Hacking Your SOX Off: Sarbanes Oxley, Fraud, and Fraudulent Financial Reporting (Hacking Illustrated Series InfoSec Tutorial Videos)
Hacking Your SOX Off: Sarbanes Oxley, Fraud, and Fraudulent Financial Reporting
I had to do a presentation for one of my MBA courses, and one of the topic
choices was the Sarbanes-Oxley act. I chose it because I thought I could relate
it to computer security, but as it turns out the connection is somewhat tenuous
as you will see if you watch the presentation. Below is a screencast of the
presentation, and below that a text version of my Power Point slides for easy
reference.
Sarbanes Oxley, Fraud, and Fraudulent Financial Reporting
Adrian Crenshaw
Disclaimer
IANAL
I Am Not A Lawyer
IANACPA
I Am Not A Certified Public Accountant
Why did I choose this topic?
I had to do if for class. :)
I do a lot of information security education from the technical side, so I
wanted to know what SOX means for a techie
I kept seeing folks referring to “SOX Compliance” in my security reading
So, what does SOX mean to a hacker
What is SOX
Sarbanes-Oxley is US legislation enacted on July 30, 2002
AKA: Public Company Accounting Reform and Investor Protection Act of 2002
SOX
Sarbox
CPA Employment Act :)
Put forth in part because of accounting scandals of corporations such as Enron,
Tyco International, Adelphia, Peregrine Systems and WorldCom that cost investors
billions of dollars
What is SOX
"To protect investors by improving the accuracy
and reliability of corporate disclosures made
pursuant to the security laws, and for other
purposes."1
Attempts to increase accountability
Applies only to publicly traded companies
Sections
1) Public Company Accounting Oversight Board (PCAOB)
2) Auditor Independence
3) Corporate Responsibility
4) Enhanced Financial Disclosures
5) Analyst Conflicts of Interest
6) Commission Resources and Authority
7) Studies and Reports
8) Corporate and Criminal Fraud Accountability
9) White Collar Crime Penalty Enhancement
10) Corporate Tax Returns
11) Corporate Fraud Accountability
Key Provisions
SOX Section 302: Internal control certifications
SOX Section 404: Assessment of internal control
SOX Section 802: Criminal penalties for violation of SOX
Information Security Triad
What is an Internal Control
SOX Section 302: Internal control certifications
Holds the Chief Executive Officer (CEO) and Chief Financial Officer (CFO)
personally responsible to certify that financial reports are accurate and
complete.
They must also assess and report on the effectiveness of internal controls
around financial reporting.
CEOs and CFOs now face the potential for criminal fraud liability.
Section 302 does not specifically list which internal controls must be assessed.
SOX Section 404: Assessment of internal control
The most contentious aspect of SOX
PCAOB standards require management to do the following:
Assess both the design and operating effectiveness of selected internal controls
related to significant accounts and relevant assertions, in the context of
material misstatement risks;
Understand the flow of transactions, including IT aspects, sufficient enough to
identify points at which a misstatement could arise;
Evaluate company-level controls, which correspond to the components of the COSO
framework;
Perform a fraud risk assessment;
Evaluate controls designed to prevent or detect fraud, including management
override of controls;
Evaluate controls over the period-end financial reporting process;
Scale the assessment based on the size and complexity of the company;
Rely on management's work based on factors such as competency, objectivity, and
risk;
Conclude on the adequacy of internal control over financial reporting.
SOX Section 802: Criminal penalties for violation of SOX
" Whoever knowingly alters, destroys, mutilates, conceals,
covers up, falsifies, or makes a false entry in any record,
document, or tangible object with the intent to impede,
obstruct, or influence the investigation or proper
administration of any matter within the jurisdiction of any
department or agency of the United States or any case filed
under title 11, or in relation to or contemplation of any such
matter or case, shall be fined under this title, imprisoned not
more than 20 years, or both. "
Also requires auditors to maintain accounting
documents and work papers for a minimum of five
years.
So, after all of that, what does SOX have to do with information security
Not a whole lot, it’s primarily concerned with accuracy in financial reports
InfoSec professionals may benefit from bigger budgets because the higher ups are
afraid of liability for inaccurate data (playing the Integrity angle)
However, InfoSec can help in the following ways:
Documentation, documentation, documentation
Control of access to financial records
Detection of modification
Preventions of data loss and contingent liabilities
Contingent liability
Liability for investor losses in stock price based on:
Disclosures that lessen consumer confidence
Security issues that effect reliability and safety
COBIT
Control Objectives for Information and related Technology
Security Policy
Security Standards
Access and Authentication
Network Security
Monitoring
Segregation of Duties
Physical Security
Criticism
Higher cost burden on US companies
Less IPOs take place on US stock exchange
Praise
Increased investor confidence
Financial restatements decreased significantly
Web References
The text of the law (PDF)
http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgidbname=107_cong_bills&docid=f:h3763enr.tst.pdf
SANS Institute - An Overview of Sarbanes-Oxley for the Information Security
Professional by Gregg Stults
http://www.sans.org/reading_room/whitepapers/legal/1426.php
Sarbanes Oxley for IT Security by Mark Rasch
http://www.securityfocus.com/columnists/322
Signing Statement of George W. Bush
http://www.whitehouse.gov/news/releases/2002/07/20020730.html
COBIT Site
http://www.isaca.org/cobit
SOX Wikipedia Entry
http://en.wikipedia.org/wiki/Sarbanes-Oxley_Act
Sarbanes-Oxley An Opportunity for Security Professionals
http://www.secureworks.com/research/newsletter/2005/03/
The Sarbanes-Oxley Act 2002
http://www.soxlaw.com/
Book References
Sarbanes - Oxley IT Compliance Using COBIT and Open Source Tools
Lahti, Christian; Peterson, Roderick
9781597490368
IT Governance : A Manager's Guide to Data Security and BS 7799/ISO 17799
Calder, Alan; Watkins, Steve
9780749444143
Business Guide to Information Security
Reuvid, Jonathan
9780749446420
Enterprise Information Systems Assurance and System Security : Managerial and
Technical Issues
Warkentin, Merrill; Vaughn, Rayford
9781591409137
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