8.02
Risk Assessment
Principle 8 - Assess Fraud, Improper Payment, and Information Security Risk
Attribute 8.02 - Management identifies risks related to fraud, improper payments, and information security through the same risk identification process performed for all analyzed risks. However, these risks are discussed further in this principle because they may be pervasive or have an impact on multiple processes and can often be inadequately addressed in the risk assessment process.
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The discussion of Attribute 8.02 is from this March 12, 2026 event, under the subheading of Motor Vehicle Department Contract.
Attribute 8.02 is unique, it seems redundant to the prior Green Book presentation "Risk Assessment" as addressed in "Components of Internal Controls." The Green Book discussion of Risk Assessment identified four risk-related Principles (i.e., 6, 7, 8, and 9), which consisted of 58 specific attributes. Despite all the prior emphasis of addressing risk, the Green Book intentionally placed the topic of risk within a broader topic of fraud, improper payments and information security. Why?
The prior discussion of risk addressed how things can go wrong on a good day; sometimes the unexpected happens and it's in the manager's best interest to understand how day-to-day operations can be disrupted from the unexpected. Here, in Principle 8 addresses risk from the perspective of malicious intent; there are "bad" people or entities that will try to deceive the governing entity for personal benefit. Thus, the Green Book addresses the risk of malicious intent separately from day-to-day risk.
Would there be any motivation to infiltrate and deceive the MC to sway the election results?
The obvious answer is "Yes." So what is MC doing to address the risk of malicious intent?
Apparently, the answer is "Nothing." Perhaps, some MC employees may be purposefully ignoring the risk, which may have legal implications, which are far beyond the scope of this governance assessment.
For Attribute 8.02, fraud and information security are the primary concerns. That said, improper payments may also be an area of interest given that the contract between MC and Dominion included an annual inflation price increase in the double digits when inflation rate was less than 3% when the contract was approved. However, this type of improper payment would not be associated with fraud since MC management knowingly approved of the higher than actual inflation rate.
Potential Green Book Deviation:
Contrary to the Green Book, MC was unable to provide any objective evidence to explain how they investigated numerous election-related anomalies as potential fraud.
