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Preventing a Fraud meltdown in your company
1. Preventing a Koss Meltdown at your
Company:
How to Prevent and Detect Fraud:
Implementing Internal Controls
2. Presenters
๏ฌ David Buslee
โ MBA UC Irvine
โ Certified Managerial Accountant
โ Certified Financial Manager
โ Partner โ B2BCFO
๏ฌ Paul Rodrigues
โ Certified Public Account
โ Masters in Tax
โ Certified Fraud Examiner
โ Certified in Financial Forensics
โ Principal at Chortek and Gottschalk
3. Goal
๏ฌ To Educate You on What is Happening
๏ฌ To Scare You to Death
๏ฌ To Make You Paranoid
๏ฌ To Provide Best Practices
3
4. What is Fraud
The elements of fraud are:
โ A representation about a material fact
โ Which is false
โ And made intentionally, knowingly, or recklessly
โ Which is believed
โ And acted upon by the victim
โ To the victimโs damage
4
5. Common Myths About Fraud
๏ฌ It canโt happen on MY watch
๏ฌ No one would do that here...
๏ฌ We have an excellent accounting system
๏ฌ My accounting clerk is my best employee
๏ฌ We donโt handle cash - Whatโs to steal
๏ฌ Problem Employees are likely suspects
๏ฌ I wouldnโt know where to start looking
5
6. The Fraud Triangle
Opportunity - Generally provided through
weaknesses in the internal controls.
Pressure - Can be imposed due to problems or
vices
Rationalization - Occurs when the individual
develops a justification for their fraudulent
activities.
6
7. Fraud Schemes
๏ฌ Three categories of fraud schemes according
to the Association of Certified Fraud
Examiners:
A. fraudulent statements
B. corruption
C. asset misappropriation
7
8. A. Fraudulent Statements
๏ฌ Misstating the financial statements to make the
copy appear better than it is
๏ฌ Usually occurs as management fraud
๏ฌ May be tied to focus on short-term financial
measures for success
๏ฌ May also be related to management bonus
packages being tied to financial statements
8
9. B. Corruption
๏ฌ Examples:
โ bribery
โ illegal gratuities
โ conflicts of interest
โ economic extortion
โ Kickbacks
๏ฌ Foreign Corrupt Practice Act of 1977:
โ indicative of extent of corruption in business world
โ impacted accounting by requiring accurate records
and internal controls
9
10. C. Asset Misappropriation
๏ฌ Most common type of fraud and often occurs as
employee fraud.
๏ฌ Examples:
โ making charges to expense accounts to cover theft of
asset (especially cash)
โ lapping: using checks from one account to cover theft
from a different account
โ transaction fraud: deleting, altering, or adding false
transactions to steal assets
10
11. How Management
Encourages Fraud
๏ฌ Management Attitude - Do Nothing
๏ฌ Little or poor Applicant screening
๏ฌ No written policies or procedures
๏ฌ Inadequate training - classroom or OJT
๏ฌ Responsibility, accountability, and authority not established or
documented
๏ฌ Goals and objectives neither established nor monitored for
success
๏ฌ Weak Enforcement Policy
๏ฌ Break accounting and policy rules - โToo Much Bureaucracyโ
๏ฌ Inconsistent application of policies or procedures - may result in
unfair treatment of employees - favoritism - low morale
๏ฌ Not listening to employees - treatment of whistleblowers
๏ฌ Weโll get them to resign - the problem will go away
11
12. Employee Fraud
๏ฌ Committed by non-management personnel
๏ฌ Usually consists of: an employee taking cash
or other assets for personal gain by
circumventing a companyโs system of internal
controls
12
13. Management Fraud
๏ฌ It is perpetrated at levels of management
above the one to which internal control
structure relates.
๏ฌ It frequently involves using the financial
statements to create an illusion that an entity is
more healthy and prosperous than it actually is.
๏ฌ If it involves misappropriation of assets, it
frequently is shrouded in a maze of complex
business transactions.
13
14. Who Commits Fraud ?
Almost anyone, rationalize they are just in
borrowing, believe they deserve what they
take, plan to repay - never do. Will continue to
commit fraud until caught.
โ Has an addictive need - alcohol, drugs, gambling, sex, shopping
โ Is intelligent
โ Has a position of trust and responsibility
โ Understands and skillfully uses technology
โ Is well respected in the community
โ Is married, 2 children, owns home
14
15. Perpetratorโs History
Perpetrator's Employment
Perpetrator's Criminal History
History
Never Never
charged or Punished or
6% 7% convicted Terminated
5%
12%
Charged but Previously
not 83% Punished
87%
convicted
Prior Previously
Convictions Terminated
15
17. Victim Organizations
Organization Type of Victim - Median Loss
Not-for-Profit
Type of Victim Organization
Government
2008
2006
Public Companies
Private Companies
$0 $50,000 $100,000 $150,000 $200,000 $250,000 $300,000
Median Loss
17
18. Victim Organizations
Size of Victim Organization - Frequency
<100
Number of Employees
100 - 999
2006
2008
1,000 - 9,999
10,000+
0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0% 45.0%
Percent of Cases
18
19. Victim Organizations
Primary Internal Control Weakness Observed by CFE
Lack of Reporting Mechanism
Lack of Employee Fraud Education
Most Important Contributing Factor
Lack of Clear Lines of Authority
Lack o f Independent Audits
Lack of Competent Oversight
Poor Tone from the Top
Override of Existing Controls
Lack of Management Review
Lack of Internal Controls
0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0%
Percent of Cases
19
20. What is a RED FLAG of Fraud?
๏ฌ A red flag is a set of circumstances that are
unusual in nature or vary from normal activity.
It is a signal that something is out of the
ordinary and may need to be investigated
further. These are warning signs.
๏ฌ Some Red Flags are easily discerned, while
others may be more subdued and/or
concealed.
20
21. Initial Detection Method by Organization Type8
Detection of Fraud Schemes
21 8The sum of percentages in this chart exceeds 100 percent because in some cases respondents identified more than one detection method.
ยฉ2008 by the Association of Certified Fraud Examiners, Inc.
22. How Costly is Fraud
๏ฌ The direct amount that is misappropriated is
oftentimes only a small portion of the cost to an
organization.
๏ฌ Intangible Costs
โ Distraction of organization
โ Employee morale
โ Embarrassment
โ Loss of customer confidence
22
23. Red Flags
๏ฌ Knowing how to spot and investigate Red Flags is
imperative in a proactive fraud deterrence program.
๏ฌ Learn to spot the behavioral and data red flags.
๏ฌ When red flags are present, investigate and
document.
๏ฌ Data mining is an effective tool for identifying red
flags in the company data files
23
24. Behavioral Red Flags
๏ฌ Fraudsters oftentimes demonstrate behaviors
that may serve as warning signs
๏ฌ Some perpetrators may act irritable, may
spend lavishly or become secretive.
๏ฌ The presence of these signs do not, in and of
itself, indicate fraud is occurring
๏ฌ Management and anti fraud professionals
should be trained to identify potential warning
signs so that they may be investigated.
24
25. 25 ยฉ2008 by the Association of Certified Fraud Examiners, Inc.
26. Behavioral Red Flags Present During Fraud Scheme24
24The sum of percentages for each scheme type
exceeds 100 percent because in several cases
the perpetrator exhibited more than one
behavioral red flag.
26 ยฉ2008 by the Association of Certified Fraud Examiners, Inc.
27. Cash Fraud
Red Flags
๏ฌ Discrepancies between cash count and account
balance
๏ฌ Mutilated/destroyed cash register receipts
๏ฌ Employee working from open cash drawer
๏ฌ Unexplained inventory adjustments
๏ฌ Unexplained increase in the use of petty cash
๏ฌ Personal checks included in cash funds
๏ฌ Unusual journal entries affecting cash accounts
๏ฌ Differences between daily receipts and bank deposits
๏ฌ โLess Cashโ line on deposit tickets indicates cash
taken
27
28. Accounts Receivable Fraud
Red Flags
๏ฌ Customer complaints regarding amounts owed
๏ฌ Discrepancies between deposit tickets and customer
records
๏ฌ Different dates between deposits and customer
payments
๏ฌ Unusual discounts or credits
๏ฌ Increase in delinquent accounts
๏ฌ Increase in the amount of write-offs
๏ฌ Receivables with unusual characteristics
๏ฌ Customers with unusual name, address or phone
number
28
29. Inventory Fraud
Red Flags
๏ฌ Unexplained inventory shrinkage
๏ฌ Excessive inventory adjustments
๏ฌ Decrease in gross margins
๏ฌ Unusual journal entries to inventory
๏ฌ Unusual trash removal practices
๏ฌ Increase in credit memos
๏ฌ Temporary workers with access to
inventory
29
30. Fixed Asset Fraud
Red Flags
๏ฌ Unusual or unexpected asset purchases
๏ฌ Missing assets
๏ฌ Unusual increases in repairs and
maintenance on assets that could be subject
to personal use
๏ฌ Unusual fluctuations in depreciation accounts
30
31. Accounts Payable/Vendor
Fraud
Red Flags
๏ฌ Higher-than-usual costs or expenses
๏ฌ Vendor complaints
๏ฌ Altered or modified vendor invoices
๏ฌ Unexplained fluctuations in payables
๏ฌ Unusual vendor names and addresses
๏ฌ Unusual payees on checks
๏ฌ Discrepancy between payees on checks and check
register
๏ฌ Unusual increase in purchases from vendor(s)
๏ฌ Copies of vendor invoices instead of originals
๏ฌ Missing cancelled checks
31
32. Payroll Fraud
Red Flags
๏ฌ Unusual fluctuations in payroll expense or hours
๏ฌ Checks to employees with minimal personnel records
๏ฌ Missing payroll checks
๏ฌ Number of paychecks do not match the number of
employees
๏ฌ Employee complaints regarding W-2 amounts
๏ฌ Employees who pick up paychecks for other
employees
๏ฌ Highly compensated employees who elect no
withholdings
๏ฌ Dual endorsements on cancelled payroll checks
32
33. Expense Reporting
Fraud
Red Flags
๏ฌ Improper or inadequate receipts underlying expenses
๏ฌ Information on expense report differs from receipts
๏ฌ Photocopies of expense receipts submitted instead of
originals
๏ฌ Repeated entertainment expenses with customer with
no associated business
๏ฌ Failure to utilize company credit cards when available
๏ฌ Expenses submitted not in line with other employees
33
34. The Perpetrators
Fraud Schemes By Accounting Personnel
Register Disbursements
Payroll
Cash Larceny
Fraudulent Statements
Type of Scheme
All Cases
Cash on Hand
Accounting
Expense Reimbursement
Check Tampering
Non-Cash
Skimming
Billing
Corruption
0.0 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0
Percent of Cases
34
35. Reduce Risk of Fraud:
Tools of Protection
๏ฌ Segregation of Duties
๏ฌ Environment
๏ฌ Internal Control Procedures
35
36. Segregation of Duties
โข No employee should be in a position to commit
fraud and then conceal it
โข Example: Person collecting/receipting cash
should not:
โข Post cash receipts to the general ledger system
โข Process cash disbursements
โข Prepare billings
โข Make bank deposits, wire transfers
36
37. Environment
๏ฌ The same rules apply to all
๏ฌ Donโt belittle internal control procedures
๏ฌ Donโt allow management to override
procedures
๏ฌ Be alert to employeeโs outside interests
37
38. Internal Controls โ Who?
๏ฌ As the owner, you are pulled in a variety
of directions
๏ฌ Need to focus on the overall business
๏ฌ No experience in creating controls
๏ฌ As the โFinderโ you canโt be constantly
involved in โMinderโ activities
38
39. Controls - Part-time CFO
๏ฌ Experienced partner to CEO
๏ฌ Knowledgeable in creating controls and
enforcing controls
๏ฌ Enables the โFinderโ to concentrate on
building the business
๏ฌ Cost effective alternative โ can help build
sales and gross margins
39
40. Controls - Part Time CFO
๏ฌ Physical security
๏ฌ Segregation of duties
๏ฌ Employee monitoring
๏ฌ Surprise audits
๏ฌ Job rotation
๏ฌ Examination of Documentation
40
41. Your Bank โ Account Control
๏ฌ Specify what, if any, ACH debits can hit your
accounts
๏ฌ Require 2 signatures for any outbound wire
๏ฌ Make sure they donโt give cash back on business
deposits
๏ฌ Make sure they only deposit to business accounts
๏ฌ Use a โtokenโ for all account inquiries
๏ฌ Only signors should access accounts
๏ฌ Positive Pay and Reverse Positive Pay
41
42. Suspected Fraud ?
โขSeek out a Fraud Practitionerโฆ
โ Type of fraud:
โ Employee fraud - dismissal or prosecution of employees?
โ Vendor fraud?
โ Any misconduct involving a high-level officers, executives or
managers
โ Financial reporting fraud?
โ Complaints involving the Foreign Corrupt Practices Act (FCPA)
โ Certain industry practices
โขWho should be in the know before any action is
taken?
โขHow was the (potential) fraud detected?
โขInvolvement of authorities?
43. Legal Considerations of Fraud
๏ฌ Intentionally false representation
โ Not an error
โ Lying or concealing actions
โ Pattern of unethical behavior
๏ฌ Personal material benefit
๏ฌ Organizational or victim loss
43
44. Summary
๏ฌ Anyone can be a Fraudster โ they tend to be
the most trusted employee
๏ฌ Fraud Prevention Checkup
๏ฌ Most Frauds are discovered by accident or tips
๏ฌ Be vigilant for Red Flags
๏ฌ Part Time CFO will create and enforce internal
and external controls
๏ฌ Your Bank has many tools to prevent fraud
๏ฌ Have a game plan for when fraud is suspected
44
45. Contact Information
David Buslee
Partner
B2BCFO LLC
(262) 271-2522
dbuslee@b2bcfo.com
Paul Rodrigues
Principal
Chortek and Gottschalk
(262) 522-8227
PRodrigues@c-gcpa.com
45
Editor's Notes
I want to educate your so that you can see what may be happening, or about to happened, in your own company. And yes, I want to scare you, because most companies who experience this have become complacent in their bad practices. As Andy Grove, chairman of Intel once said, only the paranoid survive, I want you to be sufficiently paranoid that good practices donโt become corrupted by shortcuts. And for those of you who question your current practices โ to provide some of the recognized โbest practicesโ in dealing with fraud and its causes.
First, we need to understand what fraud is.(read slide)And Fraud can be one of Omission โ leaving out important facts that, if know, would have made you act differently had you known them.
There are some common myths regarding fraud โ the persistence of those myths confirms that โDenialโ isnโt just a river in Egypt.
Opportunity - Generally provided through โ the only thing that the company can changeweaknesses in the internal controls. Someexamples include inadequate or no:Supervision and reviewSeparation of dutiesManagement approvalSystem controlsPressure - Can be imposed due to:Personal financial problemsPersonal vices such as gambling, drugs, extensive debt, etc.Unrealistic deadlines and performance goalsProblems come and go. A good employee can be subjected to pressure due to events which occur after the employee is hiredRationalization - Occurs when the individual develops a justification for their fraudulentactivities. The rationalization varies by case and individual. Some examples include: โI really need this money and Iโll put it back when I get my paycheckโโIโd rather have the company on my back than the IRSโโI just canโt afford to lose everything โ my home, car, everythingโOne of the most powerful rationalizations occurs when owners and managers fail to follow their own rules, setting the example that employees come to expect as being the NORM.
Management Attitude - Do Nothing- Not my problem- Itโs too embarrassing for the department, institution, etcโฆWho wants the bad press of an investigationScreening - Culture Index - By identifying the capabilities of every employee and prospective employee, Culture Index can prevent hiring mistakes, solve turnover problems, communication problems and morale problems.Credit Checks People need to sign off on credit check Spend more than earningNo written policies or procedures- low priority for the establishment of internal controls- no separation of duties- inadequate cash controls - documents- inadequate physical security for assets and records- no independent inventory of assets - recording and review of overages and shortages
They can be purchasing agents, salesmen, accountants, shipping clerks, VP of Operations โ almost anyone in the organization can commit fraud against the organizatio
Occupational fraudsters are generally first time offenders. Only 7% had prior convictions and only 12% had been previously terminated by an employer for fraud-related conduct.Resume inconsistencies Open spaces in resumes Few frauds are prosecuted Rarely do a criminal background Most arenโt prosecuted 83% never terminated or punished Out of court settlements
Koss โ external audit 4%. They are required to have a mind set of the potential for fraud โmaterial mis-statementsโ.Tip or accident is 65%.