Mitigation Controls in SAP® GRC
Managing Unavoidable Risks
In an ideal world, every Segregation of Duties (SoD) conflict or critical access risk would be eliminated by redesigning roles and removing access. However, business reality often requires that certain users retain risky access to perform their jobs effectively.
This is where Mitigation Controls within SAP® Governance, Risk, and Compliance (GRC) become essential. They are the cornerstone of a pragmatic and balanced risk management strategy.
What Are Mitigation Controls?
A mitigation control is a detective or preventive procedure that reduces the risk associated with a user’s access to an acceptable level. Instead of removing the access (the risk itself), you implement a safeguard that monitors or prevents the misuse of that access.
Think of it like this:
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Removing access: Taking away the keys to a secure room.
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Mitigation control: Installing a surveillance camera in the room and requiring a logbook for entry while allowing the person to keep the keys.
How They Work in the SAP GRC Framework
Mitigation controls are a core function of the SAP GRC Access Control module. The process is integrated and streamlined:
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Risk Identification: The system identifies a SoD conflict or critical access risk for a user during a access review or role assignment.
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Decision Point: The business owner decides the risk cannot be removed for operational reasons.
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Control Assignment: One or more mitigation controls are assigned to the specific risk-violating access combination for that user.
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Risk Reduction: The GRC system recalculates the user’s risk score. A effectively designed and tested control can reduce the risk of a “High” severity conflict down to “Low” or even “No Risk.”
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Ongoing Monitoring: The control itself must be tested periodically (e.g., quarterly, annually) to ensure it is operating effectively. This is a key function of the SAP GRC Process Control module.
Types of Mitigation Controls
Mitigation controls generally fall into two categories:
1. Detective Controls
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Purpose: To discover a malicious or erroneous action after it has occurred.
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Examples: Regular review of transaction logs, automated reconciliation reports, manager approval of specific journal entries, periodic audits of sensitive transactions.
2. Preventive Controls
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Purpose: To stop an inappropriate action before it is completed.
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Examples: Dual approval workflows for payment runs, system-based validations that block posting to a closed fiscal period, physical supervision for certain activities.
Best Practices for Effective Mitigation
| Best Practice | Description | Why It Matters |
|---|---|---|
| Be Specific | Link the control directly to the exact risk. A control for “prevent fraud” is useless. A control for “Manager reviews all journal entries over $50k posted by Accountant X” is effective. | Ensures the control actually addresses the vulnerability and is actionable. |
| Avoid Over-Reliance | Mitigation should not be the first option. Always explore removing the risk first. A landscape flooded with controls is inefficient and hard to manage. | Prevents “control fatigue” and maintains a cleaner, more secure access model. |
| Regular Testing | A control that is not tested is not trusted. Use SAP GRC Process Control to automate the testing schedule and evidence collection. | Provides assurance to internal and external auditors that the risk is truly managed. |
| Clear Ownership | Every control must have a single, clearly defined business owner responsible for its execution and effectiveness. | Eliminates ambiguity and ensures accountability within the business, not just IT. |
| Automate Where Possible | Leverage automated workflows, reports, and system configurations as controls instead of manual checks. | Increases reliability, reduces effort, and provides a clearer audit trail. |
The Integrated GRC Advantage
The true power is realized when SAP GRC Access Control and Process Control work together:
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Access Control identifies the risk and assigns the mitigation control.
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Process Control manages the entire lifecycle of that control: documenting its procedure, scheduling tests, collecting evidence, and reporting on its effectiveness to management and auditors.