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Understanding Three Lines of Defense

May 3, 2025

The Three Lines of Defense - Office of Internal Audit

The three lines of defense model offers a framework for effective risk management and governance within an organization's control environment. Each line plays a distinct role:

First Line of Defense: Management

  • Role: Handled by business and process owners.
  • Responsibilities:
    • Maintain effective internal controls.
    • Execute risk and control procedures daily.
    • Identify, assess, and mitigate risks.
    • Develop and implement internal policies and procedures.
    • Ensure alignment with university goals.
    • Mid-level management designs detailed control procedures and supervises their execution.

Second Line of Defense: Risk Management and Compliance

  • Role: Supports management to ensure effective risk and control management.
  • Functions:
    • Risk Management Function:
      • Facilitates and monitors risk management practices.
      • Assists in defining risk exposure and reporting risk-related info.
    • Compliance Function:
      • Monitors noncompliance risks with laws and regulations.
      • Reports directly to senior management.
    • Controllership Function:
      • Monitors financial risks and reporting issues.
  • Purpose:
    • Ensures the first line is effectively designed and operational.
    • Although supportive, lacks full independence.

Third Line of Defense: Internal Audit

  • Role: Provides assurance to senior management and board of alignment with expectations.
  • Characteristics:
    • High level of organizational independence and objectivity.
    • Cannot direct or implement processes, but advises and recommends.
    • Evaluates and improves risk management, control, and governance processes.

External Auditors

  • Responsibility:
    • Express opinion on financial statements' fairness.
    • Provide assurance on institutional compliance (e.g., Title IV funding).

Additional Information

References:

  • COSO's Take on the Three Lines of Defense.
  • "Leveraging COSO across the Three Lines of Defense", July 2015.