- Before
- Plans testing with the external auditor and answers to the CAE, while finding out late which risk has no control.
- Now
- Decides each gap with the evidence and its exposure in front of her, and signs a version only when every row is confirmed.
One process, from walkthrough to signed RCM
Kestrel & Vane Distribution US moved to a new ERP on 1 Sep 2026. Five of its SOX processes must be documented again before Q4 interim testing starts on 2 Nov, and the first is order-to-cash. The SOX program manager works with the agents the way she would with a team: they report what they drafted and found, she asks and instructs in plain words, and every answer shows its evidence. Here it is, screen by screen, in the working solution.
- 01Wednesday morning
Four plain numbers, and the agents reporting in
Claire Okafor · Group SOX Program ManagerClaire opens Today: 3 gaps to decide, 2 rows waiting for the process owner, 4 changes proposed and 31 of 38 RCMs approved for FY2026. Below the numbers the agents post what they finished and what needs her, each message with its next step: the drafted order-to-cash matrix, a high gap over manual credit memos, Marcus Lindqvist's confirmations and four proposed changes. Beside the thread she asks the agents anything — “Why is O2C-02 low confidence?” — or tells them what to do.
Watcher agent: “I drafted each redline; none is applied.”
- 0211 min 20 s after the walkthrough
A full RCM draft, and every field cites its moment
Matrix agent, with the narrative and flow agentsWalkthrough WT-26-031 ran 45:12 with six people, consent read at 00:00, transcript quality 96%. From it, five documents and the ERP configuration, seven agents drafted a 6-page narrative, a 9-step flow and RCM v3.0: 11 risks, 14 controls, 9 of them key. Claire clicks the ▶ 12:41 chip on O2C-04 and the transcript jumps to Julia Meyer describing the credit check.
Julia Meyer at 12:41: “When the order is entered, the system checks the customer’s credit limit and blocks the order if it would take them over.”
- 03Before anyone confirms
A second agent disputes a description that can't be tested
Challenger agentThe matrix agent wrote O2C-10 as “Weekly, the Head of Order-to-Cash reviews unapplied cash.” The challenger agent disagrees: no report, no age, no evidence of the review. It proposes a precise wording from the walkthrough at 34:10 and the SOP. The matrix agent explains why it kept the SOP wording. Both reasonings are on screen, and a person chooses.
The challenger agent never resolves its own disagreement and never edits a row.
- 04In the narrative
Conflicts marked, rewrites shown as redlines
Narrative agentThe narrative has seven sections, every paragraph cited, and three conflicts marked where what people said differs from what is written: the change-log review, who can release credit holds, and manual credit memo approval. Asked to make §5 shorter, the narrative agent shows a redline that keeps every citation, for the reviewer to accept or reject.
“Said ≠ written · Walkthrough and system: no approval enforced. SOP-O2C-03 §5.2: workflow approval above $10,000. Gap G1.”
- 05The flowchart
Nine steps in six swimlanes, with the gap on the map
Flow agentThe flow agent draws the process from the narrative: credit, customer service, warehouse, billing, accounts receivable and the ERP, with risk and control markers at each step. Step 7, manual credit memos, carries the gap marker. Clicking it shows risk R-O2C-08, the narrative passage behind it and the plain note: no control at this step.
- 06Said, written, configured
Three sources disagree about manual credit memos
Gap agentOf the group risk library's 27 order-to-cash risks, 11 apply and 10 are covered. Gap G1 is high: nothing covers unauthorised or inaccurate manual credit memos. The SOP requires Credit Manager approval in the ERP workflow above $10,000; the workflow WF-CM-01 covers return credit memos only, and manual billing adjustments post with no workflow. The cause: the legacy control over all credit memos was retired at go-live.
Tom Becker at 31:40: “Anything over ten thousand we e-mail Julia for an OK, but honestly the system doesn’t stop it. We can post it ourselves.”
- 07Claire decides
A new control, an interim review and a reason code
Claire Okafor · Group SOX Program ManagerThe gap agent sized the exposure from the ERP, read-only: 41 manual credit memos above $10,000 since go-live, $1,186,420, 12 with no approval e-mail found. The challenger re-ran the query blind and agrees. Claire decides with reason code GAP-NEW: new key control O2C-15, built by change CHG-26-0871 for 2 Nov, and interim O2C-15i, a weekly review by Julia Meyer from 19 Oct with a look-back over the 41. She refers it to SOX Control Testing as a potential design deficiency.
“Decision recorded · O2C-15 and O2C-15i added to the draft as proposed rows.”
- 08Due Fri 16 Oct
The owner answers in plain words, not in a matrix
Marcus Lindqvist · Head of Order-to-CashMarcus gets one question per row, with the clip of what was said. He has confirmed 11 and corrected one: the shipped-not-billed review covers items over $5,000. On O2C-13 he answers “No”: IT owns the quarterly access review. The matrix agent turns his words into a redline — owner Victor Hale, ERP Application Lead — citing his answer as the source, for him to confirm.
Marcus: “IT owns it. Victor Hale’s team runs the review every quarter and removes access; I only confirm the billing users.”
- 09A policy changes
The matrix keeps up, and nothing changes without her
Watcher agentCredit Policy CP-07 v5, effective 1 Nov, moves Division Controller approval of credit limits from $250,000 to $500,000 and lets credit analysts release holds only up to $25,000. The watcher agent drafts the redline for O2C-01 and O2C-05 and the impact on Q4 testing. It also flags that Tom Becker moves to Logistics Planning on 1 Nov, leaving O2C-07 without an owner.
“Accept into the draft · Reject · Ask about it.”
- 10Signed
Approval only when everything is true
Claire Okafor · Group SOX Program ManagerVersions compares v3.0 with v2.4, approved 12 Jan 2026, field by field. Approve unlocks only when every row is confirmed by the owner, every gap is decided with a reason code, every challenger note is resolved, every row has a source and the preparer and approver differ. Claire picks the reason, ticks the attestation and signs with her name.
“I have reviewed the narrative, the flow, the matrix and each gap decision, and I approve this version as management’s documentation of the process.”