8.09

Risk Assessment

Principle 8 - Assess Fraud, Improper Payment, and Information Security Risk

Attribute 8.09 - In addition to fraud, management also considers the risk of management override of controls. Management override of controls does not necessarily involve fraud but may indicate potential fraud and increases fraud risk.

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Jamie's Story

March 12, 2026: Maricopa County Defense Briefing

Additional details regarding this aspect of my story are available in a subsection titled Contract with the Motor Vehicle Department (MVD).N

My Public Records Request sought the contract between MC and the MVD. No contract was delivered because no written agreement was prepared. Per the MC management and legal team, MC is only required to document where specified in statutory requirements. This attribute, 8.09, was noteworthy for this governance assessment because the possibility of Management Override had never been considered before viewing this attribute. Given the Covid-19 public health controls that were implemented in from 2020 through 2022, management overrides may have been necessary for some of the election sub-processes. Manual overrides are a lower tier process feature, which would not be addressed in A.R.S.. Therefore, MC county would be expected to be unable to identify which management overrides were implemented and who approved them. Contrary to the Green Book, it wis doubtful that MC management considered the risk of their own management overrides as risking the integrity of voter registration data transferred from the MVD to MC. More concerning is the possibility that MC managers may have been performing manual overrides during the Covid-19 Pandemic, using the health crises as enabling situation to conceal fraudulent activities.

June 1, 2026: Judge's Decision

The Runbeck Contract that was provided to Jamie had numerous strikeouts and amendments that were poorly documented, especially during the Covid-19 pandemic. Maricopa County would not voluntarily explain these changes and they were not required to maintain documentation because they were not specified as a statutory requirement.

Election Anomalies

The Green Book's Principle 8 addresses Assess Fraud, Improper Payment, and Information Security Risk. Obviously, improper payments is not a concern during the Assessment of Election Anomalies. However, improper payments by MC county may exist, but would require a separate assessment.

The Green Book's emphasis on fraud and information security as separate risk assessment activity is intentional. MC may be able to defer to the Arizona Secretary of State's Election Procedure Manual as general steps taken to ensure the integrity of election results. Fraud occurs when loopholes are identified and exploited by the fraudsters. The implementers of election services (i.e., Arizona Counties) are better positioned to detect fraud and assess the risk of fraud because they are handling the data, not the state. Hence, governance gaps may be identified from patterns of poor assessment and response to risk with respect to election fraud and information security.

Maricopa Dropbox Collection (2020)

Governance issues identified from Arizona Attorney General's Office 2020 General Election Investigation of Arizona Senate allegations of Maricopa County Election Department - Drop Box Collections issues. Section 2 of the AZ AG's inspector's report identifies numerous issues, which present risk to potential fraud. The Arizona Senate's allegations of inappropriate drop box actions and behaviors were confirmed by the AZ AG's inspector.

• See the heading Deviation: Allegations Confirmed from Maricopa Dropbox Collection (2020) webpage.

Potential abuse of MC leadership authority was assessed in the prior Green Book Attribute 8.08. This attribute suggests these leadership abuses may have been implemented under the guise of a legitimate management override. However, there is insufficient documentation available to determine under what authority were changes implemented to allow these procedure violations. No justification for the change was documented, which may have been helpful to assess the legitimacy of management overrides, if that is how they were rolled out to the Election Department staff.

Maricopa County Signature Verification (2020)

Governance issues identified from Arizona Attorney General's Office 2020 General Election Investigation of Arizona Senate allegations of Maricopa County - Signature Verification Process issues. There was simple and direct justification for manual overrides during the signature verification process step, which were the unusual circumstances associate with public health mandates initiated to address the Covid-19 pandemic.

The inspector's note did not identify any specific management overrides. However, the inspector describes how training was provided to 33 MC employees in June 2020, noting that this training "mirrored" the recommendations of the Arizona Secretary of State's Election Procedure Manual. Later, the inspector noted that 40 temporary employees were hired during October and began performing Level I Signature Verifications without any training. Was this a Management Override?