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Anti-corruption accounting controls sampling represents a critical challenge for internal audit and internal control teams. Organizations must now deal with massive transaction volumes, increasingly stringent regulatory documentation requirements (France's Sapin 2, UK Bribery Act, US FCPA), and constantly evolving fraud typologies, all with limited human resources.
Facing these growing challenges, manual controls show their limitations and require adapting practices toward automation. These new approaches directly transform sampling methods: they can either complicate them or, conversely, simplify them considerably through solutions like Eye2Scan.
Let's analyze regulatory requirements concerning sampling, using the French AFA (Agence Française Anticorruption) recommendations under Sapin 2 as a reference framework—recognized as the strictest anti-corruption guidance globally—and discover how to better address them.
Regulatory Requirements for Internal Controls Sampling
Anti-corruption laws such as France's Sapin 2, the UK Bribery Act, and the US FCPA establish precise standards for accounting controls sampling. The French AFA provides the most detailed and stringent guidance on these requirements, structured around three main axes.
1- Documentation and Traceability
Sampling must be entirely documented and traceable. Each applied rule (thresholds, frequencies, selection criteria) must be formalized and justified. This documentation enables control authorities to verify the consistency and relevance of the adopted methodology.
2- Consistency with Risk Analysis
Sampling must derive directly from the organization's risk analysis. There exists a mandatory link between the corruption risk mapping and retained sampling criteria. This approach ensures that the most sensitive areas receive attention proportionate to their risk level for the organization.
3- Control Zones Distinction
Regulatory frameworks distinguish critical zones, which require exhaustive control, from sample-able zones. This distinction guides the methodological choice between sampling control and systematic verification.
4- Three Control Levels Framework
The French AFA structures this distinction according to three control levels, each having specific sampling requirements:
Level 1 Controls - Preventive
Automated controls of certain operations, authorizations, and four-eyes principle applied before the operation is executed. Sampling can be used to test the effectiveness of these preventive controls.
Level 2 Controls - Regular verification
Regular control of correct execution of anti-corruption accounting controls after the operation, based on a representative sample of records. This level constitutes the core of permanent sampling strategy.
Level 3 Controls - Systemic analysis
Control of correct execution and effectiveness of level 1 and 2 controls, analysis of resource allocation, and assessment of controls relevance against the risk mapping. For example, critical analysis of accounting control procedures considering updates to the corruption risk mapping.
This three-level structuring directly guides sampling choices: level 1 and 3 controls can be subject to occasional sampling, while level 2 constitutes the core of your permanent sampling strategy. Understanding this hierarchy allows optimizing resources while respecting regulatory expectations.
How Automated Accounting and Operational Controls Facilitate Recommended Sampling
Automated anti-corruption controls transform the sampling approach by providing auditors and internal controllers with concrete elements to optimize their practices.
High-Risk Areas Identification
Automated controls continuously analyze all accounting and operational flows, automatically identifying sensitive vendors, suspicious manual entries, and exposed expense accounts. This systematic identification of real risks allows defining sampling populations targeted on genuine high-risk areas.
Sampling Criteria Enrichment
Automated controls generate Key Risk Indicators (KRIs) and alerts that directly feed sampling selection criteria. Auditors and internal controllers thus have objective elements to stratify their samples according to detected criticality levels.
Sampling Follow-up Facilitation
An automated controls tool like Eye2Scan enables real-time monitoring of selected elements, their processing, and resolution. Complete traceability is complemented by validation questionnaires and the possibility of integrating supporting documents, facilitating compliance with regulatory requirements (AFA, UKBA, FCPA).
Exhaustive Control or Sampling? Regulatory Recommendations and Real Risk Assessment
When advising our clients on their sampling practices, we apply regulatory recommendations by considering the nature of controls to be performed and their organizational risk mapping.
Our library of pre-programmed controls automatically generates anomaly lists and enables determining optimal sampling criteria: real risk assessment, relevant population definition, threshold and frequency calibration.
Here are some typical client cases:
Sensitive Expense Accounts (Entertainment, Gifts, Travel)
Eye2Scan automatically analyzes accounts 6258 (receptions), 6238 (promotional gifts), and 6251 (travel and transportation) to detect operations deviating from usual patterns. Given typically high volumes, statistical sampling on pre-identified elements allows effective coverage.
Vendors Domiciled in High-Risk Countries
Our solution automatically identifies vendors domiciled in countries presenting high corruption risk according to international indices such as Transparency International. This precise identification allows constituting targeted samples on these particular partners rather than controlling the entire vendor database.
Segregation of Duties (SoD) Violations
Our solution exhaustively controls all user authorization combinations in SAP to detect segregation of duties conflicts. In this specific case, no sampling is recommended: each potential violation must be analyzed as it creates immediate major risk.
Vendor Banking Details Modifications
Eye2Scan systematically monitors all banking details modifications in the SAP vendor master. These operations being strongly correlated with fraud attempts, we suggest each modification be subject to exhaustive control with supporting documentation validation and formal authorization.
High-Risk Invoices Identified by Multi-Dimensional Controls
Eye2Scan uses multi-dimensional controls that intersect anomalies identified by multiple controls. One of these controls automatically identifies high-risk invoices presenting multiple anomalies such as: invoices without purchase orders, unusual payment delays, three-way match breaks. These controls' precision allows isolating very high criticality anomalies, thus justifying continuous exhaustive control without sampling recourse.
Sampling Management with Eye2Scan
Eye2Scan offers functionalities specifically designed to support internal audit and internal control teams in their sampling practices compliant with regulatory requirements.
Controls Alignment with Risk Mapping
In Eye2Scan, each automated control can be directly linked to risks identified in your mapping. This connection ensures consistency between your risk analysis and sampling practices, thus meeting fundamental regulatory requirements.
Customized Identification Thresholds Configuration
The solution allows determining thresholds for anomaly identification in your controls according to your organizational context. These customizable thresholds automatically orient your sample constitution toward zones of highest criticality.
Sampling Criteria Documentation
Sampling criteria are customizable and automatically recorded in Eye2Scan. This functionality guarantees traceability and justification of your methodological choices, essential elements during regulatory controls.
Random or Manual Sampling According to Your Needs
Eye2Scan offers flexibility to choose between random sampling or manual selection of events to control. In both cases, the solution automatically calculates your sample's coverage rate relative to the total event population, thus allowing statistical justification of your approach's representativeness.
Complete Controlled Transactions Traceability
Each event controlled via Eye2Scan is entirely traced: comments, supporting documents, corrective actions taken. This exhaustive traceability constitutes a solid foundation for demonstrating your anti-corruption system's effectiveness.
Eye2Scan: Regulatory Compliance and Operational Performance
Eye2Scan adoption transforms your control practices by providing operational ease, expanded coverage, internal resource optimization, and reinforced regulatory compliance.
By implementing Eye2Scan for your anti-corruption controls, you have all necessary tools to effectively mitigate your risks and serenely approach potential future regulatory audits.
Sampling returns to what it should be: a risk management tool, not an administrative burden.
➡️Contact us to see Eye2Scan in action.
