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    Over the last fewyears, attentionhas been

    focused on large cor-porate frauds resultingfrom cash manage-ment systems devoidof adequate controlsand governance func-tions. Fraud is a prob-lem to some degree inall organizations

    whether large or small,profit or nonprofit,public or private. TheAssociation of Certi-fied Fraud Examiners(ACFE) estimatesannual business fraudloss to exceed $650billion.1 Approximatelyhalf of all frauds occur in smallbusinesses, and the impact isoften devastating. The ACFE2006 Occupational Fraud Survey

    found the average loss in smallcompanies per fraud scheme was$190,000, greater than the aver-age loss in any other business-size category.2

    Most experts agree thatfraud generally starts small,even in large corporations. Forthis reason, all organizations

    can benefit from sharpeningtheir fraud detection and pre-vention practices regardingtheir cash management sys-tems. Since most instances of

    fraud start small, this articleexamines five cases of fraud ofsmaller proportion that couldlead to large cash losses andoffers advice for management,board members, and auditorsfor detecting and preventingsuch fraud practices in thefuture.

    COMPONENTS OFFRAUD

    In order to under-stand why peoplecommit fraud, it isuseful to examine thethree components offraud: incentive (pres-sure), opportunity, andrationalization.3 It isgenerally felt that allthree components arenecessary to perpe-trate fraud but mayvary in magnitudedepending on theorganization, environ-ment, and perpetrator.

    The first compo-nent of fraud is incen-

    tive or pressure to commit afraud. Pressures may be finan-cial, such as ones mortgagepayments, medical bills, and

    education costs, or nonfinancial,such as the need to concealones mistakes or errors, jobdissatisfaction, or pressure fromothers. In todays economy, pres-sure may represent the mostpervasive component of fraud.While its hard to predict thelevel within the organization

    Over the past few years, the spotlight has been on

    large corporate frauds. These resulted from cash

    management systems devoid of adequate controls

    and governance.

    But about half of all frauds occur in small

    businessesand the effect is often devastating.

    The average loss for any small business fraud

    scheme was found to be greater than in any other

    business-size category.

    Since fraud generally starts smalleven in

    large companieseveryone can benefit from

    sharpening their cash management fraud preven-tion. This article examines five cases of smaller

    frauds that could lead to large cash losses. And

    the authors give advice on how to better detect

    and prevent such frauds in the future.

    2008 Wiley Periodicals, Inc.

    feature

    ar

    tic

    le

    37

    2008 Wiley Periodicals, Inc.Published online in Wiley InterScience (www.interscience.wiley.com).

    DOI 10.1002/jcaf.20449

    Prevent Large Cash Losses from SmallBusiness FraudLeigh Redd Johnson and Holly R. Rudolph

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    this component impacts themost, the ACFE 2006 Surveyreveals that 41.2 percent offrauds are committed byemployees, 39.5 percent bymanagers, and only 19.3 percent

    by owners/executives,4

    suggest-ing that employees and man-agers might be more responsiveto this component of fraud thanexecutives and owners.

    The second component offraud is opportunity to commitfraud. Organizations have morecontrol over this component offraud than the other two compo-nents. Opportunities to commitfraud range from an insufficientinternal control structure to lax

    business practices. Both lower-level employees and top manage-ment may find opportunity tocommit fraud, but not alltake advantage of thesecircumstances. The ACFE2006 Survey found thatowners/executivesaccounted for less than20 percent of the numberof frauds, but their medianloss in a fraud scheme was$1 million, while employees

    and managers accounted for over80 percent of the number offrauds, but their median loss ina fraud scheme ranged from$78,000 (employees) to $218,000(managers).5 These statisticssuggest that while opportunity tocommit fraud exists at all organi-zational levels, the greatestimpact is at the owner/executivelevel, where management oftenhas the ability to override inter-nal controls.

    The third component offraud is rationalization, or theability of individuals who com-mit fraud to justify their actions.As pressure and opportunity tocommit fraud increase, rationali-zation may become easier.Rationalization is generallypresent in initial frauds but may

    dissipate as other frauds arecommitted. Employees mayhave little difficulty in rational-izing their actions to commitfraud in todays economy. Whilesome fraudsters justify their

    actions based on personal orfamily needs, others justify theiractions based on perceived orga-nizational misdoing. Similar tothe first component of fraud,organizations often do not havecontrol over this component ofthe fraud process, but maintain-ing open communication linesmight help thwart the impact ofthis component.

    Since opportunity is thecomponent of fraud that organi-

    zations have the most controlover, the following five casesare presented to show how this

    component of fraud can impactsmall as well as large organiza-tions. Exhibit 1 includes a sum-mary of each case with sug-gested fraud detection andprevention strategies.

    OPPORTUNITY NUMBER 1:DIVERTING CORPORATE FUNDS

    Auburn Professor Case Study

    By the time that LoydLawing Jr., a former Auburnprofessor, pled guilty to embez-zlement earlier this year, he hadtaken over $900,000 from thelocal chapter of Alpha TauOmega, a social fraternity.6 Theprofessor was able to divert fra-ternity funds from local banks tohis personal and corporate

    accounts for approximately threeyears before his actions weredetected because he served mul-tiple key roles for the fraternity:chapter advisor, secretary, andtreasurer. Consequently, Lawing

    had unlimited and unrestrictedaccess to the significant amountof cash in the fraternitys bankaccounts, which was derivedfrom the sale of the fraternitysbuilding and various donationsto the organization.

    The diverted funds wereused to purchase a luxury vehi-cle, as a substantial down pay-ment for a new house, and tosupport a struggling corpora-tion where Lawing served as

    president and chief operatingofficer. When fraternity boardmembers questioned Lawing

    about the status of the fra-ternitys cash accounts,Lawing assured boardmembers that the fundswere being invested inseveral vehicles, includingCDs, money marketaccounts, and fraternitytrusts.

    Preventing the Fraud

    Separating the duties ofthose who are authorized toaccess cash accounts and thosein charge of recordkeeping canhelp an organization avoid a lossof cash assets like the fraternityexperienced. Furthermore,requiring an independent reviewof corporate accounts by some-one who is removed from theday-to-day cash transactions canreveal systemic abuses by com-pany insiders. As noted above,Lawing was able to divert fundsfor his personal use due to thelack of internal controls. Aschapter advisor, secretary, andtreasurer, he had the ability toauthorize the distribution of thefraternitys cash, as well as

    38 The Journal of Corporate Accounting & Finance / November/December 2008

    DOI 10.1002/jcaf 2008 Wiley Periodicals, Inc.

    Both lower-level employees and top

    management may find opportunity to

    commit fraud, but not all take

    advantage of these circumstances.

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    oversight of the fraternitys cor-porate records. If the fraternityhad separated the functions ofadvisor, secretary, and treasurer,it is less likely that Lawingwould have been able to divertthe funds. Additionally, a ran-dom external review of the fra-

    ternitys accounts by an inde-pendent party could havedetected the fraud and possiblyprevented it from advancing asfar as it did.

    A sound corporate gover-nance structure also is a keycomponent of eliminating cer-

    tain opportunities for cashfraud. While it is illogical forboard members to reconcile allrecords related to cash, it isimperative for corporate (or, inthis case, nonprofit) boardmembers to require some inde-pendent verification of major

    The Journal of Corporate Accounting & Finance / November/December 2008 39

    2008 Wiley Periodicals, Inc. DOI 10.1002/jca

    Summary of Cases and Suggested Detection and Prevention Strategies

    Auburn Professor Case Study Separate duties of those authorized to access cashand those in charge of recordkeeping.

    Require an independent review of corporate

    accounts.

    Implement a sound corporate governance structure

    with appropriate oversight of major transactions.

    Periodically review documentation related to invest-

    ments.

    Funeral Home Case Study Review suspicious activities that involve multiple

    accounts in a short time period.

    Require two signatures on checks over a certain

    amount.

    Confirm closed accounts with customers.

    Conduct fraud detection training.

    Fast-Food Case Studies Require management and/or technological oversight

    of employees who handle cash.

    Review sales records for irregularities.

    Institute mechanisms whereby employees, cus-

    tomers, and/or suppliers can report employee fraud.

    Centrally locate cash registers.

    Longshoreman Case Study Periodically distribute payroll checks/stubs to verify

    legitimate employees.

    Reconcile payroll records with employee payments.

    Review corporate policies or external factors that mayencourage employees to commit payroll fraud.

    Conduct surprise audits of payroll accounts.

    Financial Institution Case Study Review expense reports/reimbursement requests for

    employees when such reports/requests are dispro-

    portionate to similarly situated employees.

    Hire an external auditor to review expense accounts.

    Utilize tip lines to report expense account fraud.

    Require appropriate documentation for reimburse-

    ment of business expenses.

    Exhibit 1

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    transactions, especially whenthere may be a lack of separa-tion of duties at the manage-ment level. Although fraternityboard members did questionLawing regarding the status of

    the cash assets, they did notrequire independent verificationof Lawings statements regard-ing the investments of the fra-ternitys cash. A simple requestby board members for docu-mentation relating to the invest-ments may have prevented thecash fraud.

    OPPORTUNITY NUMBER 2:FALSIFYING ACCOUNTRECORDS

    Funeral Home Case Study

    When Paul Stella wassentenced to more thanfour years in prison inFebruary of this year, hehad spent over $925,000of client funds for per-sonal gain.7 The formerfuneral director used twoschemes to facilitate alavish lifestyle of gambling

    and extravagant vehicles, homeimprovements, and vacations.In the f irst cash-fraud scheme,Stella entered into contractswith individuals whereby heagreed to safeguard prepaidfuneral expenses by holdingadvance funds in trusts.Instead, he used the funds forpersonal gain. In the secondcash-fraud scheme, Stellaraided bank accounts estab-lished by the former funeralhome director that held prepaidfuneral expenses. Specifically,he falsified customer letters tothe bank where the customeraccounts were held requestingthat the institution close theaccounts. The bank then issuedchecks to the clients, whichStella fraudulently endorsed

    and placed into his personalbank accounts.

    Preventing the Fraud

    While separation of duties

    and an independent review ofcorporate accounts may haveprevented the fraudulentscheme in the Auburn professorcase, these steps are unlikely tobe implemented in a situationsimilar to this one where theperpetrator also is the owner/manager/director. However, thebanks that accepted the phonyletters and the forged checksalso played a role in the fraud.Thus, the clients were not the

    only victims in this crime; byaccepting phony letters andforged checks, the banks may

    have exposed themselves toliability.

    This fraud may have beenprevented if the bank thataccepted the phony letters hadinstituted policies requiringreview of the closing of multi-ple third-party accounts by afiduciary. The sheer number ofrequests (111) should havealerted bank employees that theactivity was suspicious. Fur-thermore, the fraud may havebeen prevented if the banksthat accepted the forged checkshad conducted specializedtraining for bank employees tolook for common signs offorged checks. Here, multipledeposits of third-party payeechecks by a fiduciary into apersonal account may have

    served as a red flag for bankemployees.

    OPPORTUNITY NUMBER 3:REGISTER DISBURSEMENTS

    Fast-Food Case Studies

    Skimming cash at the pointof entry into a business is oneof the most common types ofcash fraud. In recent years, thefast-food industry has seen aninflux of these types of schemeswhereby employees directlytake cash from the registerthrough the fraudulent use ofcustomer credit cards.

    In the first case, a McDonalds

    employee legitimately swiped acustomers credit card in pay-ment of the customers order.8

    The employee thenallegedly swiped the carda second time for thesame amount and pock-eted that amount of cashfrom the register. Thescheme was detected whena customer noticed thedouble charge on theirbank statement and com-

    plained to the company.In the second case, a Taco

    Bell employee swiped a cus-tomers credit card a second timefor an additional $20 or $30 afterthe card had been swiped for thecorrect amount.9 The employeemaintained that he only addedthe additional charge to punishcustomers whom he consideredrude and that he did not appro-priate cash representing the addi-tional charge from the register.However, the company noted thatall cash and credit receipts wereconsistent with sales and that ithad not received additional fundsrelated to the scheme, indicatingthat the employee kept the cash.The scam was revealed when theemployees manager reported theillegal transactions to the police.

    40 The Journal of Corporate Accounting & Finance / November/December 2008

    DOI 10.1002/jcaf 2008 Wiley Periodicals, Inc.

    A simple request by board mem-

    bers for documentation relating to

    the investments may have pre-

    vented the cash fraud.

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    In another case, a Wendysemployee swiped customerscredit cards for food-relatedcharges.10 The employee thenallegedly used a handheld scan-ner to record the credit card

    numbers and expiration dateswhere she could download thenumbers on dummy cards forpersonal use at a later time. Thescam was detected when a con-sumer noticed unauthorizedcharges to her account.

    Preventing the Fraud

    In each of these cases, alack of supervision directlycontributed to the employees

    opportunity to skim cash. If anemployee perceives that hisactions will go unmonitored, heis more likely to partici-pate in cash fraud. Com-panies should properlysupervise lower-levelemployees, whether bymanagement or techno-logical oversight, toreduce the risk of cashfraud. In addition, man-agement could have

    detected the cash-fraudschemes in the McDonalds andTaco Bell cases by reviewingsales records for irregularities.Multiple entries for duplicatecharges should serve as awarning signal for managementand require additional investi-gation.

    Finally, companies shouldimplement mechanisms thatencourage employees and cus-tomers to report fraudulentactivities. According to theACFE, tips from employeesand, arguably, consumers, arethe number-one method bywhich cash fraud is detected.11

    In each of the fast-food casesnoted above, the fraudulentschemes were eventuallyexposed by fellow employees

    or by customers who had beendefrauded. Companies whohave ethics hotlines or opportu-nities for employee and con-sumer complaints are morelikely to receive information

    pertaining to corporate cashfraud.

    OPPORTUNITY NUMBER 4:PAYROLL FRAUD

    Longshoreman Case Study

    In May 2008, a Massachusettslongshoreman, Joseph J. PicardJr., pled guilty to chargesrelated to his involvement in afraudulent payroll scheme.12

    Picard was a senior longshore-man and head walking boss at aBoston terminal, where he

    supervised the loading andunloading of container ships.Allegedly, Picard was involvedin a scheme where senior long-shoremen put their children onthe payroll. The scheme was anattempt to place the children ina position to reap union andwage benefits, in the event thatthey eventually became long-shoremen.

    While other senior long-shoremen are under investiga-tion for their involvement in thescheme, Picard pled guilty toforging timesheets for his oldestson, garnering approximately$12,000 in one year for wagesthe son did not earn. In fact,since the son was attending col-lege, he could not have physi-cally worked some of the

    reported time. Picard alsoadmitted to recording threehours of work for his eight-year-old son.

    Preventing the Fraud

    While many payroll depart-ments not only permit butencourage direct deposit ofemployee pay, businesses canstill guard against payroll fraudby having an employee periodi-cally distribute payroll checks(or in the case of direct deposits,stubs) directly to employees toverify that each person receivingpayment is a legitimate employee.Companies also should have

    their accounting departmentsconfirm payroll payments withemployee records. In this case,

    periodic distribution ofchecks or check stubswould have revealed pay-ments to Picards sons,and the distributingemployee would havenoticed that the sons werenot, in fact, working forthe company. Further-more, random periodic

    distribution of paychecks andpay stubs, as well as a periodicreview of employee records,may have discouraged the scamin the first place.

    Companies also may want toreview benefits and incentivesthat they have in place that maymotivate employees to engage inpayroll fraud. In the longshore-men case, it was the possibilitythat their children could reapfuture benefits (admittance tothe union and a higher entry-level wage) that drove theseindividuals to commit payrollfraud and not necessarily theshort-term cash benefits thatthey received. Companiesshould note any potential poli-cies or external factors thatcould contribute to payroll fraud

    The Journal of Corporate Accounting & Finance / November/December 2008 4

    2008 Wiley Periodicals, Inc. DOI 10.1002/jca

    If an employee perceives that his

    actions will go unmonitored, he is

    more likely to participate in cash

    fraud.

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    and adjust payroll processesaccordingly.

    OPPORTUNITY NUMBER 5:EXPENSE ACCOUNT FRAUD

    Financial InstitutionCase Study

    When a husband-and-wifeteam, Saratou and RonaldStewart, pled guilty to chargesrelated to expense-account fraudin 2006, they had embezzled over$400,000 from CitiFinancial,Inc.13 The couple was able toperpetrate the fraud becauseMr. Stewart served as a companyauditor in charge of approving

    and overseeing employeeexpense-account charges inCanada.

    In 2003, Mrs. Stewart (usingher maiden name) and a friendopened two separate bankaccounts in Canada. Mr. Stewartproceeded to create two ficti-tious employees: one with themaiden name of his wife and theother with the name of herfriend. He then falsified expensereports in their names. Over a

    period of two years, he trans-ferred money from CitiFinancialinto the two Canadian accountsfor reimbursement of expensesto these fabricated employees.Mr. and Mrs. Stewart then with-drew the funds from the Cana-dian bank accounts to purchase aluxury vehicle and a new homeand property, and to make mone-tary gifts to their friends andfamily.

    Preventing the Fraud

    According to the ACFE,employees generally use one offour tactics to commit expenseaccount fraud: mischaracterizationof expenses, overstatement ofexpenses, fictitious expenses,and/or multiple reimbursements.14

    Management and internal andexternal auditors should reviewexpense reimbursements foremployees when such amountsare repeatedly disproportionate torequests of similarly situated

    employees. This is generally awarning sign that the employeeshave created fictitious expenses.In this case, the expense reim-bursements to Mrs. Stewart andher friend should have triggeredan independent review in thatthey were fairly large reimburse-ments in a short period of time.This case also shows the impor-tance of hiring an external audi-tor to review expense accounts,since the fraud was committed by

    the companys internal auditor incharge of these accounts.

    ADDITIONAL GUIDANCE FORPREVENTING AND DETECTINGFRAUD

    As demonstrated in thesecases, not all frauds are head-liners, and many large-scalefrauds start small. For this rea-

    son, it is beneficial for manage-ment to examine their own fraudrisk management program andplace more emphasis on detect-ing and deterring small frauds.Furthermore, small businesses

    may be more susceptible to fraudthan larger businesses due totheir lack of antifraud measures.The ACFE 2006 Survey foundthat less than 50 percent of smallbusinesses had external audits,less than 20 percent utilizedinternal audits, and only 8 percenthad anonymous hotlines forreporting frauds.15 All organiza-tions, large or small, shouldimplement an appropriate over-sight function to detect and pre-

    vent fraudulent practices.Since cash is the asset most

    often misappropriated, it is par-ticularly important to put cashmanagement controls in place.As demonstrated in the Auburnprofessor case, cash misappro-priations may be more likely insmall businesses due to the lackof segregation of duties. Whilethe size of the business may be a

    42 The Journal of Corporate Accounting & Finance / November/December 2008

    DOI 10.1002/jcaf 2008 Wiley Periodicals, Inc.

    Fraud Detection

    Customer and vendor complaints

    Employees living beyond means

    Employees not taking vacations

    Combining business and personal assets

    Missing assets such as cash, supplies, or inventory

    Unrecorded or misreported assets and/or liabilities

    Unrecorded or misreported revenues and/or expenses

    Delay in recording transactions

    Errors in bank reconciliations

    Errors in control account and subsidiary account reconciliations

    Excessive write-offs

    Missing documentation

    Voided, missing, or destroyed checks

    Exhibit 2

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    factor in implementing someantifraud practices regardingcash, it may be less of a factor inimplementing others. Even

    though some antifraud measures,such as conducting externalaudits, maintaining internal auditdepartments, or consulting a cer-

    tified fraud examiner, may becostly, the cost may be wellworth it in the long run. On theother hand, some measures, suchas tip-lines, may not be as costlyand should be utilized on a

    larger scale. Exhibits 2 and 3include additional examples offraud detection and preventionstrategies.

    Furthermore, Statement onAuditing Standards (SAS) 99,Consideration of Fraud in aFinancial Statement Audit, pro-vides additional guidance forcurbing fraudulent practices.16

    SAS 99 was issued in the after-math of large fraud scandalssuch as Enron and WorldCom in

    2002. Since auditors have theresponsibility to plan and per-form the audit to obtain reason-able assurance about whetherthe financial statements are freeof material misstatementwhether caused by error orfraud,17 SAS 99 provides audi-tors additional guidance on ful-filling this responsibility as itrelates to fraud. For example,guidance is provided to auditorson maintaining professional

    skepticism; discussions amongengagement personnel (brain-storming) and between auditorsand others within the organiza-tion; identifying, assessing, andresponding to fraud risk factors;evaluating audit evidence; com-munication about fraud to man-agement and those charged withgovernance; and documentingthe auditors consideration offraud. While not an integral partof SAS 99, Section 316.86includes management guidanceon preventing, deterring, anddetecting fraud.

    The Exposure Draft, Man-aging the Business Risk ofFraud: A Practical Guide, rep-resents a joint effort by theInstitute of Internal Auditors(IIA), the American Institute of

    The Journal of Corporate Accounting & Finance / November/December 2008 43

    2008 Wiley Periodicals, Inc. DOI 10.1002/jca

    Fraud Prevention

    Reconcile bank accounts on a timely basis. Secure incoming and outgoing mail.

    Conduct employee background checks and employee exit

    interviews.

    Secure inventory and supplies.

    Implement mandatory vacations.

    Pay invoices from approved vendor list.

    Encourage communication within organization.

    Adopt a code of ethics.

    Implement fraud policy.

    Be proactive and deal with misconduct immediately.

    Set the right tone at the top.

    Conduct external audits.

    Utilize internal audit department.

    Conduct fraud training.

    Exhibit 3

    Antifraud Resources

    American Institute of Certified Public Accountants:

    www.aicpa.org

    Institute of Internal Auditors: www.theiia.org

    Association of Certified Fraud Examiners: www.cfenet.com

    Financial Executives International: www.

    financialexecutives.org

    Information Systems Audit and Control Association:

    www.isaca.org Institute of Management Accountants: www.imanet.org

    National Association of Corporate Directors: www.

    nacdonline.org

    Society for Human Resource Management: www.shrm.org

    Committee of Sponsoring Organizations of the Treadway

    Commission (COSO): www.coso.org

    Exhibit 4

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    Certified Public Accountants(AICPA), and the ACFE in pro-viding guidance to boards, man-agement, and internal auditorsin managing fraud risk.18 TheExposure Draft includes infor-

    mation on fraud risk gover-nance; fraud risk assessment;fraud detection and prevention;and fraud investigation. Exam-ples also are included of a fraudcontrol policy; fraud risk assess-ment framework; and frauddetection and prevention score-cards. Since it is managementsresponsibility to put programsand controls in place to prevent,deter, and detect fraud, this newguidance represents a valuable

    management resource in fraudrisk management.

    Other useful resources onfraud detection and preventionalso are available, some ofwhich are included in Exhibit 4.Management and those chargedwith governance should con-sider using these resources indeveloping or improving theirown fraud risk managementprograms.

    NOTES

    1. 2006 ACFE Report to the Nation on Occu-pational Fraud and Abuse, http://www.acfe.com/documents/2006-rttn.pdf at 4.

    2. Id. at 25.3. The three components are incorporated

    in Statement on Auditing Standards No.99, Consideration of Fraud in a Finan-cial Statement Audit, AICPA (New York,2002) AU 316.07.

    4. See note 1, at 42.5. Id.6. U.S. Department of Justice. (2007, August

    7). Former Auburn University professorpleads guilty to wire, tax, and SBA fraudcharges. Retrieved August 28, 2008, fromhttp://www.usdoj.gov/tax/usaopress/2007/txdv07lawing_plea.pdf.

    7. U.S. Department of Justice. (2008,February 7). Baltimore funeral homeowner sentenced to over four years fordefrauding customers and bank of over

    $925,000 in prepaid funeral expenses.Retrieved August 28, 2008, from http://www.usdoj.gov/usao/md/Public-Affairs/

    press_releases/press08/BaltimoreFuneralHomeOwnerSentencedtooverFourYearsForDefraudingCustomersandBankofover925000.html.

    8. Jones, R. (2008, May 23). LocalMcDonalds employee arrested for fraud.Retrieved August 28, 2008, from http://cbs13.com/local/mcdonalds.fraud.atm.2.731984.html.

    9. Be nice to your fast food employees.(2004, December 27). Retrieved August

    28, 2008, from http://www.foxnews.com/story/0,2933,142660,00.html.

    10. Identity theft, with fries. (2007,December 30). Retrieved August 28,2008, from http://patterico.com/2007/12/30/identity-theft-with-fries/.

    11. See note 1.12. Longshoreman pleads guilty, sentenced

    for committing fraud and larceny. (2008,May 20). Retrieved August 28, 2008,from http://www.mass.gov/?pageID=cagopressrelease&L=1&L0=Home&sid=Cago&b=pressrelease&f=2008_05_20_

    picard_jr_cop&csid=Cago.13. U.S. Department of Justice. (2006, January).

    Owing Mills couple pleads guilty to steal-ing over $400,000 in bank fraud scheme.Retrieved August 28, 2008, from http://www.usdoj.gov/usao/md/Public-Affairs/

    press_releases/press06/Owings%20Mills%20Couple%20Pleads%20Guilty%20to%20Stealing%20over%20$400,000%20in%20Bank%20Fraud%20Scheme.html.

    14. Mahadeo, S. (2006, October). Expensereimbursement schemes. Retrieved August28, 2008, from http://www.acfe.com/resources/view.asp?ArticleID=623.

    15. See note 1, at 41.16. AICPA, Statement on Auditing Standards No.

    99, Consideration of Fraud in a FinancialStatement Audit(New York, 2002) AU 316.

    17. Id. at AU 316:01.18. Managing the business risk of fraud: A

    practical guide. (2007, November 12).Exposure draft. Retrieved August 28, 2008,from http://www.theiia.org/download.cfm?file=46988.

    44 The Journal of Corporate Accounting & Finance / November/December 2008

    DOI 10.1002/jcaf 2008 Wiley Periodicals, Inc.

    Leigh Redd Johnson, JD, is an assistant professor of business ethics and law in the Accounting Depart-ment of Murray State University. Prior to joining Murray State, Johnson was a corporate and securitiesassociate at Womble Carlyle Sandridge & Rice, PLLC, in its Research Triangle Park, North Carolina, office.Her work has been published in the U.C. Davis Business Law Journal, the Journal of Corporate Account-ing and Finance, and the Journal of Corporate Taxation. Holly R. Rudolph, DBA, CPA, is a professor ofaccounting at Murray State University. Her research interests include financial reporting for public and pri-vate companies, auditor decision making, and accounting education. She has published in Auditing: AJournal of Practice and Theory, the Journal of Accountancy, Internal Auditing,Advances in Accounting Edu-cation, the Journal of Applied Business Research, the Journal of Education for Business, New Accountant,and the Journal of Corporate Accounting and Finance.