these exams is that I always question the question, and frequently think the available answers are wrong. (I was able to pass both the UK’s Chartered Accountancy and the US CPA exams.)

I have a problem with the available answers to this question.

1. Document as an audit finding

The auditor has “identified a lack of segregation of duties,” but:

  • Has the auditor confirmed the facts with management?
  • Does the auditor understand whether it matters? Where is the risk? Even if there is a deficiency, does the risk justify corrective action? If so, there is no “finding”.
  • Does management already know? Have they assessed the risk and believe it is acceptable, given the cost, etc.?
  • Are there other controls…

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