SITUATION

A rapidly scaling RIA platform was approaching a threshold requiring ICFR documentation and controls testing for the first time. The finance function had no existing controls framework, limited documentation, and a technology stack that had grown ahead of its governance.

APPROACH

Assessed the control environment against ICFR requirements. Identified 14 key controls across revenue, AP, close, and reporting cycles. Used AI tooling to accelerate documentation — generating control narratives, process maps, and test scripts from existing system data. Prioritised controls by risk rating and sequenced implementation to avoid disrupting ongoing operations.

OUTCOME

Full ICFR controls framework documented across 14 controls in 6 weeks. Controls testing completed without external audit support. Three controls required process redesign before documentation was viable — addressed in sequence. Platform entered its first audit cycle with a complete, testable controls environment.