Designing Controls Where Compliance Is an Afterthought

Key Takeaways

• Compliance-First Control Design Creates Security Theatre: Controls optimized to satisfy audit requirements often generate evidence without meaningfully reducing real security threats or business risk.
• Risk- and Security-Driven Controls Flip the Priority: When controls are designed around actual threats and material business risks, compliance becomes a natural byproduct rather than the primary objective.
• Evidence Should Come From Operational Security Systems: Effective GRC programs rely on real-time data from systems like SIEM, vulnerability management, and identity platforms, not manual documentation built solely for audits.
• Control Effectiveness Matters More Than Control Existence: Integrated GRC testing focuses on whether controls prevent attacks and reduce business impact, not just whether they are formally in place.
• One Strong Control Can Satisfy Multiple Frameworks: A common controls approach allows organizations to map a single, well-designed security control to multiple regulatory and assurance requirements.

Deep Dive

In this latest article, Ayoub Fandi dissects a familiar but rarely challenged flaw in many GRC programs: controls designed to satisfy auditors first and protect the business second. Drawing on real-world examples from access management, vulnerability management, and application security, Fandi argues that compliance-driven control design too often results in security theater and controls that generate clean audit evidence while leaving real risks untouched. He makes the case for flipping that priority, showing how controls built around actual threats and business risk naturally produce compliance as an outcome, not an objective.

Why Compliance-First Control Design Produces Audit Evidence Instead of Real Protection

Most controls are designed to satisfy auditors first, and protect against real risks second. This backwards approach is why your GRC program feels like security theatre. The best GRC programs design controls that happen to satisfy compliance requirements, not controls that exist to satisfy compliance requirements.

What’s the difference?

• Compliance-driven controls ask: “What does the framework require?”
• Risk and security-driven controls ask: “What threats and business risks does this actually mitigate?”

The magic happens when you flip this priority. When you design controls to address real security threats and business risks, compliance becomes a natural byproduct instead of the primary objective.

Your organization rewards compliance theater because that’s what you’ve optimized your controls to deliver. Ready to build controls that actually defend and protect?

Why It Matters

Most GRC professionals are trapped in what I call the Compliance-First Control Design Trap. You’re excellent at creating controls that pass audits:

• Policies that check boxes
• Procedures that generate evidence
• Monitoring that produces screenshots

But your controls optimize for audit satisfaction, not threat prevention and business risk reduction.

The Control Design Crisis

This gap shows up repeatedly in real environments.

• MFA implementation: Marked as “enabled” in SSO settings.
  Reality: VPN access, legacy systems, and service accounts bypass it entirely.
• Access reviews: Quarterly sign-offs are completed.
  Reality: Critical privileged access goes unreviewed for more than eight months.
• Vulnerability management: Weekly scans are running.
  Reality: Forty-seven critical vulnerabilities are “accepted” due to business justification.
• Application security: A WAF is deployed and monitoring.
  Reality: Monitor-only mode prevents zero attacks.
• Code security: SAST is embedded in the CI/CD pipeline.
  Reality: One hundred twenty-seven critical findings are marked “will not fix.”

The strategic problem is clear. When compliance drives your control design, you optimize for audit evidence instead of threat prevention.

This isn’t about abandoning compliance. It’s about building integrated GRC systems that naturally produce compliance while actually defending against real threats and business risks.

Strategic Framework

The philosophy shift is simple. Design controls based on what actually threatens your business, not what frameworks require.

• Traditional approach:
  Read SOC 2 requirement → design controls → hope it helps → generate audit evidence.
• Integrated GRC approach:
  Analyze real threats → design protective capabilities → validate effectiveness → compliance naturally follows.

The insight that changes everything is this: attackers don’t read your compliance framework. They exploit gaps in your actual defenses.

The Control Design Hierarchy

Stop building controls that optimize for the wrong outcome.

• Threat prevention controls: High effort to build, low effort to evidence, maximum business protection.
• Risk reduction controls: Medium effort to build, low effort to evidence, high protection.
• Risk visibility controls: Medium effort to build, high effort to evidence, moderate protection.
• Compliance theatre controls: Low effort to build, high effort to evidence, minimal protection.

The best programs invest in threat prevention and risk reduction controls that naturally generate evidence, not compliance documentation that hopes to prevent threats.

Common Controls Framework Implementation

Instead of implementing “SOC 2 controls” and “ISO 27001 controls,” implement your security baseline and map it to whatever frameworks you need.

The breakthrough is where evidence comes from:

• SIEM platforms
• Vulnerability scanners
• Identity and access management systems

These systems serve operational security decisions and compliance requirements at the same time.

One control design can satisfy multiple frameworks.

Execution Blueprint

Step One: Control Security and Risk-Alignment Audit

Before redesigning controls, understand whether your current controls actually prevent threats and reduce business risks, or simply satisfy audit requirements.

Ask the following:

• What is the primary design driver?
  Framework requirements, or threat prevention and business risk reduction?
• How is success measured?
  Audit finding closure, or security incidents prevented and risk impact reduced?
• Where is evidence collection focused?
  Documentation completeness, or security effectiveness and risk reduction validation?
• What motivates the control owner?
  Avoiding audit findings, or preventing threats and reducing exposure?
• What drives implementation priority?
  Auditor satisfaction, or threat elimination and risk governance?

Scoring zero to two responses indicates controls optimized for auditors. Three to four indicates a transition toward integrated GRC design. Five indicates controls that naturally defend, govern risk, and enable compliance.

Step Two: Integrated Threat and Risk-to-Control Design

Transform your control design methodology from compliance-driven to security- and risk-driven through three phases.

• Phase one: Document realistic security threats and material business risks, map likely scenarios and potential impact, and analyze threat-risk interdependencies and cascade effects.
• Phase two: Design controls that prevent threats from materializing, reduce business exposure, create monitoring for early warning and decision support, and validate effectiveness through security testing and business impact measurement.
• Phase three: Align controls through a Common Controls Framework approach by mapping security and risk controls to required frameworks. Data sources become security-driven rather than compliance-driven, pulling real-time metrics from SIEM platforms, vulnerability scanners, and identity systems that support both operations and evidence generation.

Step Three: Integrated Security and Risk-Informed Control Testing

Traditional control testing asks whether a control exists. Integrated GRC testing asks whether the control prevents threats and reduces the business risks it was designed to address.

• Access control: Not whether MFA is enabled, but whether access management prevents unauthorized access and reduces insider risk.
• Vulnerability management: Not whether scans run weekly, but whether exploitable attacks are being prevented and operational risk reduced.
• Data protection: Not whether an encryption policy exists, but whether sensitive data is protected from threats and breach-related business risk.
• Business continuity: Not whether a disaster recovery plan is documented, but whether operations can be maintained during attacks and disruptions.
• Monitoring and detection: Not whether logs are collected, but whether security threats and business risk indicators are detected in time.

Your turn. Look at your three most critical controls right now. If an attacker wanted to compromise your organization, would those controls actually stop them, or would they just generate good audit evidence while the attack succeeds?

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