Recommending an Organizationwide Risk Strategy

5 minutes 5 Questions

Within the Certification in Risk Management Assurance (CRMA) body of knowledge, recommending an organizationwide risk strategy is one of the key areas where internal audit can add value in enterprise risk management (ERM), while carefully preserving its independence and objectivity. The IIA's 'Three Lines Model' and related guidance (including the IIA Position Paper 'The Role of Internal Auditing in Enterprise-wide Risk Management') describe a spectrum of roles: core assurance roles, legitimate consulting roles with safeguards, and roles internal audit should not undertake. Recommending an organizationwide risk strategy sits in the middle category—a legitimate consulting role that is permitted only with appropriate safeguards. In practice, this means internal audit may advise the board and senior management on how to design or improve a coherent, enterprise-level approach to risk. This can include recommending a risk governance structure, proposing a risk appetite and tolerance framework, suggesting a common risk language and taxonomy, advising on risk assessment methodologies, championing the establishment of ERM, and helping align risk management with strategic objectives. Internal audit draws on its organizationwide view, knowledge of controls, and familiarity with frameworks such as COSO ERM and ISO 31000 to offer informed, independent perspectives. However, critical boundaries apply. Internal audit must not set the risk appetite, own or manage risks, make risk response decisions, implement risk responses, or take accountability for risk management—these belong to management (first and second lines) and the board. Safeguards include documenting the consulting nature of the work in the charter, ensuring management retains responsibility for decisions, disclosing the role to the audit committee, and avoiding later assurance on the same areas by the same auditors, or applying rotation and independent review where unavoidable. For a CRMA candidate, the key takeaway is that internal audit can be a catalyst and advisor for an integrated risk strategy, but must never cross into management responsibility, thereby maintaining the credibility of its assurance role.

Recommending an Organizationwide Risk Strategy: Internal Audit Roles and Responsibilities (IIA CRMA Study Guide)

1. Why This Topic Matters

The Certification in Risk Management Assurance (CRMA) tests whether you understand the boundaries of internal audit's involvement in enterprise risk management (ERM). Few topics illustrate those boundaries better than the question of whether, and how, internal audit may recommend an organizationwide risk strategy.

Boards and executives frequently turn to the chief audit executive (CAE) for help when ERM is immature or non-existent. Internal auditors have a broad view of the organization, understand risk and control concepts, and are trusted advisors. It is therefore tempting for internal audit to step in and design the risk strategy. The problem is that internal audit's core value lies in independent, objective assurance over the risk management process. If internal audit builds the strategy and then audits it, objectivity is compromised and the organization loses its independent line of defense.

The IIA addresses this tension directly in its Position Paper The Role of Internal Auditing in Enterprise-wide Risk Management (commonly called the 'ERM fan' or 'fan diagram'), in the Three Lines Model, and in the Standards. CRMA Domain I (Internal Audit Roles and Responsibilities, about 20% of the exam) draws heavily on this material. Expect several questions that ask you to classify an activity as a core assurance role, a legitimate consulting role requiring safeguards, or a prohibited role. Recommending or developing a risk strategy is a classic example that sits in the middle category, and examiners love to test whether you know where the line is.

2. What It Is: Defining the Concept

An organizationwide (enterprise-wide) risk strategy is the high-level approach an organization adopts to identify, assess, respond to, monitor and report on risks in support of its objectives. It typically covers:
- The organization's risk philosophy and culture.
- Risk appetite and tolerance (set by the board).
- Roles, responsibilities and accountabilities across the three lines.
- The framework or model to be followed (for example COSO ERM 2017 or ISO 31000).
- Risk assessment methodology, criteria and scoring.
- Risk response options and escalation routes.
- Risk reporting to senior management and the board.
- Integration of risk management with strategy setting, planning and performance management.

Recommending an organizationwide risk strategy means internal audit, acting in an advisory (consulting) capacity, proposes a strategy, framework or roadmap to management and the board for their consideration and approval. In the IIA fan diagram this appears as 'Developing RM strategy for board approval' and is listed among the legitimate internal audit roles with safeguards, alongside championing the establishment of ERM, facilitating risk identification and evaluation, coaching management in responding to risks, coordinating ERM activities, consolidating risk reporting, and maintaining and developing the ERM framework.

Critically, recommending is not the same as:
- Setting the risk appetite (a board and senior management responsibility).
- Approving or owning the strategy.
- Imposing risk management processes on the organization.
- Taking decisions on risk responses or implementing responses on management's behalf.
- Being accountable for risk management.
All of these fall in the fan's third category: roles internal audit should not undertake.

3. How It Works: The Three-Category Model

The IIA fan diagram organizes internal audit's possible ERM activities along a spectrum.

Core internal audit roles (assurance):
- Giving assurance on the risk management processes.
- Giving assurance that risks are correctly evaluated.
- Evaluating risk management processes.
- Evaluating the reporting of key risks.
- Reviewing the management of key risks.

Legitimate roles with safeguards (consulting):
- Facilitating identification and evaluation of risks.
- Coaching management in responding to risks.
- Coordinating ERM activities.
- Consolidating reporting on risks.
- Maintaining and developing the ERM framework.
- Championing establishment of ERM.
- Developing a risk management strategy for board approval.

Roles internal audit should NOT undertake:
- Setting the risk appetite.
- Imposing risk management processes.
- Management assurance on risks.
- Taking decisions on risk responses.
- Implementing risk responses on management's behalf.
- Accountability for risk management.

The further an activity sits toward the right of the fan, the greater the threat to independence and objectivity, and the stronger the safeguards must be.

4. The Required Safeguards

When internal audit recommends or helps develop a risk strategy, the IIA position paper and Standards require the following protections:

1. Management remains responsible. It must be clear that management (first and second lines) and the board own risk management. Internal audit advises; it does not decide.
2. Document the role in the internal audit charter. The nature of internal audit's responsibilities, and any consulting role in ERM, should be approved by the board and recorded in the charter.
3. Do not manage risks on management's behalf. Internal audit should not take ownership of any risk or risk response.
4. Provide advice, challenge and support; never make the decision. The strategy is presented as a recommendation for board approval.
5. No assurance over your own work. Internal audit cannot give objective assurance on any part of the ERM framework or strategy for which it is responsible. If internal audit developed the strategy, assurance over it should be obtained from another suitably qualified party, or the auditors involved should be excluded from the subsequent assurance work, with the impairment disclosed.
6. Treat the work as a consulting engagement. Apply the consulting standards: agree scope, objectives and expectations with the client, exercise due professional care, and communicate results appropriately.
7. Time-limit the involvement. Best practice is for internal audit's consulting role in building ERM to be temporary, with a planned transition of responsibility to a dedicated risk management function (second line).
8. Disclose impairments. If independence or objectivity is impaired in fact or appearance, the details must be disclosed to appropriate parties (Standard 1130 in the 2017 Standards; Principle 7 and Standard 7.1 on organizational independence in the 2024 Global Internal Audit Standards).

5. A Practical Process for Recommending a Risk Strategy

If the CAE accepts the consulting role, a sound approach looks like this:

Step 1 - Agree the engagement. Confirm with the board or audit committee that the task is a consulting engagement, define scope and deliverables, and record the arrangement in the charter or engagement terms.
Step 2 - Understand the context. Review the organization's mission, objectives, strategy, business model, regulatory environment and existing risk practices. Obtain the board's view on risk appetite (do not create it for them).
Step 3 - Assess current maturity. Benchmark existing risk activities against a recognized framework (COSO ERM 2017: Governance and Culture; Strategy and Objective-Setting; Performance; Review and Revision; Information, Communication and Reporting; or ISO 31000 principles, framework and process). Identify gaps.
Step 4 - Draft recommendations. Propose governance structures, roles across the three lines, methodology, reporting lines, tools, training and a phased implementation roadmap. Present options and trade-offs rather than a single mandated answer.
Step 5 - Present for approval. Submit the recommended strategy to senior management and the board. The board approves the strategy and sets the risk appetite; management implements.
Step 6 - Step back. Transfer ownership to management and the risk function. Plan how future assurance over the strategy will be delivered objectively, and disclose any impairment.

6. Link to the Three Lines Model

The IIA's Three Lines Model (2020) reinforces this topic. The governing body sets direction, including risk appetite, and holds management accountable. First-line roles (operational management) own and manage risks. Second-line roles (risk, compliance, quality functions) provide expertise, support, monitoring and challenge. Third-line roles (internal audit) provide independent and objective assurance and advice. The model explicitly allows internal audit to provide advice, but the governing body and management must ensure that doing so does not undermine the third line's independence. Recommending a risk strategy is advice; owning it would turn internal audit into a second-line function.

7. Common Misconceptions to Avoid

- 'Internal audit can never be involved in developing ERM.' Incorrect. It is a legitimate role with safeguards, particularly where ERM is immature.
- 'If the board asks, internal audit can set the risk appetite.' Incorrect. Setting appetite is always a board and senior management responsibility.
- 'Once the strategy is approved, internal audit can audit it normally.' Not without safeguards. Auditing your own design is a self-review threat; alternative assurance or disclosure is required.
- 'Recommending a strategy is an assurance activity.' Incorrect. It is a consulting activity and must be managed as such.
- 'Developing the framework and implementing it are the same.' They are not. Developing or maintaining the framework is permitted with safeguards; implementing risk responses on management's behalf is prohibited.

8. Exam Tips: Answering Questions on Recommending an Organizationwide Risk Strategy

Tip 1 - Learn the fan diagram cold. Be able to place every listed activity in the correct one of the three categories. 'Developing RM strategy for board approval' is a legitimate role with safeguards. 'Setting the risk appetite' is prohibited. 'Giving assurance on the risk management processes' is core.

Tip 2 - Watch the verbs. Words such as recommend, advise, propose, facilitate, coach, support, champion, develop for approval signal permitted consulting roles. Words such as set, approve, decide, own, impose, implement, be accountable for signal prohibited management roles. The verb usually gives away the answer.

Tip 3 - Identify who approves. If a question asks who should approve or own the organizationwide risk strategy or risk appetite, the answer is the board (or senior management under board oversight), never internal audit or the CAE.

Tip 4 - Apply the 'best safeguard' logic. When asked what the CAE should do before or after helping develop a strategy, prefer answers involving: documenting the role in the charter, obtaining board approval, confirming management ownership, treating the work as a consulting engagement, disclosing impairment, and arranging independent assurance over the areas internal audit designed.

Tip 5 - Distinguish 'should not' from 'may with safeguards'. Many distractors describe activities that sound similar. 'Maintaining and developing the ERM framework' is acceptable with safeguards; 'imposing risk management processes' is not. 'Coaching management in responding to risks' is acceptable; 'taking decisions on risk responses' is not.

Tip 6 - Remember that immaturity does not remove the rules. Scenario questions often describe an organization with no risk function and a board asking internal audit to 'take charge.' The best answer is usually for internal audit to assist on a temporary, documented, consulting basis while management retains accountability and a plan exists to transfer the role to a risk function, not to decline outright and not to assume ownership.

Tip 7 - Know the relevant Standards. Be ready to cite: independence and objectivity requirements and impairment disclosure; the requirement that the charter define the nature of assurance and consulting services; the CAE's obligation to manage roles beyond internal auditing with safeguards; and the Standard on evaluating risk management processes (2120 in the 2017 Standards; Domain IV and Domain V content in the 2024 Global Internal Audit Standards).

Tip 8 - Choose the most conservative professionally acceptable answer. When two options both appear reasonable, select the one that best preserves independence and objectivity while still adding value. The IIA rarely rewards answers that refuse to help, and never rewards answers that make internal audit the owner of risk.

9. Worked Example

Question: The board of a mid-sized company with no formal ERM program asks the CAE to design an enterprise-wide risk strategy. Which of the following is the MOST appropriate response?
A. Decline, because internal audit may not participate in developing ERM.
B. Accept and set the organization's risk appetite as part of the strategy.
C. Accept as a consulting engagement, document the role in the charter, develop the strategy for board approval, and ensure management retains responsibility.
D. Accept and commit internal audit to implementing the risk responses identified.

Analysis: A is wrong because developing a strategy for board approval is a legitimate role with safeguards. B is wrong because setting risk appetite is prohibited. D is wrong because implementing risk responses on management's behalf is prohibited. C is correct: it reflects the consulting nature of the work, the charter safeguard, board approval, and management ownership.

10. Key Takeaways

- Recommending an organizationwide risk strategy is a legitimate consulting role with safeguards, not a core assurance role and not a prohibited role.
- The board approves the strategy and sets the risk appetite; management owns and implements; internal audit advises.
- Safeguards include charter documentation, board approval, management retaining responsibility, treating the work as consulting, time-limiting involvement, and arranging independent assurance over anything internal audit designed.
- On the exam, let the verb and the owner in each option guide you to the answer that preserves independence and objectivity while still adding value.
Test mode:

CRMA - Recommending an Organizationwide Risk Strategy Example Questions

Test your knowledge of Recommending an Organizationwide Risk Strategy

Question 1

Risk management in an organization is informal. Each function handles its own risks, and there is no common methodology or reporting to the board. The audit committee asks the chief audit executive to help move the organization toward an organizationwide approach to risk management. Management will own and run the program. As an advisory engagement, what should the chief audit executive do FIRST?

Question 2

An organization has a board-approved risk management policy, a current risk appetite statement, and a risk register with a named owner for each risk. A risk committee reviews the register quarterly. While planning an advisory engagement, an internal auditor notes that the board approved entry into two new markets last year. The register's top risks are unchanged, and unit risk assessments are prepared only after annual budgets and targets are finalized. Which conclusion BEST supports the auditor's recommendation for improving the organizationwide risk strategy?

Question 3

An organization's divisions each keep separate risk registers that use different likelihood and impact scales. The board reports that it cannot compare or aggregate the organization's top risks. Senior management asks the chief audit executive to recommend how to strengthen the organizationwide approach to risk. Which recommendation is MOST appropriate?

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