Creating SOD matrix with the help of Access control default ruleset

I am creating the SOD matrix for the existing roles of CRM and HR modules.  As I am the security consultant therefore does not have the functional knowledge about the conflicts for CRM and HR transactions. My question is can I use the function/actions/risks conflicts provided with the Access control 5.3 default ruleset.  We are not using Access control for these systems, so I want to know whether I can take the help of AC 5.3 default risks to create the SOD matrix based on it.
For e.g, like H001 default HR risk, I would make sure not to assign PA30(maintain HR data) with the PA03/PA04(maintain personal control record) as this will result in the providing conflict "Modify payroll master data and then process payroll". 
Once I have the SOD list based upon AC 5.3, I can consult the Business approver/auditor to verify and modify as per the business requirement.
Maybe I am thinking the wrong way, please provide your inputs so I can work on it.  Any help appreciated.
Thanks,
Sanjay Desai

The most important thing to keep in mind is that you need to build a rule set that reflects the customers real business risk!
What you build there will influence the way the customer will be able to continue work, assign access and perform control activities. The input HAS to come from the business!
You can use the SAP standard risk definitions as a starting point for discussions, and the HR functions are an excellent building block to identify the transactions and necessary authorization objects that allow users to perform the actions.
But the real challenge is to identify the risks as perceived/accepted by the business!
Frank.

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