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Most of the bad paths are usually taken by engineers with little or no experience being audited. After going through the ringer a few times (learn not to answer questions that aren't asked, or that they have a say in what that control should be) the pendulum swings in the other direction, where the answers are always good-path, not necessarily the real-path. At least until the practical part of the audit starts to look at what they really do, not what they say they do.

There's another giant pothole to navigate in many organizations, related to this:

> when they could have just said (...) and leaned on the fact that auditors expect management to make risk assessments

When management has decision paralysis and fear of accountability the engineers feel the need to compensate for the tight spot and solve problems the way they know how to solve them. With technical measures. And a technical measure that fixes the organizational problem tends to be complex and fidgety. Doubly hard for the auditors to properly take in.



“Management” here is a term of art. For many compliance regimes and controls, the engineer responsible for a system can make a statement as “management”.




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