Yeah, lots of good conversation on steps to take. One thing I never see mentioned is who should review and test them. Especially for a financial company, it seems they have no IT compliance/audit functions. Even at many big companies it seems IT control creation, maintenance, and testing is largely ignored or just put onto the people implementing and performing the control - a huge conflict of interest. Control analyst posting are something like 1 to 10K when measured against dev postings. Really telling when it comes to what companies actually care about...