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Since the Global Financial Crisis of 2007–09, the design and implementation of internal control systems has attracted serious academic and professional attention. Despite these efforts, there has been little systematic analysis of how to design an internal control system that does not affect the efficiency and effectiveness of corporate governance processes, especially at financial institutions such as banks. The “three lines of defense model” has been used traditionally to model the interaction between corporate governance and internal control systems. In this paper, authors consider that the existing three-lines-of-defense model can be substantially enhanced by giving it a specific focus on the supervision of banks; thus, they address this deficiency by proposing a more effective internal control model outlining a “four lines of defense” model that endows supervisors and external auditors, who are formally outside the organization, with a more specific role in the organizational structure of the internal control system.
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