7 August How to Implement Internal Controls for FX Risk Management August 7, 2017By FX Initiative FX Risk Management, FX Risk Policy Drafter , Accounting, Compliance, Confirmation, Continuing Professional Education, CPE, IC, Internal Control, Management, Personnel, Prevention, Record Keeping, Risk, Segregation of Duties, Training, Foreign Exchange, FX 0 Internal control (IC) involves everything that controls risks to an organization. IC relates to operational effectiveness and efficiency, reliable financial reporting, and compliance with laws, regulations and policies. When it comes to hedging foreign exchange risk and Sarbanes-Oxley (SOX), management should be able to understand, assess, and conclude on the adequacy of internal controls over financial reporting as it relates to currency risk management. In general, a minimum of three personnel are required for sufficient internal controls since the trading, accounting, and confirmation duties should be segregated. For example, the Chief Financial Officer (CFO) could be responsible for confirmation and authorization, the controller could be responsible for accounting and record keeping, the treasurer could be responsible for trading and custody. Furthermore, the Board of Directors could be responsible for oversight and approval, and in the event that an exception to the Policy is warranted, the CFO could be responsible for approving any exceptions. While specific internal controls will need to be tailored to the specific needs of an organization, some key questions that should be addressed include: Who has the authority to execute trades? How will trades be executed and what process should be followed? How and when are trades confirmed and compared? Are the trading, accounting, and confirmation duties segregated sufficiently? Who has the authority to authorize policy exceptions, and trade ticket or accounting discrepancies? It is critical to include internal controls as an essential component of an effective Foreign Exchange Risk Management Policy because it outlines in detail the specific processes to be followed. The Internal Controls section of a Policy should address the key questions above by stating internal controls have been set forth to segregate the trading, accounting, and confirmation processes. Continuing the example using the CFO, controller, and treasurer, internal controls could apply to the following FX Risk Management related tasks: The Treasurer will be responsible for recommending hedging strategies, and the Controller and Chief Financial Officer will be responsible for approving the proposed strategies prior to trade execution. The Treasurer will be responsible for selecting counterparty foreign exchange service providers in accordance with 'Counterparty Guidelines', and the Controller is responsible for approving the selected counterparty prior to trade execution. The Treasurer is responsible for executing approved hedging strategies and subsequently recording the transaction in the appropriate general ledger account within 24 hours. The Controller is responsible for confirming that the financial reporting surrounding trade execution matches the trade confirmation received by the counterparty service provider within 72 hours. If a trade confirmation is not received within 72 hours, the Controller is responsible for obtaining the confirmation directly from the counterparty service provider, mediating any disputes between the Treasurer and the counterparty service provider, and alerting the Chief Financial Officer of any pertinent issues. The Treasurer will prepare a cash reconciliation at each month end related to all underlying positions and derivative transactions, both inflows and outflows, that occurred throughout the period. The Controller will cross check the cash reconciliation with all trade confirmations to ensure cash balances reflected on the accounting records match the economics of the underlying positions and derivative transactions settled throughout the period. These are just some of the many ways organizations engaged in foreign exchange risk management should be considering internal controls as part of their currency hedging program and formal Policy. Keep in mind that policies and procedures are never perfect, and should be viewed as a process that is responsive to change and capable of continuous enhancement. By starting sooner rather than later, practice, experience, and results will contribute better information to the internal control process allowing for changes to be made to the foreign exchange risk management program in the future. If you are interested in learning how internal controls are integrated into a foreign exchange risk management policy, FX Initiative's currency risk management training has a course on FX Risk Management that walks you through a real-world scenario using the Foreign Exchange Risk Policy Drafter to illustrate step-by-step the process of segregation of duties and how it relates to personnel and reporting. World class organizations know that proactive prevention is the best approach to long-term compliance and sustainability, so take the FX Initiative and improve your internal control process by subscribing today! Ready to learn about Internal Control and FX Risk Management? Click here to get started > Cheers, The FX Initiative Team support@fxinitiative.com Related Posts Identify Internal Controls for FX Risk Management Interested in identifying internal controls for FX risk management? FX Initiative’s FX Risk Policy Drafter tool will help your firm establish internal controls by appointing personnel to the roles of trading, accounting, and confirmation, and specifying the individual responsibilities that fall under each segregated duty. Get started with our foreign exchange risk management training, which provides 24/7 365 access to our complete suite of foreign exchange (FX) continuing professional education (CPE), examples and events at FXCPE.com. Start Training > Download the PDF FX Risk Management Maturity Model Foreign exchange (FX) risk management involves identifying, analyzing, and prioritizing various foreign currency exposures, and developing and implementing a coordinated and systematic plan that utilizes company resources efficiently and effectively to mitigate FX risk. The degree to which companies implement adequate foreign exchange risk management practices can vary substantially, from not managing the risk at all to engaging in robust hedging activities, and as a result, the impact on the bottom line can vary widely across organizations. This FX Risk Management Maturity Model outlines the 5 stages of a comprehensive currency risk management program. The process involves performing a FX risk assessment, developing a FX risk management policy, and implementing progressive FX hedging strategies. 5 Stage FX Risk Management Maturity Model FX Risk Assessment: Exposure Identification & Measurement FX Risk Management Policy: Hedging Guidelines & Procedures Balance Sheet Hedging: Booked Receivables & Payables Cash Flow Hedging: Forecasted Revenues & Expenses Net Investment Hedging: Subsidiary Earnings & Equity The design and implementation of a FX risk management program must take into account the specific goals and objectives of the firm, the organizational structure and operations, the line of products and/or services, ... FX Risk Management Maturity Model Foreign exchange (FX) risk management involves identifying, analyzing, and prioritizing various foreign currency exposures, and developing and implementing a coordinated and systematic plan that utilizes company resources efficiently and effectively to mitigate FX risk. The degree to which companies implement adequate foreign exchange risk management practices can vary substantially, from not managing the risk at all to engaging in robust hedging activities, and as a result, the impact on the bottom line can vary widely across organizations. This FX Risk Management Maturity Model outlines the 5 stages of a comprehensive currency risk management program. The process involves performing a FX risk assessment, developing a FX risk management policy, and implementing progressive FX hedging strategies. 5 Stage FX Risk Management Maturity Model FX Risk Assessment: Exposure Identification & Measurement FX Risk Management Policy: Hedging Guidelines & Procedures Balance Sheet Hedging: Booked Receivables & Payables Cash Flow Hedging: Forecasted Revenues & Expenses Net Investment Hedging: Subsidiary Earnings & Equity The design and implementation of a FX risk management program must take into account the specific goals and objectives of the firm, the organizational structure and operations, the line of products and/or services, ... FX Risk Management Maturity Model Foreign exchange (FX) risk management involves identifying, analyzing, and prioritizing various foreign currency exposures, and developing and implementing a coordinated and systematic plan that utilizes company resources efficiently and effectively to mitigate FX risk. The degree to which companies implement adequate foreign exchange risk management practices can vary substantially, from not managing the risk at all to engaging in robust hedging activities, and as a result, the impact on the bottom line can vary widely across organizations. This FX Risk Management Maturity Model outlines the 5 stages of a comprehensive currency risk management program. The process involves performing a FX risk assessment, developing a FX risk management policy, and implementing progressive FX hedging strategies. 5 Stage FX Risk Management Maturity Model FX Risk Assessment: Exposure Identification & Measurement FX Risk Management Policy: Hedging Guidelines & Procedures Balance Sheet Hedging: Booked Receivables & Payables Cash Flow Hedging: Forecasted Revenues & Expenses Net Investment Hedging: Subsidiary Earnings & Equity The design and implementation of a FX risk management program must take into account the specific goals and objectives of the firm, the organizational structure and operations, the line of products and/or services, ... FX Risk Management Maturity Model Foreign exchange (FX) risk management involves identifying, analyzing, and prioritizing various foreign currency exposures, and developing and implementing a coordinated and systematic plan that utilizes company resources efficiently and effectively to mitigate FX risk. The degree to which companies implement adequate foreign exchange risk management practices can vary substantially, from not managing the risk at all to engaging in robust hedging activities, and as a result, the impact on the bottom line can vary widely across organizations. This FX Risk Management Maturity Model outlines the 5 stages of a comprehensive currency risk management program. The process involves performing a FX risk assessment, developing a FX risk management policy, and implementing progressive FX hedging strategies. 5 Stage FX Risk Management Maturity Model FX Risk Assessment: Exposure Identification & Measurement FX Risk Management Policy: Hedging Guidelines & Procedures Balance Sheet Hedging: Booked Receivables & Payables Cash Flow Hedging: Forecasted Revenues & Expenses Net Investment Hedging: Subsidiary Earnings & Equity The design and implementation of a FX risk management program must take into account the specific goals and objectives of the firm, the organizational structure and operations, the line of products and/or services, ... CPE Webinar Invite: FX Risk Management Policies Program Overview FX Initiative cordially invites you to attend our webinar titled “FX Risk Management Policies” on Thursday, February 11th, 2021 at 11AM Pacific / 2PM Eastern. Join us for a continuing professional education (CPE) program and earn CPE credit as we learn how to draft a corporate foreign exchange risk management policy. This FX Risk Policy webinar will address the basics for drafting a foreign exchange risk management policy. We begin with best practice policies for pricing and booking foreign exchange (FX) transactions that enable a corporation to retain the FX risk rather than the customer, supplier or vendor. We then discuss how FX personnel, resources and operations are incorporated into a policy document that serves as a guideline for managing foreign exchange risk. Furthermore, we will cover the essential elements of a formal written FX risk management policy, including which FX exposures to hedge, how to handle counterparty credit risk, segregation of duties (SOD), internal controls, and reporting among other areas. Lastly, we will observe how FX risk policy language is disclosed in corporate annual reports (10-K) using the Securities and Exchange Commission ... Comments are closed.