CC3.3: Fraud risk

The risk assessment specifically considers how someone inside or outside the company could commit fraud, including misuse of privileged access or manipulation of data.

Category: Security (common criteria, required in every SOC 2 report) · Series: CC3 (Risk assessment) · TSC 2017 (2022 points of focus)

That summary is Policyseed’s own paraphrase, written to be read next to the policy sections below. The authoritative wording is the AICPA’s Trust Services Criteria, which the CPA firm tests your controls against during the examination.

Policies that address CC3.3

The Policyseed crosswalk points CC3.3 at 3 policies. Each link opens the full sample text at the section an auditor would read. Section 4 holds the statements management commits to; section 5 holds the procedures that produce evidence.

P03 Access Control Policy, section 4 (Policy Statements). Owner: Security Owner.
P17 Risk Assessment and Management Policy, section 4 (Policy Statements). Owner: Security Owner.
P18 Human Resources Security Policy, section 4 (Policy Statements). Owner: People/HR Lead.

Evidence examples for CC3.3

Artifacts a company of 5 to 200 people can realistically produce. The Audit Kit’s evidence checklist lists them per policy with an owner column so each one has a name against it before the examination.

Risk register entries tagged as fraud or insider-threat risks with their treatments
Segregation-of-duties statement in the Access Control Policy and a screenshot showing production deploys require a second approver
Background check policy statement and completion records for roles with privileged access

Related criteria in CC3 (Risk assessment)

Previous: CC3.2 Identifying and analyzing risks. Next: CC3.4 Changes that affect risk. All 38 criteria are listed on the template index.

Policyseed provides governance policy templates and AI tailoring. It is not legal advice and not a compliance guarantee. Management adopts the policies; the CPA firm performs the SOC 2 examination.