stop the fraudster! pennsylvania treasury, industry expert chris doxey and fulcrumway

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CON8207: Stop the Fraudster!

Mark Stebelton, CPA, CFE (Oracle) – Director of GRC Product ManagementChris Doxey, CAPP, CCSA, CICA, CPC - Management ConsultantBob Enders (Fulcrum Way) - Senior Client Services DirectorJeffrey Bohr (Pennsylvania Treasury) - Applications Developer Administrator, IT

@OracleAdvCntrlsFollow us on Twitter


MANAGE RISK | REDUCE COSTS | IMPROVE CONTROLS


0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

Strategic Priorities Survey________________

Finance Executives SURVEYED

263

Reaching New Heights: The Dividends of Collaboration between

Finance and Procurement is published by CFO Publishing LLC, May 2012

Survey question: Where does the procurement function need to get stronger?

SUMMARY:________________________________

Better Controls & Efficiencies Needed

#1#2

#3

#4

#5

Audit/Control of Procurement

Risk Analysis

CashFlow

PayableExposure

Compliance

Copyright © 2014, Oracle and/or its affiliates. All rights reserved. | 6

BOTTOM LINE: Document/Email Approaches Challenge GRC

53%

Spreadsheets, Documents & Email

17%

Solutions Built In-house by IT

24%

Commercial GRC Solution

6%

2+ CommercialGRC Solutions

The lack in modern

technology makes

achieving goals challenging

OCEG SURVEY • 2014 GRC Technology Strategy Survey • www.OCEG.org HOW ORGANIZATIONS APPROACH AND ADAPT THEIR TECHNOLOGY STRATEGY FOR GRC

The impact on FTE’s is particularly significantOne financial services organization stated that 80% of their GRC staff

resources were nothing more than document reconciles for

reporting. […] A mess they are aggressively trying to correct.

of GRC professionals reported that they use Spreadsheets, Emails, Custom reports apps.

70%

http://www.OCEG.org


Oracle GRC Product Strategy

PLATFORM

ENTERPRISE

GRC

COMPLETE

One, UnifiedPlatform

The #1 PlatformWith intelligence, advanced

controls

& management capabilities


Comprehensive Risk & Controls Mgmt.

Detect and Fix Issues

Continuous Improvement and

Monitoring

Assess Risk & Compliance

Close the

LOOP

Identification

Analysis

Evaluate

1. BUSINESS RISKS

Document

Assessments

Reviews

2. CONTROL OBJECTIVES

Author

Execute

Investigate

3. CONTINUOUS MONITORS


Meeting Mission Critical Goals

1OneUnified Platform

2Big Data Techniques for Advanced Analytics

MASTER DATA

3

Embedded ControlsExtensive API Library

FINISHED


Enterprise Graph

________________

ALL USERS

____________

ALL SYSTEMS

_________________

ALL TRANSACTIONS

INTUITIVE | FLEXIBLE | COMPLETE

SECURITY

SETUP

MASTERDATA

TRANSACTIONS

_______________________________________

__________________________________

BILLIONS OF NODES & RELATIONSHIPS


Big Data Analytics

USERS

SYSTEMSTXN

TXN

ROLES

SET UP

ROLES

USERS

SETUP

MASTER DATA


Standard Controls

User Roles

3-Way Match

Approval Hierarchies

StandardControls

Social Media Policy

E-learningEthics Policy


Standard + Advanced Controls

Sentiment Analysis

Split Purchase

OrdersHide

Displays of Sensitive

DataDuplicate Payments

Transaction Threshold Amounts

Duplicate Vendors

Fine-grained User Access

ConfigurationSnapshots &

Audit Trial

Transaction Pattern Analysis

Fuzzy Logic, ‘similar values’

User Roles

3-Way Match

Approval Hierarchies

Advanced Controls

StandardControls

Social Media Policy

E-learning Ethics Policy


Government/Education

Technology/Services

Retail

Energy

Communication Industrial

Logistics

Healthcare Services

Mining/Exploration

Customer By Industry

http://www.tjx.com/default.asp

http://www.tjx.com/default.asp

http://images.google.com/imgres?imgurl=http://pnt.gov/membership/dot-large.jpg&imgrefurl=http://pnt.gov/membership/dot.shtml&usg=__ZYOuYeBtj3L1fm9LTPL7THeyIig=&h=335&w=337&sz=27&hl=en&start=1&um=1&tbnid=k4fEQ3d3NRcUpM:&tbnh=118&tbnw=119&prev=/images?q=department+of+transportation&um=1&hl=en&sa=N

http://images.google.com/imgres?imgurl=http://pnt.gov/membership/dot-large.jpg&imgrefurl=http://pnt.gov/membership/dot.shtml&usg=__ZYOuYeBtj3L1fm9LTPL7THeyIig=&h=335&w=337&sz=27&hl=en&start=1&um=1&tbnid=k4fEQ3d3NRcUpM:&tbnh=118&tbnw=119&prev=/images?q=department+of+transportation&um=1&hl=en&sa=N

http://www.csx.com/

http://www.csx.com/

http://www.fedex.com/gb/

http://www.fedex.com/gb/


Advanced Controls Partner SpecialistsOracle recommends using partners and consultants who are Advanced Controls specialists:

Specialized Partner

Implementation Specialist

Pre-Sales Specialist

Sales Specialist

•Can plan, design, deliver, support successful solutions

•Has all specialists shown below

•Demonstrated track record of success

•Can design detailed solutions

•Passed rigorous Oracle examination

•Can describe introductory solutions

•Completed ten hours of study and self-assessment

•Can identify need for Advanced Controls

•Completed ten hours of study and self-assessment

Oracle Confidential – Internal/Restricted/Highly Restricted 16


Specialized PartnersIncrease your Return On Investment

• Get more from Advanced ControlsSpecialists address more of your needs with Advanced Controls’ many capabilities

• Increase your organization’s effectiveness Specialists help you embed Advanced Controls in your business processes

• Accelerate your implementationSpecialists guide and support you during planning, implementation and go-live

Oracle Confidential – Internal/Restricted/Highly Restricted 17

Chris Doxey, CAPP, CCSA, CICA, CPCManagement Consultant

Doxey, Inc.

[email protected]

571-267-9107

Stop the Fraudster! Set the Tone at the Top and Prevent Fraud with Oracle Advanced

Controls

18

mailto:[email protected]

Business Processes with Biggest Fraud Challenges

Source: 2014 Aberdeen Survey

Processes with Biggest Challenges – Example: PTP

Source: 2014 Aberdeen Survey

2014 Association of Finance Professionals (AFP) Payments Fraud Survey Highlights

• 60% of organizations were exposed to actual or attempted payments fraud in 2013.

• 27% of financial professionals that experienced payment fraud in 2012 report the number of fraud incidents increased from 2013.

• 16% of financial professionals from organizations that experienced payment fraud report a decrease in fraud incidents in 2013 compared with 2012.

Source: 2014 AFP Payments Fraud Survey

21

2014 Association of Finance Professionals (AFP) Payments Fraud Survey Highlights (Cont.)

• 82% of survey respondents report that checks were the primary target for fraud attacks at their companies.

• 43% of survey respondents from organizations exposed to fraud attacks, report credit/debit cards were targeted.

• The typical financial loss incurred by companies due to payments fraud in 2013 is $23,100.

Source: AFP Payments Fraud Survey 2014

22

Fraud Schemes Reported in the 2014 Association of Certified Fraud Examiners (ACFE) Report to the Nations

Source: 2014 ACFE Report to the Nations

P2P Fraud Case Study 1: Brenda Belton and Washington DC Charter Schools

• Belton, 61, convicted of stealing and illegally steering more than $800,000 in school system money, was begging for mercy in the same courthouse where another corruption case is playing out, involving the alleged theft by two other D.C. government employees of $20 million or more from city tax collections.

• Belton, who was responsible for monitoring 17 charter schools for the D.C. Board of Education from 2003 to 2006, pleaded guilty in August to theft and tax evasion. Prosecutors said she cheated the system throughout her tenure as chief executive of the board's Office of Charter School Oversight.

• Prosecutors said Belton steered about $446,000 in no-bid contracts to friends and a cousin and stole $203,000 by directing school money to a fictitious company. At the same time, she received $180,000 in illegal payments and kickbacks from friends for whom she helped win school business.

Source: http://www.washingtonpost.com/wp-dyn/content/article/2007/06/05/AR2007060500797.html

24

http://www.washingtonpost.com/wp-dyn/content/article/2007/06/05/AR2007060500797.html

P2P Fraud Case Study 1: Brenda Belton and the Washington, DC Charter Schools (Continued)

• As part of her plea agreement, Belton promised to pay restitution of $384,000, the amount she was accused of pocketing in the scheme.

• Prosecutors say at least seven others participated in the embezzlement, but no charges have been filed against them. Authorities said Belton was the driving force behind the thefts and diversion of contracts.

Source: http://www.washingtonpost.com/wp-dyn/content/article/2007/06/05/AR2007060500797.html

25

http://www.washingtonpost.com/wp-dyn/content/article/2007/06/05/AR2007060500797.html

P2P Case Study 1: What internal controls were missing?

“Tone at the Top”

Segregation of Duties

A P2P Internal Controls Program

Disbursement Controls

Random Audits

Bank Reconciliations

What else?

26

Fraud Case Study 2: Too Much Systems Access

27

• A large company enlisted a group of finance process subject matter experts to help test the installation of a new enterprise resource planning (ERP) system.

• In order to fully test the integration of transaction processing to the general ledger, the team was given full systems access to all the master files, transactional interfaces, and accounting functionality of the system.

• After the system was implemented, members of the team were sent to other departments as managers or senior financial analysts; however, the system access rights that they were granted for testing purposes was not removed.

Fraud Case Study 2 :Too Much Systems Access (Continued)

28

• One former accounts payable manager found that she still had the system access rights to set up a vendor, pay an invoice, and void the transaction – even though she was in another department.

• An internal audit found this significant issue and determined that the individual had embezzled nearly $300,000.00 in company funds.

• The employee was terminated and paid back the funds.

• The review of system access rights was immediately added to all audit and internal control programs.

What internal controls were missing?

• Systems Access Controls

• Systems Access Review

• Timely Bank Account Reconciliations

• Journal Entry Controls

• General Ledger Reconciliations

• What Else?

29

Leverage Technology:Move Your Business Forward™

Risk and Compliance Financial Reporting Internal Audit Controls Catalog Application Security Advanced

Analytics

A Leader in Risk Based Enterprise Controls Management Solutions

Copyright ©. Fulcrum Information Technology, Inc.Give me a lever long enough and a fulcrum on which to place it, and I shall move the world - Archimedes

Stop the Fraudster! Set the Tone at the Top and Prevent Fraud with Oracle Advanced Controls

Oracle Advanced Controls for

the Procure to Payment Process

www.fulcrumway.comPage 31Copyright © FulcrumWay

Introduction

Robert Enders

Client Services Director

FulcrumWay Technologies

[email protected]

708-903-7971

Stop the Fraudster! Set the Tone at the Top and Prevent Fraud with Oracle Advanced Controls

mailto:[email protected]


A Leader in Risk Based Controls Management™

FulcrumWay: is the #1 End-to-End Provider of Risk Based Enterprise Controls Management

Solutions for Oracle EBS, PeopleSoft and JDE customers with over 200 Fortune-500 to Middle

Market clients. Since 2003, we have successfully assisted companies across all major industry

segments.

Expertise: Risk Advisory Services. Advanced Controls Design for Enterprise Applications. Best

Practices for Risk Mitigation and Internal Controls Automation. Audit, Compliance, Financial,

Enterprise and Operational Risk Assessments. Risk Remediation Services.

Packaged Solutions: FulcrumWay is the #1 choice of Oracle customers for Oracle GRC Advanced

Controls, GRC Manager, and GRC Intelligence/OBIEE software implementation. Oracle has

certified us as the only partner with Accelerators for Oracle GRC. We also provide Managed

Services

Software Services: Risk Assessment for ERP systems, Control Design and Management Tools,

Controls Catalog, Enterprise Risk Manager, Financial Reporting Manager, Audit Manager

USA Presence: Privately held Delaware Corporation with US offices in New York City, Dallas and

San Francisco

International Presence: in Auckland, Chennai, Johannesburg, London, Mexico City

FulcrumWay


Continuous Controls & Risk Monitoring

Enterprise Risk & Controls Foundation

Setups Master Data Transactions Audit Tests

Risk, Controls & Compliance Management

Reviews Assessments RemediationSurveysDocumentation

Dashboards, Reports & Alerts

NotificationsWorklists Email PerspectivesSearch

Access

Custom or Legacy Applications

Complete Advanced Controls Solution

Report

Manage

Enforce

Complements core ERP to enhance business efficiency

Advanced Controls


Business Process Models Service Oriented Architecture

Corporate Performance Management Collaboration

Strategic Sourcing & Contract Mgmt

Supplier Collaboration

Spend Categories

Indirect & MRO

Direct

Materials

Services

SWIFTNet

Settlement

Payment

Processors

Requisition

Purchase

Goods /

Services

Receive

Goods /

Services

InvoiceIssue

Payments

Banks

Example - Oracle Procure-to-Pay Procure-to Pay Controls are Required

Control Points

Advanced Controls





Spend Categories

Indirect & MRO

Direct

Materials

Services

SWIFTNet

Settlement

Payment

Processors

Requisi-

tion

Purchase

Goods /

Services

Receive

Goods /

ServicesInvoice

Issue

Payments

Banks

Example - Oracle Procure-to-Pay

Are your vendors compliant with trade regulations? Are the vendors

blacklisted?

Do you have duplicate suppliers?

Are there inappropriate associations between a

vendor and an employee?

Are there frequent changes to Supplier

information?

Are you missing critical supplier information?

Is the information valid?


CONTROLS

Automated Controls for Strategic Sourcing & Contract Mgmt

Advanced Controls






Spend Categories

Indirect & MRO

Direct

Materials

Services

SWIFTNet

Settlement

Payment

Processors

Receive

Goods /

ServicesInvoice

Issue

Payments

Banks


Do you have duplicate Purchase Orders?

Are there purchases with non-preferred vendors?

Are there split POs?

Are POs created on the same day as goods

arrive?

Requisition

Purchase

Goods /

Services

CONTROLS

Automated Controls for Requisitions and Purchases

Advanced Controls






Spend Categories

Indirect & MRO

Direct

Materials

Services

SWIFTNet

Settlement

Payment

Processors

Requisi-

tion

Purchase

Goods /

Services

Banks


Are you making accurate and timely payments?

Did the person making the payment create or

modify the vendor?

Are there discrepancies in freight charges?

Receive

Goods /

ServicesInvoice

Issue

Payments

CONTROLS

Are payment term changes reviewed before payment?

Are there duplicate invoice amounts being

processed?

Automated Controls for Receiving, Invoices, and Payments

Advanced

Controls


• Duplicate Payments

• Invoice Sequence Anomalies – alpha

character check

• Invoice Sequence Anomalies - sequential

numbers

• Split Payments

• Payment to Prohibited Vendors - OFAC

• Payment to Prohibited Vendors - Missing

Taxpayer Identification Number (TIN)

• Invoice Amount Exceeding Limit

• Duplicate Vendors

• Not in Accordance with Policies and

Procedures – One time vendors

• Payee Incorrect - multiple vendor numbers for

payment

• Potential Fraud - Same bank account

• Overall Reasonableness of Payment – travel

expenses

• Potential Fraud – PO Box

• Overall Reasonableness of Payment – High

Risk Vendors

• Overall Reasonableness of Payment -

advanced accounts

• Duplicate Payments

• Potential Fraud – Vendor vs. Employee

• Overall Reasonableness of Payment – gifts

• Overall Reasonableness of Payment – new

vendors

• Missing Support

• Address Incorrect – Missing Address

• Pending Priority

• Resubmitted Payments

Client case Control Requirements


Fiscal watchdog ensures tens of billions of dollars in

payments are lawful and correct

Our Client

A state government agency responsible for safeguarding financial assets – more than $120 billion of public funds.

Helps local governments and nonprofits invest their money with flexibility, security, and confidence.

ChallengesReplace fragmented legacy system for recovery audit department with a single incident management systemReplace manual control checklists with a audit analytics system to identify suspicious vouchers submitted for payments by 28+ agencies across the state. Assign suspension transaction to auditors for final review and approval using a pattern matching system

Solutions

Oracle GRC Advanced Controls

Results: Reduce erroneous payment processing by 5% on millions of payments processed each day by consolidating all vouchers across 28 agencies into a single data hub. Improve incident investigation process by establishing business rules to assign incidents based upon risk level, investigation type, priority that match the auditor skills and job roleProvide management visibility and independent oversight to monitor approved and rejected paymentsEliminate inconsistent and contradictory actions by auditors by providing a structured investigation process based on approved investigation checklists based on type of the suspicious transaction. Optimize recover audit business process with integration to the ERP system for vendor management and payment processing

Client case


Establish and Improve Controls

Monitoring and Framework

Our Client Major energy producer recognized for

innovation, flexibility, exploration proficiency

and our technical capabilities in developing

hydrocarbon resources, with an impressive

record of success in various regions of the

world.

Global Operations in over 20 different locations

Oracle E-Business Suite

ChallengesComply with IT Governance Policies

Improvement to overall Controls Framework

Replace manual task for Segregation of Duties

management with over 25,000 functions,

providing greater integration with the ERP

Provide greater controls over ERP technical

components and order to reduce overall

organization risks

Establish more effective preventative and

monitoring controls

SuccessesDeployed SOD monitoring tool that improved

overall operational and management

efficiencies

Established control framework improving

preventative and monitoring controls

Increased visibility into actual operations in

the controls environment

Reduced risk of SOX issues and fraud

opportunities

SolutionsOracle GRC Controls Suite

Client case


Mitigates risks and unlock new opportunities with

Advanced Control Analytics

Our Client Designs, develops, markets, and distributes

footwear for men, women, and children, as well

as performance footwear for men and women

Operates globally through four segments:

Domestic Wholesale Sales, International

Wholesale Sales, Retail Sales, and E-commerce

Sales

PeopleSoft Financials

ChallengesComply with IT Governance Policies

Improve overall Controls

Replace manual task for Segregation of Duties

management to provide greater integration with

the ERP

Establish more effective monitoring of global

transactions through advanced controls

SuccessesDeployed SOD and transaction monitoring

tools improving operational and management

efficiencies

Increased visibility into procure to pay, and

financial operations in the controls

environment

Reduced risk of SOX issues and fraud

opportunities

Client case

SolutionOracle Application Access Controls and

Transaction Controls Governors


Industry Opportunities Next, What is Possible with TCG?


AP AuditFulcrumWay Retail Industry

Claims Trend


MerchandiseFulcrumWay Retail Industry

Merchandise Losses

Net Price


Vendor RiskFulcrumWay Retail Industry


FreightFulcrumWay Retail Industry


MediaFulcrumWay Retail Industry

www.patreasury.gov

Advanced Controls

Jeff BohrInformation Technology Manager

http://www.patreasury.gov/index.html


Rob McCord, State Treasurer |www.patreasury.gov

Organization Overview

Rob McCordState Treasurer

• Processed about 30 million payments worth nearly $75 billion last fiscal year.

• IT systems manage about $15 billion in State assets.• Unclaimed Property program collected $265 million

and returned over $116 million, generating nearly $148 million for the General Fund in FY 13-14.

• PA 529 College Savings Program is setting new records: more than $3 billion in assets, serving 186,000 accounts as of June 30, 2014.

• Prevents tens of millions of dollars in erroneous payments annually through pre-transactional audits ($58 million in FY 12-13).



http://www.patreasury.gov/newsMediaBio.html

http://www.patreasury.gov/newsMediaBio.html


Pre-Audit Goal

• Treasury is responsible to perform pre-payment audits

• Goal: 0% fraud and errors

• Goal: 100% pre-audit coverage

• Saw Oracle GRC as a pre-payment auditing tool not just a

post-payment audit tool




Why – Business Challenges

• Standards-based solution to provide 100% pre-audit support.

• Compliance with Pennsylvania management directives and laws.

• Desire to put control logic into the hands of users.

• Ability to analyze vouchers from multiple sources.




Why – Technical Challenges

• Project to replace Mainframe system with PeopleSoft ERP Financials system.

• Requirements– Able to analyze data in SQL Server– Able to analyze custom data structures and PeopleSoft delivered

data structures.– Able to scale to very large datasets

Our solution analyzes potentially 100,000’s of new vouchers per day that are compared against a set of 3 years of historical vouchers which numbers up to approximately 20 million vouchers.




How we Integrated

• Setup GRC/TCG as a pilot project against legacy system.

• Integrate GRC implementation into the PeopleSoft ERP project.

– Pre-audit staff designed controls

– Technical staff built custom GRC business objects

– Development built interface from GRC to PeopleSoft

• GRC solution went live at the same time as PeopleSoft Financials (7/1/2014)




Pilot Project Architecture

Legacy



http://www.salesforce.com/

http://www.salesforce.com/


Our Current Architecture




How we Integrated with PeopleSoft• Vouchers are staged in PeopleSoft

• All staged vouchers are analyzed by GRC – Vouchers with incidents moved to a custom

Audit Workbench Application for further review

– Vouchers without incidents are moved forward for further processing.

• Phased approach, new controls will be moved to production




Integration Example




Examples of Controls

• First payment for a new purchase order or contract

• Duplicate vouchers

• Resubmitted payments

• Incorrect address

• Invoice with similar sequence




What worked well and what didn’t• What works well

– Providing 100% audit coverage– Improving pre-audit consistency– Scaling to large volumes of data– Users taking control of logic

• Users can quickly design a new control as they identify new audit conditions.

– Integrating into Treasury workflow• Easily integrated into PeopleSoft Accounts Payables processing

– Ease of Technical Operations• Single server solution operates the GRC software and Oracle Database

• What didn’t– Random Sampling




Future Expansion Plans

• Expand to more controls

• Build analytics out of GRC results

• Help agencies to identify problems

• Refine controls to meet change

• Move beyond TCG to ACG and CCG




Oracle GRC – Enterprise Risk and Controls Foundation

A Unified Platform


Dashboards, Reports and AlertsNotificationsWorklists Email PerspectivesSearch

Risk, Controls & Compliance ManagementReviewsDocumentation Assessments RemediationSurveys

Continuous Controls & Risk MonitoringSetupsAccess Master Data Audit TestsTransactions

User Authored ControlsData Connectors Fraud & Error PatternsRo

le B

ase

d A

cce

ss S

ecu

rity

We

b S

erv

ice

s &

AP

Is Flexible

• Graphical Authoring• Detect and Prevent• Access, Transactions, Setups

Data Driven

• 100% of Transactions• Manage by Exception• Pattern Analysis

Comprehensive

• Multiple GRC Projects• From Documentation to Test• Closed Loop Approach


Roadmap: Investment Areas


Dashboards, Reports and AlertsNotificationsWorklists Email PerspectivesSearch

Risk, Controls & Compliance ManagementReviewsDocumentation Assessments RemediationSurveys

Continuous Controls & Risk MonitoringSetupsAccess Master Data Audit TestsTransactions

User Authored ControlsData Connectors Fraud & Error PatternsRo

le B

ase

d A

cce

ss S

ecu

rity

We

b S

erv

ice

s &

AP

Is

Pre-Built Controls

Pre-Built Business Objects

Investment Areas

Pre-Built Integrations

Platform Features

Extensibility

Questions?

63


Oracle GRC Advanced Controls - Sessions Left Today

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Oracle GRC Advanced Controls - Sessions Tomorrow

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Achieve a Quicker and Compliant Financial Close with Oracle Governance, Risk, Compliance

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Controlling for Multiple ERP Systems with Oracle Advanced Controls

8154

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How Your Vendor Master File is Critical to Governance, Risk Management and Compliance

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Oracle GRC Advanced Controls - MTE and Demo Grounds

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Host

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Wed, 5:00Westin at 3rd & Market St

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Demo Station: Oracle Fusion Governance, Risk, and Compliance Advanced Controls

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Mon 9:45 – 6:00Tue 9:45 – 6:00Wed 9:30 – 3:45

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