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Compliance and Internal Audit · Controls · Hub

AI Agents for
Control Validation

Designed, documented and operating are three different claims, and most testing answers only the first two.

Key takeaways
  • Whether a control is designed, documented, or actually operated on every transaction are three separate claims, and only the third protects anything.
  • Whether a control can be bypassed is almost never tested, and it is where losses happen.
  • A control test examines items that went through the process, so it cannot see an item that never entered it.
  • A payment made outside the payment run, or a vendor created and paid the same day, is made of individually legitimate steps. The sequence is the signal.
  • Evidence preparation is retrieval and assembly rather than judgement, which is why automating it does not touch auditor independence.

AI agents for control validation test whether a control operated on every transaction in the period, look for the transactions that bypassed it entirely, and assemble audit evidence with its support attached. ChatFin tests for absence and sequence rather than only for correctness.

The gap in most control frameworks is not the design. It is that testing examines items which went through a process and confirms they were handled properly, which by construction cannot see the manual payment made outside the run or the approval given by the person who raised the request. ChatFin looks for what avoided the control.

Internal auditControl validationSegregation of dutiesAudit evidencePolicy complianceException identificationControlsAI agents for finance
01

Designed, documented and operating are three different claims

Control frameworks conflate three separate questions, and most control testing answers only the first two. Whether a control was designed sensibly, whether it is written down, and whether it actually operated on every transaction in the period are genuinely different things, and only the third protects anything.

ClaimHow it is usually evidencedWhat it proves
The control is designedA narrative or flowchartSomebody thought about it
The control is documentedA procedure documentIt is written down
The control operatedA sample of approvalsIt worked on those items
The control operated alwaysRarely tested at allNothing, it is assumed
The control cannot be bypassedAlmost never testedNothing

The bottom two rows are where losses happen and they are the two nobody evidences. ChatFin tests operation across the whole period and, more usefully, looks for the transactions that went around the control rather than through it.

In ChatFin

ChatFin tests whether a control operated on every transaction and looks for the ones that bypassed it, which is the question a sample of approvals cannot answer.

02

The interesting transactions are the ones that avoided the control

Control testing looks at items that went through a process and checks they were handled correctly. That design cannot see an item that never entered the process.

A payment made outside the payment run. Manual and urgent, and it skipped every check the run applies.
A journal posted directly to a subledger controlled account. Which the reconciliation then absorbs without anyone asking why it exists.
An invoice paid without a purchase order in a PO mandatory category. The policy says it cannot happen, and the policy is not the system.
An approval given by somebody who also raised the request. Segregation stated in a matrix and not enforced at the point of approval.
A vendor created and paid on the same day. Each step legitimate, the sequence is the signal.

Every one of those is a normal looking transaction. None of them appears in a sample of items that went through the control, because they did not. ChatFin tests for absence and sequence rather than only for correctness.

a boardroom of people watching a presenter at a whiteboard
A control test cannot see a transaction that never entered the process.
In ChatFin

ChatFin tests for absence and sequence, which is how a payment made outside the payment run or a vendor created and paid the same day becomes visible.

03

Evidence preparation is most of the cost of an audit

The expensive part of an external audit is rarely the auditor's thinking. It is finance assembling what the auditor asked for, in the format they asked for, twice, because the first version was not quite it.

RequestWhy it takes daysWhat removes the delay
A sample of fifty invoicesRetrieved one at a timeBulk retrieval by criteria
Support for a journalAttachments across systemsAssembled at posting
A reconciliation as at a dateRebuilt retrospectivelySnapshotted when prepared
Approval evidenceScreenshots from workflowExported as a record
An explanation of a movementWritten from scratchDrafted from the ledger

Every row is retrieval and assembly rather than judgement, which is why it is worth automating and why doing so does not reduce the auditor's independence at all. ChatFin assembles the requested population with its support attached and reports what it could not find, which is itself a finding.

In ChatFin

ChatFin assembles audit requests with the support attached and reports what it could not find, because a missing document is a finding rather than a gap in the pack.

04

Where this underperforms

Three.

Segregation is not recorded structurally. Testing that an approver did not also raise the request needs both identities on the record, and some systems keep only the approver.
Manual processes are the control. Where a control is a person reviewing a printed pack, absence testing has nothing to read.
Policy is ambiguous. A rule that says purchase orders are required for significant spend cannot be tested until significant has a number attached.
Start with payments made outside the payment run in the last twelve months. It is one query, it needs read access only, and it is the clearest example of a control being bypassed rather than failing.

Deeper in control validation

The use cases this hub covers.

Worked on this page
Audit evidence preparation · Exception identification · Control validation

Covered as sections here
Designed versus operating · Bypass detection · Sequence testing · Evidence assembly

Questions heads of audit ask first

What is the difference between a control being documented and operating?

A documented control is written down. An operating control was applied to every transaction it should have been applied to. A sample of approvals proves the control worked on those items and says nothing about the rest, and it says nothing at all about items that never entered the process. ChatFin tests the whole period and looks for bypasses.

How do you test for a control being bypassed?

By testing for absence and for sequence rather than for correctness. A payment outside the payment run, a journal posted directly to a subledger controlled account, an invoice paid with no purchase order in a category that mandates one. Each looks normal on its own. ChatFin identifies them by what is missing and by the order things happened.

Does automating audit evidence compromise independence?

No, because the work being automated is retrieval and assembly rather than judgement. Pulling fifty invoices by criteria, attaching support to a journal, or exporting approval records does not touch what the auditor concludes. ChatFin also reports what it could not find, which is itself a finding rather than a gap in the pack.

How ChatFin works on controls

Look for what went around the control.

ChatFin tests whether a control operated across the whole period, and separately tests for the transactions that never entered the process at all.

Audit evidence is assembled with support attached, and anything that could not be found is reported as a finding.

Bring twelve months of payments. The bypass query runs in minutes.

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AM
Ashok Manthena
CEO and co founder, ChatFin

Ashok Manthena is the CEO and co founder of ChatFin, an AI agent platform for enterprise finance that runs across NetSuite, Acumatica, JD Edwards, SAP and Dynamics 365. He works with CFOs and controllers on governed automation of the close, payables, receivables and reporting. Connect on LinkedIn.

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Bring twelve months of payments.

We will look through ChatFin for the ones made outside your payment run and show you which controls were bypassed rather than failed.

✓Operation tested across the period, not a sample
✓Bypass and sequence testing, not just correctness
✓Evidence assembled with support attached
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