ACCA/CAT

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（b） FIVE typical causes of internal control failure and the performance of Global-bank

There are several possible causes of internal control failure. The UK Turnbull report （in paragraph 22） gives examples of causes of failure but this list is not exhaustive.

Poor judgement in decision-making. Internal control failures can sometimes arise from individual decisions being made based on inadequate information provision or by inexperienced staff. Human error can cause failures although a well-designed internal control environment can help control this to a certain extent. Control processes being deliberately circumvented by employees and others. It is very difficult to completely prevent deliberate circumvention， especially if an employee has a particular reason （in his or her opinion）to do so，such as the belief that higher bonuses will be earned.

Management overriding controls，presumably in the belief that the controls put in place are inconvenient or inappropriate and should not apply to them.

The occurrence of unforeseeable circumstances is the final cause referred to in the Turnbull Report. Control systems are designed to cope with a given range of variables and when an event happens outwith that range，the system may be unable to cope.

[Tutorial note：accept other，equivalent explanations or references to other governance codes if valid. Study texts make reference obliquely rather than as a ‘list’ to learn. The above points can be expressed in different ways.]

In assessing the performance of Global-bank，there is evidence of a widespread failure of internal control systems and a weak internal control environment. It is possible to highlight five specific failures.

- Poor judgement by Mr Mineta as he breached trading rules （exceeding his trading limit and trading in unauthorised instruments）.

- Poor judgement and management over-rides by Mr Evora and an inability or unwillingness to enforce trading rules at the Philos office.

- Mr Evora＊s withholding of compliance information. He seems to view the Philos office as his own personal fiefdom in which head office directives on trading rules and internal controls do not apply.

- Failure of the head office system to insist on full compliance by acting upon failure by Mr Evora to return the required compliance information.

- Mrs Keefer/head office’s attitude does not inspire confidence that the incident could not recur. She has failed to enforce controls throughout the company including at its remote offices. Her denial that the board had any responsibility for the loss would only apply if they had ensured that all internal controls had applied throughout the company including at the Philos office. This was not the case.

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