Establishment IT Controls for Sarbanes-Oxley Compliance

Enacted in 2002 to restore investor confidence in the public markets and enhance corporate governance, the Sarbanes-Oxley (SOX) Act stipulates that companies establish and maintain internal control over financial reporting and assess the effectiveness of those controls annually. To carry out the mandates specified by SOX, Control Objectives for Information and Related Technology (COBIT) was established as a blueprint for IT risk management activities. COBIT maps IT processes to the components set forth by the Committee of the Sponsoring Organizations (COSO), the general framework recommended by the Public Company Accounting Oversight Board (PCAOB) to companies striving to achieve SOX compliance.

Basic best practices for implementing the COBIT framework include:

  • Automating the Log Management and Intelligence (LMI) process
  • Deploying LMI in a distributed environment
  • Ensuring data integrity
  • Establishing regular compliance reporting capabilities
  • Performing ongoing user monitoring

It is the fiduciary responsibility of management to protect corporate assets against misuse, theft and downtime. Critical infrastructure data in the form of log files from corporate firewalls, VPN concentrators, web proxies, IDS systems, email servers, operating systems, enterprise applications and backup systems provide critical insight into the use of corporate assets, risks and IT performance. However, these logs are often not readily available or accessible when corporations need them most – during compliance audits or when responding to Legal, Human Resources and other business requests. Achieving compliance requires you to be able, in real-time, to access, search through and organize such data quickly and cost-effectively.

Today, tens of thousands of log data messages are produced by enterprise systems, applications and network devices every second. In most Fortune 1000 enterprises, these log messages add up to terabytes of data per month. At these rates, it is not humanly possible to extract from logs the necessary information using homegrown scripts. For example, to satisfy SOX auditors, you must not only ensure that appropriate IT controls are in place, you must also provide evidence of functioning controls and the documented results of testing procedures. This could take days using scripts – a luxury and expense that you can’t afford.