Creating a sustainable SOX process requires
organization-wide or entity level efforts. As with
any other entity level effort, the organizational
culture will be impacted by a set of new
requirements. Conversely, this means that the
culture will influence how to efficiently fulfill
the new requirements of the SOX initiative.
Discussions on how to achieve efficient
sustainability begin with a discussion about each
Bank’s unique organizational culture.
For our purpose, culture may be
described as a combination of several core elements;
1.
Uniquely talented employees with unique
perspectives,
2.
Ethical and moral predispositions and
preferences of those same persons
3.
Team-orientation versus self-orientation
4.
Bank’s technology-focus (pro or con)
5.
Behavior and policy flexibility within
mandated guidelines
6.
Willingness and adaptability to change as
established by Senior Management
7.
Organizational pride and cohesiveness
Based on this mix of variables, as well as others, any Bank
culture requires a custom-tailored approach to
compliance within mandated guidelines. Both COSO
(Committee of Sponsoring Organizations) and the
PCAOB (Public Company Accounting Oversight Board)
recognize that internal control systems are unique
to the organization. They are also subject to change
as Regulations are “tweaked”, reemphasized, and new
Regulations are introduced.
Approaching SOX sustainability requires a critical assessment
of the (existing) organizational culture, its
capabilities and limitations. This assessment should
be conducted in the context of existing capabilities
and talents, and external needs and support.
Included may be internal strengths such as Internal
Audit and external needs such as outsourced
Information Technology, web-hosting services or
business continuity planning.
Cultural impediments to sustainability must be addressed to
limit distractions and to focus the organization on
its new implementation challenges. SOX represents a
business process evolution challenge.
Cultural capabilities and adaptability must be emphasized and
the intrinsic functions challenged to identify and
assimilate new structures and tools that will help
the organization achieve sustainability more
effectively, and with less recurring effort. It is a
natural tendency of people to seek shortcuts to
achieve their goals and rewards. This predisposition
should be tapped to identify efficient pathways
toward more effective operations that are inherently
compliant. Achieving effective sustainability
requires entity-level optimization and enforcement
of policies and protocols across the culture, across
divisions and departments. Optimizing for
entity-wide compliance must overcome departmental
sub-optimization.
Control audits and practices will evolve over the
next few years, notably in the Information
Technology audit and business application areas.
Requirements for cultural evolution of the entity
including training and education should be a
strategic element of a tailored sustainability
plan.
Our Team
Our team is
comprised of experienced executives, managers and
consultants who will assist your banking
organization in the development, implementation and
execution of comprehensive risk management and
compliance strategies. From the initial passage of
Sarbanes-Oxley in 2002, Visage has provided
solutions to a client base ranging from private,
entrepreneurial companies to large multinationals.
