Preparing Servers for Sarbanes Oxley Section 404 Testing and Auditing

 

The Sarbanes Oxley act calls for the testing and auditing of  controls to ensure that financial reports are accurately reported and that controls are in place to prevent and detect fraud.  Every publicly held company must become compliant with Sarbanes Oxley and must withstand audits and testing of their controls and processes that fall under Section 404 of the Sarbanes Oxley act.  Most of these audits are concerned with documentation and formal approval of processes and changes.  There are however many that deal with the security of the servers that hold sensitive corporate financial data.  In your section 404 audit you will be required to demonstrate that your servers and processes are secure and that fraud detection exists.  Below are some tips that will help you prepare for Sarbanes Oxley audits.  Additional information on Sarbanes Oxley and Section 404 can be found at http://www.sec.gov Section 404 specific information is available at the Sarbanes Oxley Section 404 page.

 

Sarbanes Oxley Section 404 Audit Tips

  • Isolate servers that handle financial transactions and reporting.  This focuses on any finance or production or sales systems.  Any system that is involved in generating corporate numbers or to which tampering could result in fraud or incorrect financial reporting.

  • Keep all systems up to date with the latest service packs and hot fixes.

  • Be prepared to demonstrate that Anti-Virus software is in place and up to date.

  • Be prepared to show logs of nightly backups of data affected by Sarbanes Oxley

  • Create written policies that are related to changes to the operating system or software riding on the operating system.  Keep documentation of any changes to these systems especially reasons for changes and the approvals obtained.

  • Harden these systems as if they were internet systems.  This includes applying ALL service packs and hot fixes to both operating systems and applications.  Document these updates and be prepared to demonstrate patch levels.  Review any registry or group policy related security tweaks and apply them.  This would include getting rid of null sessions, and any information that can be obtained by anonymous users.

  • Change NTFS permissions on all directories to get rid of the default everyone full control permission.  Be prepared to demonstrate that non administrators are prevented from accessing file systems.

  • If remote access to systems is a factor secure and audit these connections and be prepared to show that you audit.

  • Ensure that logging is enabled and of a size that is useful.  Create a formal policy of the review of all logs that affect the systems you've isolated.  Be prepared to show your Sarbanes Oxley auditors that your logs are reviewed.  Try to create a deliverable product based on these reviews that can be given to your auditors.  The addition of centralized logging will go along way in demonstrating to Sarbanes Oxley auditors that you can actually retrieve useful data from various server logs.

  • Have a defined password policy and enforce it for all applications.  Suggestions for this policy would include changing passwords every 60-90 days, enforcing complex passwords and using strict account lockout policies.  Use Windows Group Policies where possible to ensure all servers adhere to your password policy.

  • Conduct an audit of all user accounts.  Verify that users with admin rights need them and prepare a report explaining a reason for each account.  Get rid of generic account and ensure that only accounts exist for users and services currently employed.  Be prepared to show information such as last logon date from a random sample of users.  Create an ongoing policy of periodic review of accounts and be prepared to demonstrate such a policy exists.

  • Expect to screen print or provide reports of proof of processes or controls under Sarbanes Oxley.  Keep this in mind as you change processes or tighten your server in anticipation of a Sarbanes Oxley audit.

The Sarbanes Oxley Section 404 Pre-Audit tips should make any visit with a Sarbanes Oxley auditing firm a much easier time.  If the above isn't in place you will likely end up implementing or at a minimum documenting mitigating controls you have in place. 

 

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