Barclaycard UK - Sarbanes Oxley Compliance Project

Section 404 of the Sarbanes Oxley Act continues to place a major burden on those companies that fall within its remit. In order to meet their compliance requirements within the timeframe allocated we were asked by the client to deliver a comprehensive programme to document, evaluate and test their system of internal controls.

ZR Consultants took over the project management of the Sarbanes Oxley Project and put together a comprehensive plan to deliver the project within timescales.

ZR Consultants were responsible for managing a team of consultants in order to deliver all documentation to set standards. Templates were devised by ZR Consultants using Word, Excel, Visio and SOX Express. The templates were tailored to suit the Barclaycard environment and were a huge success with both internal and external Audit.

ZR Consultants were responsible for both the IT and the Finance controls within the organisation and produced over 50 set of process documentation, all of which contained a Visio Process flow diagram, a risk/control matrix and a control description document. The 50 processes covered included Barclaycard UK, Barclaycard Germany, Barclaycard Spain, Juniper (US), Cluster Finance, Barclay Loan and First plus all of which operated in different cultures and locations and used different systems.

All the processes were walked through to ensure that they had been documented correctly. Following which all the controls were tested to ensure that they effectively mitigated the risks associated with them. Where it was found that controls did not mitigate the risk, remediation plans were put into place to either tighten the controls or to implement a new control. ZR Consultants were responsible for setting up a deficiency management committee to report on the progress of all remediation’s.

ZR Consultants were also responsible for the reviewing entity level controls and were asked to review the impairment process in order to ensure its compliance with current regulations (MIFID, Basel II).

ZR Consultants were responsible for liaising with Internal and External Audit (PWC) and were highly commended by PWC for the quality of their control proving. As a result of the assurance that PWC placed upon our work, PWC reduced their sample sizes.

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