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4    |   Enterprise Risk Management   |  Compliance Risk Management: Applying the COSO ERM Framework




        differences, even if the scope of application of a C&E program   Figure 1.1  The COSO 2013 Framework
        may differ (i.e., limited to bribery and corruption in some
        jurisdictions and broader application in others). The common
        thread across these various guides is a shared appreciation
        for the elements on which this COSO guide is based.

        The relationship between compliance, internal
        control, and enterprise risk management
        COSO defines internal control in Internal Control – Integrated
        Framework (2013) and Enterprise Risk Management –
        Integrating with Strategy and Performance (2017) as follows:

           A process, effected by an entity’s board of directors,
           management, and other personnel, designed
           to provide reasonable assurance regarding the
           achievement of objectives relating
           to operations, reporting, and compliance.        Source: COSO Internal Control Framework ©2013
                                                            COSO defines ERM as follows:
        As this definition clearly points out, internal control is not
        solely about accounting and financial matters. Compliance   The culture, capabilities, and practices, integrated
        with laws and regulations is one of the three fundamental   with strategy-setting and its performance, that
        objectives of an organization’s system of internal controls.   organizations rely on to manage risk in creating,
        The following five components of internal control support all   preserving, and realizing value.
        three categories of objectives:
                                                            The COSO ERM framework, like the internal control
        •  Control environment                              framework, comprises five interrelated components:

        •  Risk assessment
                                                                 Governance & culture
             COSO Infographic with Principles
        •  Control activities
                                                                 Strategy & objective-setting
        •  Information and communication
                                                                 Performance
        •  Monitoring activities
                                                                 Review and revision
        The relationships between the three objectives, five
        components, and the entity are depicted in figure 1.1:    Information, communication, and reporting



          Figure 1.2  Risk Management Components
                                             ENTERPRISE RISK MANAGEMENT





             MISSION, VISION      STRATEGY           BUSINESS         IMPLEMENTATION          ENHANCED
             & CORE VALUES       DEVELOPMENT         OBJECTIVE        & PERFORMANCE           VALUE
                                                    FORMULATION





                Governance         Strategy &         Performance      Review             Information,
                & Culture          Objective-Setting                   & Revision         Communication,
                                                                                          & Reporting
           1.  Exercises Board Risk    6.  Analyzes Business  10.  Identifies Risk   15.  Assesses Substantial  18.  Leverages Information
            Source: COSO Enterprise Risk Management—Integrating with Strategy and Performance
                Oversight          Context        11.  Assesses Severity         Change         and Technology
           2.  Establishes Operating  7.  Defines Risk Appetite         of Risk  16.  Reviews Risk and  19.  Communicates Risk
                Structures    8.  Evaluates Alternative  12.  Prioritizes Risks         Performance         Information
           3.  Defines Desired Culture         Strategies  13.  Implements Risk  17.  Pursues improvement    20.  Reports on Risk,
                                                                                            Culture, and
           4.  Demonstrates   9.  Formulates Business         Responses         in Enterprise Risk
                Commitment         Objectives     14.  Develops Portfolio          Management         Performance
                to Core Values                           View
           5.  Attracts, Develops,
           c oso . or g
                and Retains Capable
                Individuals
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