Binary Scam Watch Monitor
Auditing vs. Fraud ExaminationIssue Auditing Fraud ExaminationTiming Recurring Nonrecurring
Presumption Professional Proofskepticism
Objective Opinion Affix blameScope General Specific
Relationship Nonadversarial Adversarial
Methodology Audit techniques Fraud examinationtechniques
Defining Occupational Fraud and Abuse
The use of one’s occupation for personal enrichment through the deliberate misuse or misapplication of the employing organization’s resources or assets
Elements of Fraud
A material false statement Knowledge that the statement was false
when it was uttered Reliance on the false statement by the
victim Damages resulting from the victim’s
reliance on the false statement
Opportunity
Pressure Rationalization
Fraud Triangle
corruption, which includes conflicts of interest, bribery (including kickbacks), illegal gifts, and economic extortion;
misappropriation of assets, which includes skimming, larceny, and asset misuse; and
financial statement fraud, which can include financial (either asset or revenue over- or understatements) and non-financial components
An ounce of prevention is better than a ton off treatment
In order to prevent fraud there is a need to make your organization immune against fraud
The means to reduce risk Prevention
Reduce the opportunity for Deterrence (punishment) Detection
Detection of fraud is much more costly
Management has the responsibility and means to implement measures to reduce the risk of fraud Good corporate
governance reduces the risk
Create and Maintain a culture of honesty and high ethics
Evaluate the risk and implement policies, procedures, and controls to mitigate the risk and reduce the opportunity
Develop appropriate oversight processes
Setting the tone at the top
Positive work place environment
Hiring & promoting appropriate employees
Training
Conformation
Discipline
Lead by example (words and actions) Management has to
Behave Ethically Communicate it’s intolerance for dishonest
and unethical behavior Employees must be treated equally with
disregard to position
Set achievable financial goals (not to create undue pressure)
Create a code of ethics and implement itThe code of ethics should be clear,
understandable and developed in a positive participatory manner .
The code of conduct should reflect the core values of the entity and guide employees in
making appropriate decisions during their workday.
The code of conduct might include such topics as ethics, confidentiality, conflicts of interest,
intellectual property, sexual harassment, and fraud.
Employees should be given the opportunity to help in development and updating of code of conduct to create ownership
Employees should be encouraged to report violation of code or wrong doing A hotline (anonymous is preferred to avoid
fear or retribution )
wrongdoing occurs less frequently when employees have positive feelings about an entity than when they feel abused, threatened, or ignored
Without a positive workplace environment, there are more opportunities for poor employee morale, which can affect an employee’s attitude about committing fraud against an entity
Top management that does not seem to care about or reward appropriate behavior
Negative feedback and lack of recognition for job performance
Perceived inequities in the organization Autocratic rather than participative
management
Low organizational loyalty or feelings of ownership
Unreasonable budget expectations or other financial targets
Fear of delivering “bad news” to supervisors and/or management
Less-than-competitive compensation Poor training and promotion opportunities Lack of clear organizational responsibilities Poor communication practices or methods within
the organization
Recognition and reward systems that are in tandem with goals and
Equal employment opportunities Team-oriented, collaborative decision-making
policies Professionally administered compensation
programs Professionally administered training programs at
all organizational levels Career development A good HR Department is instrumental
Hire the best sited for the job
with integrity Equivalence of
effort to reward Promotion biased
on evaluation
When people are under pressure and there is a perceived opportunity some people will behave dishonestly rather than face negative consequences of honest behavior
Conducting background investigations on individuals being considered for employment or for promotion to a position of trust
Thoroughly checking a candidate’s education, employment history, and personal references
Periodic training of all employees about the entity’s values and code of conduct, (training is addressed in the following section)
Incorporating into regular performance reviews an evaluation of how each individual has contributed to creating an appropriate workplace environment in line with the entity’s values and code of conduct
Continuous objective evaluation of compliance with the entity’s values and code of conduct, with violations being addressed immediately
New employees should be trained at the time of hiring about the entity’s values and its code of conduct.
This training should explicitly cover expectations of all employees regarding Their duty to communicate certain matters; A list of the types of matters, including actual
or suspected fraud, to be communicated along with specific examples;
Information on how to communicate those matters.
The training should be at the time of hiring as well as refresher training periodically
Training should be specific to an employee’s level within the organization, geographic location, and assigned responsibilities.
Management needs to clearly articulate that all employees will be held accountable to act within the entity’s code of conduct. All employees within senior management and the finance function, as well as other employees in areas that might be exposed to unethical behavior (for example, procurement, sales and marketing) should be required to sign a code of conduct statement annually, at a minimum.
The way an entity reacts to incidents of alleged or suspected fraud will send a strong deterrent message throughout the entity, helping to reduce the number of future occurrences.
The consequences of committing fraud must be clearly communicated throughout the entity.
A thorough investigation of the incident should be conducted.
Appropriate and consistent actions should be taken against violators.
Relevant controls should be assessed and improved.
Communication and training should occur to reinforce the entity’s values, code of conduct, and expectations.
Fraud can not occur without a perceived opportunity to commit and conceal the act.
Organizations should be proactive in reducing fraud opportunities by (1) Identifying and measuring fraud risks, (2) Taking steps to mitigate identified risks, and (3) Implementing and monitoring appropriate
preventive and detective internal controls and other deterrent measures.
Feed forwardFeed back
inputprocess
outputC
process
inputC
output
Coutputinput
process
Existence of a control even if non- operational can be a deterrent and act as a real control
Audit Committee or Board of Directors
Management Internal Auditors Independent Auditors Certified Fraud Examiners
To monitor compliance with laws Integrity of financials Asses external auditor qualifications &
independence Follow up on internal audit