SOC 2 (2017 TSC) CC3.3 — Fraud Risk Assessment

What this control requires

The entity considers the potential for fraud in assessing risks to the achievement of objectives.

In plain English

The entity considers the potential for fraud in assessing risks to the achievement of objectives. In practice, this means you can prove you risk objectives-level controls on a defined cadence.

Why it matters

Every SOC 2 audit opinion is built control-by-control from the Trust Services Criteria. A missing or failing criterion produces an exception in the report, which buyers, partners and procurement teams read line-by-line during vendor reviews.

This control is rated high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.

What an auditor looks for

A SOC 2 auditor (under AT-C §§ 105/205) tests both design and operating effectiveness over the audit window. For each criterion they expect a written control, a control owner, a population of events, and a sample tested against the population — including remediation tickets for exceptions.

Within Common Criteria (Security), the assessor will trace your implementation back to the catalogue reference (Criterion CC3.3) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Vulnerability Management

Scanners. Pair an unauthenticated scanner (Nessus / Qualys / Tenable.io) for external surface with an authenticated agent for OS/library CVEs on every host.

SLA. Document remediation SLAs by CVSS / EPSS: critical 7 days, high 30 days, medium 90 days; report monthly trend to leadership.

Containers. Scan images in CI (Trivy / Grype / Snyk Container) AND at runtime; block deploys on critical findings without exception.

Operational checklist

• Risk. Document the trigger, the owner and the cadence.
• Fraud. Document the trigger, the owner and the cadence.
• Security. Document the trigger, the owner and the cadence.
• Management. Document the trigger, the owner and the cadence.
• Scope: objectives, risk assessment, management.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Signed policy or standard documents the safeguard. Focus: Fraud Risk Assessment.

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
• Scans that hit only the perimeter; missing authenticated scans of OS, runtime libs and base images so most CVEs are invisible.

How it maps to other frameworks

Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.

• NIST SP 800-171 Rev. 3 3.12.1 — Security Assessment
• ISO/IEC 27001:2022 A.8.8 — Management of technical vulnerabilities
• HIPAA (45 CFR Part 164) 164.308(a)(1)(ii)(B) — Security Management Process - Risk Management
• NIST SP 800-53 Rev. 5 CA-7(1) — Independent Assessment
• CIS Controls v8 7.1 — Establish and Maintain a Vulnerability Management Process

Related controls in SOC 2 (2017 TSC)

• Criterion CC3.1 — Objective Setting
• Criterion CC3.2 — Risk Identification
• Criterion CC5.2 — Technology Control Activities to Support Objectives
• Criterion CC2.2 — Internal Communications
• Criterion CC5.1 — Control Selection and Development
• Criterion CC2.3 — External Communication on Internal Control Matters

References

• AICPA / ASEC — SOC 2 (2017 TSC)
• Catalogue identifier: Criterion CC3.3

Topics: governance riskpolicy managementvulnerability management