Top risks and controls for Audit

From the Doorstep International risk register, curated by Ahmer Nehal. Last updated 17 Oct 2026.

The Audit register lists 38 key risks and 195 best-practice controls across 6 units: Compliance Audit, Financial Audit, Fraud Audit, Information Technology Audit, Internal Audit, Operational Audit. Use it to identify risks, benchmark your existing controls or start a risk and control self-assessment (RCSA).

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An integral part of the banking sector, the audit function is responsible for confirming that a bank's activities adhere to applicable rules and regulations and that its financial statements are reliable and accurate.

The banking sector has grown more sophisticated recently, and new dangers are constantly arising. As a result, performing risk assessments has grown to be an essential part of the audit function at banks.

Auditor risk assessments allow them to discover potential risks and weaknesses in a bank's operations, allowing them to focus their auditing efforts and offer useful management advice on how to reduce those risks.

As a result, banks are better able to uphold their good name, safeguard the assets of their clients, and meet regulatory requirements.

Compliance Audit: key risks and controls

Accountable for making sure the bank abides by all relevant rules and regulations. Usually, the compliance audit team checks the bank's policies and practices to make sure they comply with legal standards.

Risk	What can go wrong	Best-practice controls
Complex Regulations	Commercial banks are subject to a wide range of regulations, which can be complex and challenging to navigate. Compliance auditors must have a deep understanding of these regulations to ensure that the bank is operating in compliance with them.	To make sure compliance auditors are knowledgeable about the most recent rules and procedures, give them ongoing training. Create and maintain internal controls, including as rules, procedures, testing and monitoring programmes, and reporting methods, to ensure compliance with legislation. Engage an independent audit company to conduct routine audits to verify regulatory compliance. Appoint compliance officers to manage the application of rules and compliance monitoring. Keep an eye out for regulatory notices and updates, and evaluate how they might affect your bank's operations. To identify potential compliance risks and create suitable procedures to manage them, conduct periodic risk assessments. Create a document management system to guarantee that all applicable laws are duly documented and that the required records are accessible for audits and regulatory examinations. To identify compliance risks and find potential violations, use monitoring technologies like automated compliance monitoring systems. Engage legal advice to help you negotiate regulatory requirements and to provide guidance on difficult regulatory matters. Keep thorough records of all compliance-related activities, including as audits, risk analyses, training, and other related activities.
Cultural and Organizational Challenges	Compliance auditors may face challenges related to the bank's culture and organizational structure. Some employees may not fully understand the importance of compliance, or may be resistant to change. Compliance auditors must work closely with the bank's management team to address these challenges and ensure that the bank's compliance program is effective.	Create and conduct training programmes to inform all staff about the value of compliance and how it affects business operations at the bank. Key rules, processes, and guidelines that employees must follow should be covered in the training. Implement a communication plan to keep staff members informed about compliance-related issues. In order to give staff with pertinent information, the plan can involve frequent email updates, bulletin boards, and other communication channels. Make sure the bank's executive staff is dedicated to compliance and serves as a role model for the rest of the company. Conduct routine compliance audits to spot potential non-compliance areas and put corrective measures in place to deal with any problems. This will make sure that both staff members and the bank's compliance programme continue to operate effectively. Encourage staff members to comment on the compliance programme of the bank and suggest areas for improvement. Changes to the compliance programme that address any issues or concerns can be made using this input. Employ performance rewards for staff members who show a strong dedication to compliance. Rewards for finishing compliance training or disclosing potential compliance problems could fall under this category. Hold staff members accountable for noncompliance and make sure the proper disciplinary measures are taken when required. Employees will be deterred from acting in a non-compliant manner by this, helping to underline the significance of compliance. Create a compliance culture that is supported by a strong commitment to moral conduct and regulatory compliance throughout the organisation.
Data Management	Banks collect and store a large amount of data, which must be properly managed to ensure compliance with regulations. Compliance auditors must have a thorough understanding of the data management systems used by the bank and the regulations that govern data management.	Create and put into effect a thorough data management policy that describes the protocols and requirements for data collecting, archiving, and processing. The policy ought to be based on applicable laws and industry standards. Create a data governance structure for managing data that includes roles and duties, policies, procedures, and standards. By using this paradigm, all systems' data should be accurate, complete, and consistent. To safeguard data from unauthorised access, modification, or destruction, put robust data security measures in place, such as encryption, access controls, and data backups. To ensure that data is retained for the necessary time and then disposed of securely, establish criteria for data retention and disposal. This should cover guidelines and practices for data deletion and archiving. Conduct routine compliance audits to see how well the bank complies with data management laws. A evaluation of data management policies, practices, and controls should be part of these audits. Implementing policies and procedures for gathering, storing, and processing sensitive data and personally identifiable information (PII) will ensure compliance with data privacy laws. Employees should get training on data management policies and practices, as well as any applicable laws and industry best practices. This will make it easier to guarantee that staff members comprehend the value of data administration and abide by the bank's data management standards. To guarantee that data management policies and procedures are being followed, implement a compliance monitoring programme. Regular evaluations of the systems, controls, and processes used for data management should be part of this programme.
Human Resource Management	Compliance audit is heavily dependent on human resources. Getting the right person with appropriate qualifications, experience and technical knowledge of the compliance standards is a challenge.	Create a thorough job description for the compliance auditor position that details the skills, background, and technological expertise needed for the position. Verify the credentials and experience of potential compliance auditors by conducting in-depth background checks and reference checks. To guarantee that compliance auditors stay current with evolving compliance standards, offer sufficient training and chances for continued professional development. To assure continuation of the compliance audit function in the event of unanticipated personnel changes, establish a systematic succession planning approach. Consider automating some compliance audit processes with technology to lighten the load on human auditors and improve the efficiency and accuracy of the audit process. Engage outside experts with knowledge of compliance auditing to offer more assistance and knowledge as required. To make sure compliance auditors are carrying out their responsibilities successfully and consistently, as well as to pinpoint areas for improvement, establish a peer review procedure. Establish a compliance culture throughout the company by stressing the value of compliance and enlisting the help of all staff members in upholding all relevant laws and standards. To ensure consistency and accuracy, create and maintain thorough documentation of the compliance audit process, including protocols, checklists, and other tools. Review and update the compliance audit programme frequently to make sure it's current and working to fulfil the organization's compliance requirements. Make sure the compliance auditor's job description outlines the skills, background, and technological expertise necessary for the position. This will make it easier for you to find qualified candidates and determine whether they are a good fit for the position. Once the ideal individual has been found, it is crucial to continue training them so they are knowledgeable about the most recent compliance requirements, laws, and best practices. This will lessen the possibility of insufficiently knowledgeable individuals conducting compliance audits. Compliance audits will be conducted consistently and in accordance with the necessary standards if clear policies and procedures are established. This will lessen the possibility of mistakes and discrepancies during the auditing process. In the process of conducting a compliance audit, leveraging technology can assist in lowering the reliance on human resources. The audit process can be streamlined and the need for manual intervention decreased by implementing tools like automated testing and monitoring systems. To lessen the risk of losing important individuals, the compliance audit function should develop a succession plan. In the event of an unanticipated leave or absence, a succession plan will help to guarantee that there is a pool of competent and trained people who can step in and carry out the work.
Internal Controls	Compliance auditors must review and test the bank's internal controls to ensure that they are operating effectively. This can be a time-consuming process, and auditors must be thorough to ensure that all areas of the bank's operations are covered.	Create a thorough internal control structure that addresses every aspect of the bank's activities. As a result, auditors won't have to review and test every facet of the bank's operations but may instead concentrate their attention on key risk areas. Establish a risk-based strategy to internal control testing that gives priority to the most important risk areas. This will make it easier for auditors to concentrate their efforts on the areas most likely to lead to non-compliance. Create a thorough internal control structure that addresses every aspect of the bank's activities. As a result, auditors won't have to review and test every facet of the bank's operations but may instead concentrate their attention on key risk areas. Establish a risk-based strategy to internal control testing that gives priority to the most important risk areas. This will make it easier for auditors to concentrate their efforts on the areas most likely to lead to non-compliance. To make the process of internal control testing more efficient, use automated techniques and technologies. To test controls, for instance, automated testing scripts can be created that are both more accurate and efficient than manual testing. To increase the effectiveness and efficiency of audits, educate auditors on the use of automated tools and technology. This will facilitate quicker and more accurate risk area identification by auditors. Utilise a continuous monitoring strategy for internal control testing, where controls are examined continuously as opposed to simply once a year during audits. As a result, auditors will be able to see problems earlier and stop them from developing into serious compliance violations. To find and fix gaps in the bank's internal control architecture, conduct routine internal control evaluations. This will lessen the time and effort needed by auditors to examine and test controls and help to ensure that they are running effectively and efficiently. Implement a comprehensive compliance programme that gives all staff members regular training and awareness-raising opportunities. Employee accountability and understanding of the value of internal controls in upholding compliance will be improved as a result.
IT Infrastructure	With advancements in technology, auditors must continuously update themselves with the latest technologies, tools and techniques for carrying out audits. However, in some banks, the IT infrastructure may not be well equipped to handle such new technological advancements, which becomes a challenge for compliance audit.	Regularly evaluate the IT infrastructure to find any holes or places that need to be improved. By doing this, you can make sure that the infrastructure is current and capable of incorporating new technology breakthroughs. To keep auditors up to date with the newest technologies, tools, and procedures, offer regular training and development programmes. This will enable them to quickly adopt to new technologies and apply them wisely while conducting audits. To guarantee that IT infrastructure is appropriately managed, monitored, and maintained, establish an IT governance framework with policies, processes, and controls. By doing this, you can make sure that the infrastructure is always current and capable of supporting new technological developments. Spend money on IT infrastructure to make sure it can handle future technological developments. This can entail updating the network infrastructure, software, and hardware. To identify areas for improvement, share knowledge, and cooperate on the implementation of new technologies that can assist the audit process, encourage cooperation and communication between the compliance audit team and the IT department.
Rapidly Changing Regulations	Regulations in the banking industry are constantly changing, and compliance auditors must stay up-to-date with these changes. This requires a continuous learning process and a high level of flexibility to adapt to new regulations.	Establish a thorough training programme that covers new laws, updates, and modifications to the banking sector for compliance auditors. To make sure that auditors are keeping up with new regulatory requirements, this should include regular reviews and evaluations. Create a method for regulatory monitoring that enables the compliance team to stay up to date with any new regulatory requirements, updates, or modifications. Subscribing to regulatory news feeds, attending industry conferences, and receiving regular updates from regulatory bodies are all ways to achieve this. To ensure that the compliance standards and processes are understood, all compliance-related processes should be documented. This will facilitate the implementation of any required process modifications and guarantee the consistency of compliance initiatives. Conduct routine risk analyses to find and evaluate the potential effects of regulatory changes. This will make it easier to recognise and prioritise any adjustments that must be made to compliance processes and procedures. Automate compliance procedures as much as you can to minimise the possibility of human error and guarantee the consistency of your compliance efforts. Automation of regulatory reporting and monitoring is part of this, and it can be used to spot compliance issues before they become serious ones.

Financial Audit: key risks and controls

Accountable for checking that the bank's financial statements are correct, comprehensive, and compliant with all applicable accounting standards. The bank's financial records, transactions, and reports are normally examined by the financial audit team.

Risk	What can go wrong	Best-practice controls
Complexity of financial products	Commercial banks offer a range of financial products, such as loans, mortgages, credit cards, and investments. These products can be complex, and the financial statements may contain a significant amount of data, making it difficult for auditors to ensure accuracy.	To reduce errors or fraudulent activities, make sure that distinct individuals handle different stages of financial products, such as loan origination, underwriting, approval, and servicing. Inaccurate financial statements can be avoided by regular training of workers, particularly those in the finance department, on proper accounting procedures, regulatory changes, and risk management. To identify errors or anomalies and enhance accuracy, conduct independent evaluations or audits of financial products and financial statements. Make certain that all financial transactions are accurately recorded with supporting documentation, such as contracts, agreements, and pertinent financial information. To spot odd patterns, shady activity, or mistakes in financial transactions or statements, use automated controls and data analytics software. To find and fix errors, reconcile financial data from various sources, like bank statements and the general ledger. To promote transparency and accountability in financial reporting, establish effective governance and oversight systems, such as oversight committees, risk management frameworks, and regulatory compliance. Create and maintain effective internal control systems, including as procedures for authorising transactions, reconciling financial records, and routinely monitoring and reviewing transactions. Make that auditors and other third-party service providers are competent, independent, and uphold ethical and professional standards by conducting due diligence on them. Maintain ongoing monitoring, evaluation, and improvement of internal systems, processes, and controls to accommodate shifting business conditions and new threats.
Cybersecurity risk	As banks become more digital, the risk of cybersecurity breaches increases. Auditors must ensure that the bank has appropriate cybersecurity measures in place and that they are effective in protecting the bank's assets and data.	To find vulnerabilities and threats, conduct routine security audits and risk assessments. To safeguard sensitive data, use strong access controls like multi-factor authentication. Make sure every employee receives regular cybersecurity training and is informed about the dangers of online banking. Create security rules and processes that are in line with industry best practices, and enforce them. To defend against cyberattacks, install firewalls, intrusion detection/prevention systems, and anti-virus/anti-malware software. Update software and systems often to close any security gaps and fix known vulnerabilities. To ensure that the bank can react successfully in the case of a cyberattack, develop and test incident response plans. In order to spot potential security incidents and act immediately, monitor network traffic and logs. To find flaws in the bank's systems and applications, do frequent penetration testing and vulnerability scanning. Protect sensitive data both in transit and at rest by using encryption. Form alliances with trade groups and other organisations to exchange best practices and keep up with new dangers. Use data loss prevention (DLP) technology to stop sensitive data from being stolen or lost. To make sure all vendors have the right cybersecurity protections in place, conduct routine third-party vendor risk assessments. In order to ensure that the bank can quickly recover from a cyberattack, you should have a disaster recovery strategy that includes backups of crucial data and systems. Make sure that consumer data is not being sold or traded illicitly by keeping an eye out on the dark web for any potential data breaches.
Data quality and availability	Auditors must rely on data provided by the bank to perform their audits. If the data is incomplete, inaccurate, or not available, it can be challenging to conduct an accurate audit.	Data Quality Management: Implement robust data quality controls and processes to ensure the completeness, accuracy, and availability of data used by auditors. This includes regular data validation, reconciliation, and data integrity checks. Data Governance Framework: Establish a comprehensive data governance framework that defines roles, responsibilities, and processes for managing data throughout its lifecycle. This framework should include data ownership, data stewardship, data classification, and data access controls to ensure the reliability and trustworthiness of data.
Fraud risk	Commercial banks are at risk of fraud, including internal fraud by employees and external fraud by customers or other third parties. Auditors must be aware of these risks and ensure that appropriate controls are in place to mitigate them.	Segregation of duties: Implementing a clear segregation of duties is the most effective control measure to mitigate fraud risks in commercial banks. This involves dividing critical tasks and responsibilities among different employees to create a system of checks and balances. For example, the employee responsible for initiating a financial transaction should not have access to approve or reconcile that transaction. Regular monitoring and review: Conducting regular monitoring and review processes helps detect fraudulent activities and identify any weaknesses in control systems. This includes periodic audits, reconciliations, and independent reviews of financial transactions and records. By promptly identifying and addressing any irregularities, banks can minimize the impact of fraud and prevent its recurrence.
Regulatory compliance	Commercial banks are highly regulated, and auditors must ensure that the bank is in compliance with all relevant laws and regulations. This requires a thorough understanding of the regulatory environment, including changes in laws and regulations, and staying up to date with the latest changes.	Regulatory Compliance Monitoring: Implementing a robust system to monitor and track regulatory requirements and changes, including maintaining an updated repository of relevant laws and regulations. This control helps ensure that the bank is aware of and compliant with all applicable regulations. Regular Internal Audits: Conducting periodic internal audits to assess the bank's compliance with laws and regulations. This control involves reviewing policies, procedures, and processes, identifying gaps or areas of non-compliance, and taking corrective actions to address any issues identified.
Time pressure	Auditors must complete their work within a limited timeframe, which can be challenging in a complex and dynamic environment like a commercial bank.	Effective Time Management: Implementing robust time management practices and tools to optimize the allocation of resources and prioritize audit activities can significantly enhance auditors' efficiency and ensure timely completion of their work. Streamlined Audit Planning: Developing a comprehensive and well-structured audit plan tailored to the specific needs and risks of a commercial bank can help auditors efficiently allocate their time and resources, reducing the likelihood of delays and ensuring timely completion of audits.

Fraud Audit: key risks and controls

Accountable for identifying and looking into cases of theft, fraud, and other financial crimes. To make sure that fraud risks are identified and addressed, the unit closely collaborates with the internal audit and compliance functions.

Risk	What can go wrong	Best-practice controls
Complexity of Banking Operations	Commercial banks have complex operations, and identifying fraudulent transactions can be difficult, especially in large banks with a vast customer base.	To identify shady transactions and money laundering operations, implement effective anti-money laundering (AML) rules and processes. Utilise cutting-edge fraud detection technologies and software to spot odd patterns or transactions. Conduct routine evaluations of the risk of fraud and put in place the proper procedures to manage the risks found. To encourage customers and staff to report suspected fraudulent activity, create a thorough fraud reporting structure. To reduce the danger of insider fraud, thoroughly background-check both employees and outside service suppliers. To secure customer accounts, use two-factor authentication and strict password policies. Review and update the bank's internal controls frequently to spot any potential system weaknesses. To improve staff members' knowledge of fraud risks and defences, conduct frequent training sessions and awareness campaigns. Track consumer transactions and alert authorities to any questionable activity. Share information about fraud trends and patterns with law enforcement organisations and other financial institutions.
Insider Threats	Fraud can also be committed by insiders, such as employees or managers, who have access to sensitive information and can manipulate transactions. Detecting insider fraud can be challenging as they may have a deeper understanding of the bank's operations and systems.	It is possible to ensure that no one individual has total control over any transaction or activity by assigning various tasks to several personnel. As insider fraud would require the cooperation of numerous employees, this can aid in its prevention. Strict access controls can be implemented to restrict each employee's access to certain systems and sensitive data. By restricting the number of employees who have access to sensitive information, this can lower the risk of fraud. All prospective employees should undergo extensive background checks before being hired in order to find out if they have ever been involved in fraud or other illegal conduct. Any suspect activity can be found with regular observation of employee behaviour, especially that of employees with access to sensitive information. Regular internal audits can assist in finding any anomalies or discrepancies that might be signs of insider fraud. Regular training on fraud prevention and detection for employees can assist increase awareness of the problem and lessen the possibility of insider fraud. Insider fraud can be thwarted and quickly detected by having a clear, widely communicated policy that encourages staff to report any suspicious conduct or concerns about fraud. The potential impact on the bank and its clients can be reduced by having an incident response plan in place, which can assist guarantee that any suspected fraud instances are swiftly investigated and resolved.
Lack of Adequate Resources	Fraud audits require significant resources, including skilled personnel, technology, and time. Limited resources can hamper the effectiveness of fraud audits in commercial banks.	Implement a robust risk assessment process: Conducting a thorough risk assessment helps identify areas prone to fraud, enabling banks to allocate their limited resources effectively. By focusing on high-risk areas, banks can optimize the allocation of skilled personnel, technology, and time to mitigate fraud risks effectively. Strengthen internal controls and segregation of duties: Implementing strong internal controls, such as segregation of duties, ensures that no single individual has complete control over a critical process. This reduces the risk of collusion and increases the chances of detecting fraudulent activities. By segregating duties and establishing clear lines of responsibility, banks can optimize the utilization of skilled personnel while minimizing the risk of fraud.
Large Volume of Transactions	Commercial banks handle a large volume of transactions daily, making it challenging to identify fraudulent transactions within the vast amount of data.	Implement advanced analytics and machine learning algorithms: By leveraging advanced analytics and machine learning, banks can develop sophisticated fraud detection models that can effectively analyze large volumes of transactional data in real-time. These models can identify patterns and anomalies associated with fraudulent transactions, enabling early detection and prevention. Implement robust transaction monitoring systems: Banks should deploy comprehensive transaction monitoring systems capable of analyzing transactional data in real-time. These systems can employ rule-based engines, anomaly detection techniques, and behavior profiling to identify potentially fraudulent transactions. Regular monitoring and alerts allow for timely investigation and mitigation of fraudulent activities.
Legal and Regulatory Compliance	Fraud audits in commercial banks must comply with various legal and regulatory requirements, such as the Bank Secrecy Act (BSA), Anti-Money Laundering (AML), and the USA PATRIOT Act. Non-compliance can result in severe penalties.	Implementing a robust internal control framework: Establishing strong internal controls, such as segregation of duties, regular review and monitoring of financial transactions, and implementing effective fraud detection and prevention measures, can significantly mitigate the risk of non-compliance with legal and regulatory requirements. This control ensures that proper checks and balances are in place to identify and address any potential issues promptly. Conducting regular compliance audits: Regular audits specifically focused on compliance with legal and regulatory requirements, including the Bank Secrecy Act (BSA), Anti-Money Laundering (AML), and the USA PATRIOT Act, are essential to ensure adherence to the prescribed guidelines.
Sophisticated Fraud Techniques	Fraudsters use sophisticated techniques to conceal their activities, such as identity theft, phishing, and social engineering, making it difficult to detect fraudulent transactions.	Multi-factor authentication (MFA): Implementing MFA can significantly enhance security by requiring multiple forms of authentication, such as passwords, biometrics, or security tokens, making it harder for fraudsters to gain unauthorized access. Employee awareness and training: Educating employees about the risks associated with fraud and providing training on identifying phishing emails, social engineering tactics, and suspicious activities can help create a vigilant workforce that can detect and report fraudulent transactions promptly.

Information Technology Audit: key risks and controls

Responsible for checking that the bank's information technology systems, including networks, hardware, and software, are safe, dependable, and adhere to all relevant rules and regulations.

Risk	What can go wrong	Best-practice controls
Complexity of the IT environment	Commercial banks typically have complex IT systems that are often distributed across multiple locations, making it difficult to conduct a comprehensive audit.	Create a thorough IT architecture that gives a clear picture of the bank's IT systems and how they interact. To prevent unauthorised access to the IT systems, implement efficient access controls and user management procedures. Conduct regular penetration tests and vulnerability assessments to find and fix any potential security flaws. To guarantee that any security problems are quickly detected, contained, and resolved, establish a strong incident management system. To guarantee that modifications to the IT systems are duly authorised, tested, and implemented, create efficient change management procedures. To guarantee adherence to internal policy and statutory obligations, conduct routine IT system audits. Make sure IT employees are properly educated and trained on the newest security dangers and best practices. In order to ensure that the bank's activities can continue in the case of an IT system failure, implement disaster recovery and business continuity plans. Centralise IT systems and infrastructure to make the auditing process simpler and less difficult. Create and keep an IT inventory of all the hardware, software, and apps being used by the company.
Data protection	Commercial banks hold sensitive customer data that needs to be protected during the IT audit process.	Strong access controls should be put in place to restrict access to sensitive client data during the IT audit process. Role-based access controls, password regulations, and multi-factor authentication are all examples of what is meant by this. Both in transit and at rest, sensitive client data should be encrypted. Data backups, log files, and any other data transported over networks are all encrypted in this. During the IT audit process, the risk of unauthorised access or disclosure can be decreased by masking and anonymizing sensitive customer data. Make sure that sensitive client data is transferred between systems and locations in an encrypted fashion. Secure file transfer protocols and encrypted email are examples of this. As part of the IT audit process, routinely monitor and audit access to sensitive customer data. This entails checking access records and doing recurring security audits. During the IT audit process, educate staff members on the value of securing sensitive customer data. This includes instruction on data processing, secure password management, and security best practices. Create and maintain an incident response strategy with protocols for handling any security lapses or incidents that may occur throughout the IT audit process. Make certain that the vendors taking part in the IT audit process adhere to the same security guidelines and measures as the bank. This entails carrying out frequent security audits and due diligence on third-party vendors.
Limited access to information	The IT department of a commercial bank may not always be willing to provide unrestricted access to systems and data, which can hinder the effectiveness of the IT audit.	Clear and well-defined access control policies: Implementing comprehensive access control policies that clearly outline roles, responsibilities, and levels of access for different users within the IT department. This ensures that only authorized personnel have access to systems and data, reducing the risk of unauthorized access or misuse. Regular and independent IT audits: Conducting regular IT audits by an independent internal or external party to assess the effectiveness of controls and identify any gaps or deficiencies in access management. This helps ensure compliance with policies and provides an objective evaluation of the IT department's practices.
Regulatory compliance	Commercial banks operate in a highly regulated environment, and IT audits need to ensure that the bank's IT systems are compliant with all relevant regulations.	Documentation and Policy Compliance: Establishing comprehensive documentation and policies that outline regulatory requirements and ensuring strict adherence to them is a crucial control. This includes regularly reviewing and updating policies to align with evolving regulations. Regular IT Audits: Conducting periodic IT audits to assess the compliance of the bank's IT systems with relevant regulations is vital. These audits should encompass comprehensive assessments of IT controls, systems, processes, and data security to identify and address any compliance gaps.
Risk management	Banks are exposed to various risks such as cybersecurity, fraud, and operational risks, which must be considered during an IT audit.	Risk assessment and management: Conducting a comprehensive risk assessment to identify and prioritize potential risks such as cybersecurity threats, fraud, and operational risks. Implementing effective risk management strategies, including controls and mitigation measures, to minimize the likelihood and impact of these risks. Robust cybersecurity controls: Implementing strong cybersecurity controls to protect against cyber threats, including the use of firewalls, intrusion detection systems, encryption, multi-factor authentication, and regular security testing and monitoring. This includes ensuring that systems and networks are regularly patched and updated to address vulnerabilities.
Staff expertise	IT auditors need to have a deep understanding of both banking operations and IT systems to effectively assess the risks and controls in place.	Comprehensive Training and Education Programs: Implementing thorough training and education programs for IT auditors to enhance their knowledge and understanding of both banking operations and IT systems is crucial. This ensures auditors have the necessary expertise to assess risks and controls effectively. Cross-Functional Collaboration: Foster collaboration between the IT and banking operations teams to facilitate knowledge sharing and understanding. Encourage regular communication, joint meetings, and cross-training opportunities to bridge the gap between the two domains. This collaboration enables IT auditors to gain a deeper understanding of banking operations and IT systems, leading to more effective risk assessments.
Time constraints	IT audits in commercial banks are often conducted within tight timelines, making it challenging to conduct a comprehensive audit.	Effective Planning and Scheduling: Implementing a well-defined and thorough planning process for IT audits is crucial. This includes setting realistic timelines, identifying priorities, and allocating resources appropriately to ensure comprehensive audits can be conducted within the given time constraints. Automation and Standardization: Leveraging technology solutions and standardized audit processes can significantly improve efficiency and effectiveness. Utilizing audit management software, data analytics tools, and predefined audit templates can streamline audit procedures, reduce manual effort, and enhance the ability to conduct comprehensive audits within tight timelines.

Internal Audit: key risks and controls

Is in charge of examining and evaluating the internal controls, risk management procedures, and financial reporting of the bank. The internal audit team is also in charge of locating weak points and recommending enhancements to management.

Risk	What can go wrong	Best-practice controls
Complex Operations	Commercial banks have complex operations, which can make it difficult to identify and evaluate risks. Internal auditors must have a good understanding of the bank's operations and be able to assess the risks associated with each area of the business.	Create and implement a thorough framework for risk management that is continually reviewed and improved to ensure its effectiveness. To make sure internal auditors have a solid awareness of the operations of the bank and the risks connected with each area of business, conduct frequent training and development sessions for them. Establish rules and practices for risk management that are precise and well-defined that are regularly followed throughout the bank. Employ a team of independent risk managers that can offer an unbiased assessment of the operations and risk profile of the bank. Implement the proper technology and systems to support risk management operations like risk monitoring, reporting, and evaluation. To identify, assess, and manage risks across the bank, comprehensive risk assessments should be conducted on a regular basis. Create a successful internal auditing programme that regularly examines the bank's operations and risk management procedures. Make sure the bank's board of directors and senior management are routinely updated on the bank's risk profile and risk management procedures. Implement the proper internal controls to reduce the risks that have been identified. Establish an effective reporting and escalation process for identified risks to ensure that they are addressed in a timely and appropriate manner.
Conflicts of Interest	Internal auditors must remain independent and objective in their work, which can be challenging in a commercial bank where there may be conflicts of interest. For example, auditors may be asked to evaluate the work of their colleagues or managers, which can create tensions and challenges.	Create an internal auditing code of ethics that explains the requirements and expectations for behaviour. Train internal auditors on the importance of independence and objectivity, and provide ongoing education and training opportunities to reinforce these principles. To allow internal auditors to voice any concerns about potential conflicts of interest, clearly define reporting lines and channels. To lessen familiarity and potential conflicts of interest, implement rotation procedures that mandate internal auditors to periodically rotate to other parts of the bank. Provide internal auditors with audit teams that are separate from the departments of the bank they previously worked in. To guarantee that audit plans and reports are impartial and independent, create a procedure for assessing and approving them. To find and resolve any potential conflicts of interest, conduct routine internal evaluations of the internal audit function. To guarantee independence and objectivity, make sure the internal audit function reports to a senior-level, independent executive, such as the board of directors or audit committee. Establish precise policies and procedures for handling conflicts of interest, as well as a method for disclosing potential conflicts and, when required, removing internal auditors from particular assignments. Make sure internal auditors are informed of the procedure for reporting any worries about potential conflicts of interest by creating a whistleblower policy and making sure they are aware of it.
Data Analysis	Banks generate a vast amount of data, and internal auditors must be able to analyze and interpret this data to identify potential risks and control weaknesses. This requires strong analytical skills and the ability to work with complex data sets.	Implementing automated data analytics tools: Automation can enhance the efficiency and effectiveness of data analysis by processing large volumes of data quickly and accurately, allowing internal auditors to identify potential risks and control weaknesses more efficiently. Strengthening data governance and management: Establishing robust data governance frameworks and data management processes ensures the availability, accuracy, integrity, and confidentiality of data. This creates a solid foundation for effective data analysis and interpretation by internal auditors.
Human Resource Management	Internal auditors must also be able to evaluate the performance of bank employees. This can be challenging when they have to interact with individuals who may not be receptive to criticism or feedback.	Clear communication channels and expectations: Establishing clear and open lines of communication between internal auditors and bank employees is crucial. This includes clearly defining the objectives and expectations of the auditing process and providing employees with a platform to express their concerns or feedback. Training and awareness programs: Implement training programs to educate bank employees about the importance of internal auditing and its role in enhancing overall performance. This can help foster a culture of receptiveness to criticism and feedback, enabling employees to understand the value and benefits of constructive evaluations.
IT Security	As banks increasingly rely on technology to conduct their operations, IT security has become a critical area of focus for internal auditors. They must have a good understanding of the bank's IT systems and be able to assess the risks associated with them.	Regular Vulnerability Assessments and Penetration Testing: Conducting regular vulnerability assessments and penetration testing helps identify weaknesses and vulnerabilities in the bank's IT systems. This allows for proactive remediation of potential security risks and helps ensure the systems are robust against attacks. Strong Access Controls and User Management: Implementing strict access controls and user management practices helps prevent unauthorized access to sensitive data and systems. This includes employing strong authentication methods, such as multi-factor authentication, and regularly reviewing and updating user privileges to ensure they align with job roles and responsibilities.
Regulatory Compliance	Banks operate in a highly regulated environment, and internal auditors must ensure that the bank complies with all relevant laws and regulations. This requires a deep understanding of regulatory requirements and the ability to stay up-to-date with changes in regulations.	Robust Regulatory Compliance Program: Implementing a comprehensive regulatory compliance program that includes policies, procedures, and controls designed to ensure compliance with all relevant laws and regulations. This program should encompass regular monitoring, assessment, and reporting of compliance activities. Continuous Education and Training: Provide ongoing training and educational programs to internal auditors to enhance their understanding of regulatory requirements. This should include training on the latest changes in regulations, industry best practices, and emerging risks to stay up-to-date with the evolving regulatory landscape.

Operational Audit: key risks and controls

Accountable for assessing the effectiveness and efficiency of the operational procedures at the bank. In order to find opportunities for improvement, the operational audit team often evaluates the bank's processes, systems, and procedures.

Risk	What can go wrong	Best-practice controls
Complexity of Banking Operations	Commercial banks have complex and diversified operations that involve various departments and processes. Conducting operational audits in such an environment requires auditors to have a comprehensive understanding of the bank's operations and processes, including risk management, credit analysis, compliance, and regulatory requirements.	To make sure that auditors are aware of what has to be audited, clearly define the objectives and scope of the audit. Employ auditors that are equipped to comprehend the intricate operations and procedures used by the bank. Create a thorough audit plan that takes into account risk assessment, a review of pertinent laws and regulations, and the identification of critical control points. To maintain consistency and effectiveness, develop standardised methods for performing operational audits. Check the audit program's effectiveness at identifying important control points and hazards. To keep audit procedures current and efficient, evaluate and update them frequently. For the purpose of demonstrating adherence to internal policies and regulatory requirements, it is necessary to document all audit procedures and conclusions. Including management in the audit process will help to ensure that audit recommendations are properly considered and that necessary action is done. Establish efficient reporting and communication processes to inform management of audit conclusions and suggestions. Establish a system for tracking audit results and suggestions so that the proper steps are implemented as soon as possible.
Data and Technology Challenges	Commercial banks store vast amounts of data and use complex technology systems to manage their operations. Auditors must have the necessary expertise to access and analyze this data, understand the technology systems, and identify any potential issues or risks associated with the bank's technology and data management processes.	Robust Information Security Controls: Implementing strong information security controls, such as firewalls, intrusion detection systems, encryption, access controls, and regular security assessments, can help protect the vast amounts of data stored by commercial banks from unauthorized access, breaches, or cyberattacks. This control ensures the confidentiality, integrity, and availability of sensitive information. Expertise and Training: Providing auditors with the necessary expertise and training in technology systems and data analysis is crucial to effectively identify and assess potential risks and issues associated with a bank's technology and data management processes. Continuous professional development programs and certifications can enhance auditors' knowledge and skills in this area.
Regulatory Compliance	Commercial banks operate under strict regulatory requirements and guidelines, which can pose a challenge for auditors. Auditors need to ensure that the bank's operations comply with all applicable regulations and guidelines, such as the Federal Reserve Board, Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation.	Robust Compliance Management System (CMS): Implementing a comprehensive CMS that includes policies, procedures, and controls designed to ensure compliance with regulatory requirements is essential. This includes establishing internal controls, monitoring processes, conducting regular audits, and maintaining proper documentation. Independent Internal Audit Function: Having an independent internal audit function is crucial to assess and evaluate the bank's operations and compliance with regulatory requirements. This function should perform regular and thorough audits to identify any potential non-compliance issues, assess the effectiveness of existing controls, and recommend improvements.
Resistance to Change	Commercial banks have established practices and procedures that may not align with recommended audit practices or may resist changing their current processes. Auditors may face resistance from bank staff, which can make it challenging to implement recommendations or changes suggested during the audit.	Establish a robust regulatory framework: Implementing strong regulatory standards and guidelines that align with recommended audit practices can help ensure that commercial banks adhere to effective audit procedures. This includes clearly defining audit requirements, providing detailed audit methodologies, and enforcing compliance through regular audits and inspections. Promote a culture of compliance and transparency: Foster an organizational culture within commercial banks that values compliance with audit practices and encourages transparency. This can be achieved through comprehensive training programs, awareness campaigns, and clear communication channels to educate bank staff about the importance of audits and their role in ensuring effective risk management and governance.
Staffing and Resource Constraints	Conducting operational audits in a commercial bank can require a significant amount of resources, including personnel, time, and financial resources. The availability of resources can be a challenge for audit teams, especially when conducting audits in large banks or during times of economic uncertainty.	Resource allocation and planning: Effective resource allocation and planning is crucial to mitigate the risk associated with conducting operational audits in a commercial bank. This includes allocating personnel, time, and financial resources appropriately, considering the scale and complexity of the audits. Adequate planning helps ensure that resources are utilized efficiently and effectively. Prioritization and risk-based approach: Adopting a prioritization and risk-based approach to operational audits allows audit teams to focus their efforts on areas that pose the highest risks to the bank. By identifying and assessing the key risks, audit teams can allocate resources where they are most needed, thereby optimizing resource utilization.
Time Constraints	Commercial banks operate in a fast-paced environment, and auditors must complete their work within tight deadlines. This can be a challenge, especially when conducting comprehensive audits that involve multiple departments and processes.	Automation and Workflow Management: Implementing automated systems and workflow management tools can greatly enhance the efficiency of auditing processes in commercial banks. These tools help streamline the audit workflow, reduce manual effort, and ensure timely completion of audits by tracking tasks, deadlines, and progress. Risk-based Audit Planning: Adopting a risk-based audit planning approach allows auditors to prioritize their efforts based on the criticality and complexity of different departments and processes. By focusing on high-risk areas first, auditors can allocate their time and resources more effectively, ensuring that the most important audits are completed within the tight deadlines.

This register is a starting point for risk identification and benchmarking against international practice. Adapt the risks and controls to your institution's size, products, jurisdiction and regulatory requirements.

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Frequently asked questions

What are the key risks in Audit?

The main risk areas covered are Compliance Audit, Financial Audit, Fraud Audit, Information Technology Audit, Internal Audit, Operational Audit. Each unit lists its key risks with a short explanation and the best-practice controls that mitigate them.

How do I use this register for a risk and control self-assessment?

Select the risks that apply to your units, map the listed controls to the controls you actually operate, rate inherent risk and control effectiveness, then agree actions for gaps. The free RCSA workbook on this page has the columns ready.

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