IIA Australia - Managing Internal Audit Function Risks
IIA Australia - Managing Internal Audit Function Risks
White Paper
Managing Internal
Audit Function
Risks
2024
This resource was prepared after the ‘Global Internal Audit Standards’ were published in 2024
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Financial › Budget Setting – Incomplete or inaccurate data used to estimate required financial resources
during internal audit planning.
› Budget Limits – Exceeding the Internal Audit Function budget approved by the audit committee.
Compliance › Standards – Nonconformance with the ‘Global Internal Audit Standards’.
› Laws and Regulations – Non-compliance with requirements such as:
› Australian Federal/ State / Territory internal audit related requirements for the public sector.
› Australian Prudential Regulation Authority (APRA) Prudential Standards applicable to internal
audit such as CPS510 ‘Governance’ and CPS234 ‘Information Security’.
› ASX Corporate Governance Principles and Recommendations.
Risks Cascaded from Other Parts of the Organisation circumstances it would be necessary for the Internal Audit
Function to ensure the presence of process and procedure
Another area to consider is when business units devolve
documentation to clarify organisational expectations and
common controls to other business units. They may vary in
behaviours. Some considerations are included below for
nature and complexity, and sometimes are not applicable
reference:
to the Internal Audit Function due to their nature, but
they require careful consideration. In most, if not all,
Area Considerations
Expense Depending on nature of usage (for example high frequency of travel) and maturity of expense
Management and related controls within the organisation, the chief audit executive might consider additional
Corporate credit controls to further safeguard the reputation of the Internal Audit Function and its staff.
cards
Safeguarding Chief audit executives would be responsible for their own physical space where the Internal Audit
of Assets Function is located and facilities used by the Internal Audit Function. This includes but is not
and Access limited to reviewing access to physical workspaces, computers, audit management system, online
Management collaboration workspaces (e.g. SharePoint or Google Drive) or non-audit related information such
as employee details, compensation, etc.
Health and Safety Several health and safety related controls may be cascaded down to the rest of the organisation.
The Internal Audit Function is not exempt from those requirements. Training and appointment of
first aiders, fire wardens, review of work environment, and periodic communication of health and
safety obligations are common controls to address health and safety risks. In addition, there may
be considerations specific to the Internal Audit Function such as working from home and overall
employee wellness such as work-life balance, response to organisational health surveys, etc.
Corporate There may be organisation wide initiatives stemming form the organisation’s strategy which
Initiatives may present risks to the Internal Audit Function. These initiatives may include mergers and
acquisitions, divestitures, cost restructuring and other strategies which may impact internal audit
team composition, resources and the internal audit plan delivery.
How the IIA Standards Help in Managing Internal Audit following:
Risks
› Risk of not identifying or managing potential biases
The ‘Global Internal Audit Standards’ state they “guide when performing audit work – addressed through
the worldwide professional practice of internal auditing Standard 2.1 ‘Individual Objectivity’.
and serve as a basis for evaluating and elevating the
› Risk of self-review / performing management
quality of the internal audit function”. While not explicit,
responsibilities – addressed through Standard 2.1
the Standards provide a variety of responses to potential
‘Individual Objectivity’.
risks that may face Internal Audit Functions. Consider the
Step 1 – Identify
Action Considerations
Identify all potential › Start from the purpose, definition and mandate of the Internal Audit Function (Internal
risks the Internal Audit Audit Charter).
Function might be › Review the strategy, objectives and goals of your organisation and list internal audit
exposed to processes within the audit lifecycle that directly or indirectly contribute to it.
› Ask the question – ‘what should go right’?
› Ask the question - ‘what could go wrong’?
› Consider workshopping risks in the identified processes (internal audit planning,
engagement execution, audit committee reporting, etc) internally, with the risk team
and compliance team, external industry and refer to industry literature.
› Use your organisation’s risk assessment methodology (if available) to consider all
risks and categorise risks identified through this process.
Step 3 – Prioritise
Action Considerations
Rank risks based on their › Once the list is finalised, prioritise areas requiring attention.
significance so that a
› Test your understanding of risks with Line 2 assurance activities or subject matter
risk that would cause experts.
little issue to the Internal
Audit Function is given a Outcome – Clarity on which risks will need to be addressed for example all risks equal to
low priority and above ‘Medium’.
Step 4 – Manage
Action Considerations
Respond to the risk by › Be open to accept insignificant risks.
accepting, avoiding,
› Identify and develop controls to manage risks or consider alternative strategies to
managing or sharing risk address risk such as accept, avoid or share risks.
› Controls can be described in a similar way to how recommendations or improvements
are developed during an internal audit engagement:
› Who is best placed to execute the control (e.g. capacity / capability)?
› When is the best time for the control execution (preventive / detective)?
› What is the best control (manual review / automated configured workflow, etc)?
› Where is the best evidence of the control (e.g. checklist sign-off)?
› How is the control managing the risk?
For example: The Chief audit executive reviews and approves an audit file in the audit
management system prior to issuing the internal audit report to confirm audit evidence is
sufficient and appropriate to support the audit results.
Outcome – All significant risks and controls mitigating them are identified. Where controls
are absent or ineffective, Specific / Measurable / Attainable / Relevant / Time-based
(SMART) action plans are in place to address the significant risks.
Appendix 1 – Illustrates how significant risks and controls effectively. Consider asking for annual confirmation of
within the internal audit lifecycle can be managed and control effectiveness.
monitored over time.
› Take control issues seriously to continually improve
and learn from past experience.
Critical Success Factors
› Evaluate cost versus benefit of risk responses. Unless
Some factors that are likely to maximise the value derived
absolutely necessary, avoid over-controlling risks
from managing Internal Audit Function risks may be:
and burdening the internal audit team with excessive
› Like any process, Tone at the Top from the chief audit procedures or processes.
executive is critical. Chief audit executives need to
promote the value of actively managing Internal Considerations for Smaller Internal Audit Functions
Audit Function risks and participate in brainstorming
Even smaller Internal Audit Functions need to take steps to
sessions.
manage their own risks. Risks specific to smaller functions
› Involving the whole internal audit team in the include:
brainstorming process and get their input as the
› Constrained budgets impacting their ability to acquire
Internal Audit Function risk register is built. Engaging
specialised skills, get trained on and deploy data
the team in this process helps to build awareness as
analytics, and provide extensive coverage of the risk
well as support effective risk management.
universe or audit universe.
› Limiting the number of risks included in the risk
› Difficulties recruiting and retaining staff as growth
register helps to direct focus and right-size effort. The
opportunities may be limited and larger Internal Audit
number of risks will vary based on the size, operating
Functions elsewhere may offer better compensation.
model and nature of Internal Audit Function activities.
› Challenges with engagement supervision, in
› Sufficiently resource the risk management function
particular for functions with a solo internal auditor,
with capable staff.
and maintaining an effective quality assurance
› Make control owners aware of their responsibilities and improvement program (in particular, getting an
and the expected result of operating a control external quality assessment).
from relevant, reliable approve audit documentation such as risk to the relevancy, reliability and
and sufficiently analysed and control matrix (RACM), engagement sufficiency of the audit procedures
information. This could lead to work program, testing work papers etc to performed to reach the conclusions
inaccurate assurances or the confirm: reached in the internal audit report.
erroneous inference of control › The Internal Audit Function audit
methodology was correctly applied
environment effectiveness
and result in loss of trust and › Documentation supports the
engagement objectives and
confidence in the Internal conclusions reached
Function.
9
Process Key Risks Control Control Type Monitoring Methodologies
P3. Hiring R3. Internal Audit Function C3. Prior to onboarding a resource, Chief Preventive M4. Periodic Self-Assessment:
and Co- staff or internal audit service Audit Executive (or delegate) performs a Independent review of conflicts in
sourcing providers are not or do not Conflicts of Interest assessment to confirm the conflict of interest register to
appear to be independent. that there are no, in actual or appearance confirm identified conflicts have
This could negatively impact of, impropriety with the relevant resource. been sufficiently and appropriately
integrity, reliability and This could be because resource has assessed.
credibility of internal audit previously worked with the management
reports. or has first degree familial relationship with
key individuals in the management. If any
instances of conflicts are identified and
the resource has been accepted, sufficient
and appropriate independence safeguards
have been identified and implemented (for
example temporarily barring the resource
Function Risks
10
Managing Internal Audit
Function Risks
Bibliography and References This White Paper also draws from the superseded
document:
Bibliography
The Institute of Internal Auditors, 2009. Practice Advisory
ASX Corporate Governance Council, 2019. Corporate 2120-2, Managing the Risk of the Internal Audit Activity.
Governance Principles and Recommendations, 4th Edition.
Purpose of White Papers
[Online]
Available at: https://www.asx.com.au/documents/asx- A White Paper is a report authored and peer reviewed
by experienced practitioners to provide guidance on a
compliance/cgc-principles-and-recommendations-fourth-
particular subject related to governance, risk management
edn.pdf or control. It seeks to inform readers about an issue and
Australian Prudential Regulation Authority, 2019. Prudential present ideas and options on how it might be managed. It
does not necessarily represent the position or philosophy
Standard CPS 234 Information Security. [Online]
of the Institute of Internal Auditors–Global and the Institute
Available at: https://www.apra.gov.au/sites/default/files/
of Internal Auditors–Australia.
cps_234_july_2019_for_public_release.pdf
Author’s Biography
Australian Prudential Regulation Authority, 2019. Prudential
This White Paper written by:
Standard CPS 510 Governance. [Online]
Available at: https://www.apra.gov.au/sites/default/ Farah George Araj PFIIA, CIA, CRMA, QIAL, CPA, CFE
files/draft_prudential_standard_cps_510_governance_ George is an experienced internal audit leader who has
actively managed internal audit risks in various chief
march_2019_v1_0.pdf
audit executive roles. He has served as a councillor on
Department of Finance (Australia), 2014. Commonwealth the IIA-Australia Western Australia and New South Wales
Risk Management Policy. [Online] Chapters. George was previously a member of the IIA
Global International Internal Auditing Standards Board.
Available at: http://www.finance.gov.au/comcover/risk-
management/ Umair Danka CIA, CRMA, CA, FCCA, CPA, CISA
Umair Danka is a seasoned financial services internal
International Internal Auditing Standards Board, 2024. auditor with over 15 years of experience. He has excelled
Global Internal Audit Standards. [Online] in assessing and enhancing internal controls, risk
Available at: https://www.theiia.org/globalassets/site/ management processes, and compliance frameworks
within leading financial institutions. Umair’s expertise
standards/globalinternalauditstandards_2024january9_
spans banking, insurance, and investment management.
printable.pdf
This White Paper edited by:
International Organization for Standardization, 2018.
Michael Parkinson PFIIA, CIA, CRMA, CISA, CRISC
ISO 31000:2018 Risk management - Guidelines, Geneva:
International Organization for Standardization. Andrew Cox MBA, MEC, GradDipSc, GradCertPA,
DipBusAdmin, DipPubAdmin, AssDipAcctg, CertSQM, PFIIA,
NSW Government, 2020. Internal Audit and Risk CIA, CISA, CFE, CGAP, CSQA, MACS Snr, MRMIA
Management Policy for the General Government Sector.
[Online]
Available at: https://www.treasury.nsw.gov.au/documents/
tpp20-08-internal-audit-and-risk-management-policy-
general-government-sector
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