Client Objectives and Challenges
Compliance was now an obstacle to sales. The bank needed audit-quality evidence to prove its controls, yet the way it was collecting and reporting on evidence had nearly precluded its ability to do so:
Metadata Evidence Collection: The compliance team manually compiled audit evidence using Excel, without any central repository for control documentation.
An Incomplete History of Audits: A previous audit by a CPA firm lasted 14 months and ended with many outstanding exceptions since the evidence varied between reviewers.
Lack of Visibility into Cloud Services: There was no monitoring of cloud-hosted banking workloads, and therefore any control drift remained unnoticed.
Ongoing Control Shortcomings: Change management controls were missing, logical access reviews were inadequate, and there was no risk program for key third-party integrations.