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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Examples from Jamie's Story
No examples are available.
Examples from the Anomalies
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.
Potential Green Book Deviation:
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.
