We are back with another series of Adventures in Compliance podcasts. This week I am exploring stories from The Casebook of Sherlock Holmes. In this week’s second offering, I consider The Problem of Thor Bridge. From this story we take the Holmes utterance “We must look for consistency. Where there is want of it, we must suspect deception”. This informs our discussion on monitoring controls.

1. How do you determine that want of consistency? Monitoring controls is one key.
2. Consider the fifth and final Objective from the COSO 2013 Internal Control Framework is Monitoring Activitiesas a guide.
3. Further consider Principles 16 & 17 of the COSO Framework.
4. Monitoring Activities should bring together your entire compliance program and give you a sense of whether it is running properly.
5. Both ongoing monitoring and auditing are tools the CCO and compliance practitioner should use in support of this objective.
6. The most important item to note is that all the controls need to be sustainable.