Sunday, 22 September 2019

Which Technologies Are Changing Audit?

Source: ACCA Report June, 2019.



Businesses across almost every industry are experiencing at first hand the disruptive changes that are also affecting their auditors. This chapter explores which advanced technologies are impacting the audit profession, referring to both the tools available to auditors and the systems that need to be audited.

In April 2019, ACCA surveyed members and affiliates about their understanding of terms such as artificial intelligence (AI), machine learning (ML), natural language processing (NLP), data analytics and robotic process automation (RPA). On average for any given term, 62% of respondents had not heard of it, or had heard the term but did not know what it was, or had only a basic understanding. On average, only 13% of respondents claimed a ‘high’ or ‘expert level’ of understanding of these terms. There’s a need for greater awareness of what these technologies are and their implication for the audit profession.

ARTIFICIAL INTELLIGENCE (AI)

AI is often described as ‘an evolving technology’ that is equipping computer systems with something akin to human intelligence, but it is better seen as an umbrella term for a group of technologies that can be combined in different ways, whether for driving your car, controlling your central heating, or managing your investment portfolio. It is also the subject of a large amount of hype, with ‘human-like intelligence’ predicted to appear in 2029 (or whatever the current date is plus ten years) and either drastically reducing the workforce or destroying us all. According to Elon Musk: ‘with artificial intelligence we’re summoning the demon’ (Finamore, E. and Dutta K 2014). It could be argued that because of a lack of understanding of concepts such as ‘intuition’ and ‘thought,’ we do not even know what it is we are trying to emulate. Is intelligence what is measured by an ‘Intelligence Quotient’ (IQ)? Or, in developing AI, should we be trying to emulate other quotients, such as an ‘Emotional Quotient’ (EQ). 

‘It is clear that some tasks will no longer be done by the auditors. In the long term, it is likely that the profession will see a shift in its focus with more emotional intelligence expected from auditors rather focusing on data testing.’ Michal Stepan, Assurance Director, Deloitte Czech Republic

The ‘intelligence’ in AI often constitutes a combination of processing power and access to data: for instance, a computer will play a game such as chess by analyzing all the possible outcomes of a move, using datasets from past games and selecting the winning option. But that fact alone makes AI highly useful to people: it enables the analysis of entire populations of data to identify patterns or exceptions. Auditors are freed from mundane tasks and can focus their time on deploying their skills, training and judgement: although technology is making progress in areas such as speech processing and sentiment analysis, professional judgement is much harder to apply technology to.

ROBOTIC PROCESS AUTOMATION (RPA)

RPA is often mistakenly thought of as a form of AI but the ‘robots’ are software routines that are more like very sophisticated Excel spreadsheet macros than genuine AI.As highlighted in ACCA’s joint report with CA ANZ and KPMG Embracing robotic automation during the evolution of finance, ‘RPA is software that can be easily programmed or instructed by end users to perform high-volume, repeatable, rules-based tasks in today’s world where multiple loosely integrated systems are commonplace.’ (ACCA et al. 2018).

RPA is commonly used when the output of one financial process needs to be input into another, or where multiple sources of information need to be consulted. As a result, it is sometimes referred to as ‘swivel chair automation’, conjuring up the image of an employee swiveling their chair around as they consult multiple systems and re-key and check information.

Such work is repetitive, mundane, time consuming and, when done by individuals, prone to error. It is also difficult to scale to cope with variations in workload. A classic example would be processing timesheet information from seasonally employed temporary staff. One solution is to deploy or lease a ‘robot’, a software routine that precisely mimics the actions of the chair-swiveling person shifting between systems. Looking back to the timesheet example, the robot would take the information gathered by optical character recognition (OCR) from the paper records and feed it into the payroll system. Because it mimics a process rather than analyzing data, RPA itself is not AI, which could be used later to look for the anomalies that previously a human operator might have had to spot. RPA offers many benefits: the robots work non-stop and are faster, more accurate and scalable. Nonetheless, there are also questions about accountability and ownership of the RPA process and security of the data that passes through it. There is also the question of whether RPA simply perpetuates inadequate processes that should have been overhauled. We can distinguish between ‘good RPA’, which closes gaps and contributes to straight-through data processing and ‘bad RPA’, which simply disguises the flaws in obsolescent or badly implemented systems. In short, fix the process first before applying RPA. 

DATA ANALYTICS

Analytical tools have long been applied to the data derived from accounting and operational systems. Some firms are already using data analytics as part of their transactions testing, gradually moving away from traditional sampling techniques. Data analytics allow auditors to use 100% of a population’s transactions when performing their tests. ‘Using D&A we make the analysis of the past more insightful. Rather than sampling transactions data to test a snapshot of activities, we can now analyze all transactions processed, allowing us to identify anomalies and drill down on the items that show the greatest potential of being high risk. Our systems automate this process, increasing its ability to produce high quality audit evidence.’ (KPMG 2015). 

‘I expect that my auditors will no longer test a sample of transactions, for example 100 items, and consider this to be sufficient evidence to form a conclusion for the entire population, when in fact we have tens of thousands of transactions coming in and out on a daily basis.’ Juraj Striezenec, CFO, Kiwi.com 

However, the UK Financial Reporting Council (FRC) has found that ‘the use of data analytics in the audit is not as prevalent as the market might expect’ (FRC 2017) and it is not yet used consistently across the entire ledger. Even where it is used – such as in journal entry testing, auditors will still need to consider the issue of completeness, as well as the increasing amount of corporate reporting that does not derive from transactions in the ledger. ‘Being able to test 100% of a population does not imply that the auditor is able to provide something more than reasonable assurance opinion or that the meaning of “reasonable assurance” changes.’ (IAASB 2016). 

The next step for auditors and finance is to apply AI and ML algorithms to improve the quality of analysis and forecasting, and increase the rate of fraud detection. The business ‘data warehouse’ is increasingly being supplemented by information drawn from a variety of public and/or proprietary sources, often using cloud-based applications combined with desktop analytical tools. Augmenting these tools with DL and NLP increases the range of data that can be handled, from written text speech or even images. The ability to analyse data across and outside corporate data silos promises to enhance the ability of organisations to spot opportunities, head off threats, make better decisions and enable this process to be ‘democratized’ throughout the organisation. Auditors can use ‘data mining software’ to drill down and identify anomalies – possibly aided by AI – focusing resources on identifying risks in addition to monitoring ‘business as usual’ activities.

MACHINE LEARNING (ML)

A major challenge to the audit profession has been the extreme proliferation of data, accompanied by a less extreme but nonetheless rapidly expanding volume of regulation. According to ACCA’s report Machine Learning: More Science than Fiction: ‘The rapid growth in the volume of financial transactions, if not properly managed, could pose a threat to the work of accountants. For auditors, this may relate to the sample they need and its ability to be representative of the population, enabling them to form conclusions that can be generalised beyond the sample’ (ACCA 2019b).‘In fact, technology like machine learning could go beyond that with the possibility for reviewing entire populations to assist the auditor to test for items that are outside the norm’ (ACCA 2019b). 

 ML uses statistical analyses to generate predictions or make decisions from the analysis of a large historical dataset. A classic example would be credit scoring decisions for loans. The accounting software company Xero has implemented ML to make coding decisions for invoices. ML can achieve surprising levels of accuracy quite quickly: in the case of Xero’s software, the system achieves 80% accuracy after learning from just four invoices.ML ‘predictions’ can be both backward and forward-looking. It has clear applications in risk management and the detection of fraud and inaccuracy by comparing historical data sets with current data, which can help with risk assessment. Or it can look forward, predicting, for example, the likely future value of an asset. In practice, the usefulness of ML is crucially dependent on the data it ‘learns’ from. This means the possibility of bias is ever present. Examples have come to light where ML has introduced bias into areas such as credit-scoring and CV assessment. 

The machine correctly sees that a previously excluded group had not completed many successful loan transactions or risen very high in management and wrongly concluded that the defining characteristics of those groups, such as gender, were predictors of poor future performance. An example using ML in audit can be found in PwC’s report Confidence in the future: Human and machine collaboration in the audit report. As per this example ‘company A was way out of line with the peer group benchmarks on a particular point. This data is then shared with the audit team, who can decide whether that variance is really an anomaly and if so, what caused it. The team’s decision about the anomaly and its cause is then fed back to the machine, which is ‘taught’ how to respond to similar relationships in future. And the more this exercise is carried out, the better the machine will get at spotting real anomalies — meaning we’ll be better able to identify unusual patterns and anomalies in huge amounts of data in an instant.’ (PwC 2017). 

The self-instructing nature of ML means that decision-making can often be a ‘black box’, with no one able to say precisely how decisions have been arrived at. There is also the danger that during the learning stage – when ML is shadowing human auditors – it will pick up any human errors and repeat them eternally. ML therefore needs to be validated in some way: it is a risk as well as a tool. This raises the possibility that the challenging and testing of internal algorithms may become part of the external auditor’s role, with a much wider remit than assessing accuracy: as the Harvard Business Review comments: ‘the auditor’s task should be the more routine one of ensuring that AI systems conform to the conventions deliberated and established at the societal and governmental level’ (Guszcza et al. 2018). 
 

NATURAL LANGUAGE PROCESSING (NLP)

NLP refers to the ability of the computer to recognize and understand human speech. The most immediate impact is speed: NLP has been shown to achieve orders of magnitude improvements in due diligence exercises involving very large numbers of documents. In 2017 Forbes reported that Deloitte’s use of NLP took contract review from a task keeping ‘dozens’ of employees occupied for half a year to one which six to eight members could complete in less than a month (Zhou 2017). Deloitte’s Audit of the Future Survey found that 70% of audit committee members and other stakeholders believed that auditors should not only use advanced data analytics but consider information beyond traditional financial statements (Deloitte 2016). This data could be anything from recordings of phone calls to board minutes or postings on social media, which are unstructured and therefore require an understanding of natural language.

DEEP LEARNING (DL)

DL is a subset of ML; it more closely mimics human learning through the use of artificial neural networks to perform more complex tasks such as visual object recognition. Its best known example is Google’s AlphaGo, which mastered Go, a game which exceeds chess in intellectual complexity and where it was thought that computers could never match the best human players. Unlike previous programs, which learned winning strategies from databases of previous games, AlphaGo taught itself and not only defeated its human opponent but also used highly inventive winning moves, which – according to Demis Hassabis, CEO of the Google subsidiary DeepMind, which created AlphaGo ‘were so surprising they overturned hundreds of years of received wisdom’ (Hassabis 2017).

DL systems are commercially available and have already been deployed by the Big Four accountancy firms: KPMG uses IBM’s Watson to analyze commercial mortgage loan portfolios, while Deloitte works with Canadian-based legal AI company, Kira Systems to ‘read’ thousands of complex documents, such as contracts, leases and invoices, extracting and structuring textual information such as key words or phrases. In the era of Big Data, the structured information accessible to auditors is only a fragment or an abstraction of the much wider universe of data. But this ‘dark matter’ exists in unstructured formats: the ability of DL to analyze a range of internal and external sources means that Big Data can potentially supply complementary audit evidence and feed into the narrative requirements of audit.

‘For instance, content analysis of social media postings and news articles could inform auditors of potential litigation risk, business risk, internal control risk, or risk of management fraud...auditors may identify troublesome products or services by analyzing customers’ reviews...sentiment scores of the Q&A section of earnings conference calls can help the auditor predict internal control material weakness’ (Sun and Vasarhelyi 2018).Used in audit, DL potentially goes beyond merely extracting set words or phrases or even what has been explicitly said:‘auditors interview management, internal auditors, employees, predecessor auditors, bankers, legal counsel, underwriters, analysts, or other stake-holders. The language that subjects use and how they respond to questions over the course of the interview can be just as important as the answers themselves, because they may indicate deception. For example, the use of terms that suggest uncertainty, such as “kind of,” “maybe,” or “sort of,” as well as response latency, could be signs of concealment or falsification’ (Sun and Vasarhelyi 2017). 

DRONE TECHNOLOGY, INTERNET OF THINGS AND SENSOR TECHNOLOGIES

Unmanned drones are used in a variety of commercial projects, such as power line inspection, and the Big Four accountancy firms have spotted the potential for their use in inventory inspection, particularly where physical scale or distribution is an issue. For example, PwC recently announced its first stock count audit – of an open cast mine – using drone technology (PwC 2019).Drones are the aerial component of the Internet of Things, the constantly growing number of devices and sensors connected via IP (internet protocol). An example of a sector that is ripe for the adoption of such technologies in audit and assurance is agriculture.

DISTRIBUTED LEDGER TECHNOLOGY (DLT)

DLT, a family of technologies that includes blockchain, is of great interest to both auditors and businesses. According to ACCA’s report Divided we Fall, Distributed we Stand, DLT ensures that ‘in a distributed ledger all participants are looking at a common view of the records.’ (ACCA 2017a), which are validated without the need for a central authority for this purpose. ‘So if the majority of participants agree that an update has been correctly validated, that becomes the basis for the updated entry to be added to the ledger.’ (ACCA 2017a).

For businesses, the attraction of DLT is that it greatly enhances performance in areas where inefficiencies are introduced by the so-called ‘efficiency visibility’ and ‘trust’ deficits. Examples include the inefficiencies and delays involved in setting up trade finance, the need to establish trust via ‘know your customer’/‘customer due diligence’ (KYC/CDD) requirements in finance and banking or the lack of visibility in the global garment supply chain are all key areas for distributed ledger applications. For the auditor, distributed ledgers become a sort of universal bookkeeping service, removing the need to reconcile multiple databases of records and providing a perfect audit trail. A key principle of DLT is immutability: historical entries cannot be changed, only corrected with a balancing entry. While this may help auditors to test audit assertions such as occurrence and cut-off, it does not remove the need for higher-level auditor judgements. 

Transactions may exist outside the ledger and, while those recorded are unlikely to be false, they still may not be legitimate. The auditor therefore needs to combine the ledger information with judgements based on accounting principles and an understanding of the nuances applicable to ownership and valuation. For auditors, DLT offers the possibility of generating exception reports that are based on all transactions rather than on using sampling techniques – a return to the roots of auditing. Today’s audit cycles could potentially be replaced by more frequent or even continuous, real-time, audit. This is likely to release resources and provide the material for a deeper and more contextual understanding of the business, as required for the production of extended audit reports. However, this is also likely to increase resources with specialized skills in DLT, at least in the short-term. While DLT may be supported by standardization and automation of data collection – possibly via ‘accounting-as-a-service’ platforms – the removal of mundane tasks will bring the contribution of the auditor’s judgement into stronger focus.

The report concludes: ‘The auditor role may pivot towards non transaction-management elements requiring human judgement, business context and knowledge of technical accounting policy and of the outputs created by the application of these elements to specific questions within the audit, for example the fair value of assets’ (ACCA 2017a).

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