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3/19/2009




     ACFE Regent Emeritus
        Tommy Seah
               presents

    Fraud Risk Management
       A Paradigm Shift
             2009



                                      1




  “………….. financial institutions
     must have in place, all the
 necessary measures to deter or
   prevent fraud and constantly
     review all its controls and
 measures and also have in place
 a f d management function t
   fraud               tf     ti to
 prevent loopholes that fraudsters
can exploit.” …… who said that ?




                                      2




  march 05, 2009 at Shangri-La
   hotel and the guest of honour
  was Ms Teo Swee Lian, Deputy
     Managing Di t MAS
     M      i Director, MAS.




                                      3




                                                 1
3/19/2009




Why is Internal Control Important?




                              Financial Reporting
                          • Promotes integrity of data
                            used in making business
                            decisions

                          • Assists in fraud prevention
                            and detection through the
                            creation of an auditable trail of
                            evidence
                Operations
        Promotes efficiency and
        effectiveness of operations
        through standardized                 Laws and Regulations
        processes
        Ensures the safeguarding of      • Helps maintain compliance
        assets through control           with laws and regulations
                                         through periodic monitoring
        activities




                                                                   4




   Limitations of Internal Control




                Errors may arise from
                misunderstandings of instructions,
                mistakes of judgment, fatigue, etc.
                Controls that depend on the
                segregation of duties may be
                circumvented by collusion
                Management may override the
                structure
                Compliance may deteriorate over
                time




The Existing model

                                     Financial
                                      Control
   The Fraud Examiner                                              The Certified
                                                                System Investigator
          CFE
                                                                       CSI

     Compliance                           The                              Risk
                                                                        Management
     CPA,LLB, CSI                       Trinity
                                                                        CPA,CFA CSI
                                           of
                                      Controls



                                   Internal Audit
                                   CPA(CIA) CSI,
                                        CISA
                                                                                      6




                                                                                                 2
3/19/2009




                     The Spectrum of Risk
www.cfe-in-practice.net



                                   Liquidity Risk

                                            B



                          A                                    C
 Operational                                                           Credit Risk
    Risk

                                   What is Risk ?




                                                         D
                              E
     Reputational                                                Market Risk
        Risk


                                                    7




www.cfe-in-practice.net




                          “External”
                            Audit

           Internal audit
    (COSO + COBIT+ ISO…




      Forensic audit
                                       Investigative auditing
      (Specific, Post event)
                                       ( suspicious, unusual activities, allegations)
      Eg. NKF, CAO
                                       E.g.. Money Laundering penetration Test




                                                    8




                    Fraud Control Principle
                    F   dC t lP i i l




                                                                                               3
3/19/2009




      If an organisation accepts that it
      is exposed to fraud – and no
      organisation is immune to fraud –
      the next step is to
      apportion responsibility for fraud
      risk management.

  Copyright (c)2006            www.cfe-in-practice.net                     10




The Paradigm Shift

                                      Financial
                                       Control
  The Fraud Examiner                                        The Certified
                                       The CPA
                                                         System Investigator
            CFE
                                                                CSI

                                                                Risk
           Compliance                                        Management
          CPA,LLB, CSI                                       CPA,CFA CSI

                                     S.T.A.R
                               Strategic Tracking
                                and Resolution

               Investigation                                  FRM Unit
                                    Internal Audit
                   Unit
                                    CPA(CIA) CSI,
                                         CISA
                                                                                11




 WHY is there a need for the paradigm shift ?

 Historically, the management of fraud risk
 does not lie with any one
 particular department or practitioner.



  Copyright (c)2006            www.cfe-in-practice.net                     12




                                                                                            4
3/19/2009




    It can be handled internally or be
    outsourced,
    and how it is handled is affected by
    many variables such as organizational
    size, industry sector, geographical
    location, cultural dynamics - and
    management
    perception of the problem.

Copyright (c)2006         www.cfe-in-practice.net   13




                    Regardless of these
                    variables, any fraud
                    prevention and control
                    model should aim to
                    achieve one, or all, of
                    the five
                    primary objectives:

Copyright (c)2006         www.cfe-in-practice.net   14




              The five
              primary objectives:
              _ Prevention
              _ Deterrence
              _ Disruption –
              _ Identification
              _ Civil action/criminal prosecution

Copyright (c)2006         www.cfe-in-practice.net   15




                                                                5
3/19/2009




 The Fraud Triangle.



    Fraud Risk                          Fraud Risk
    Management                          Management




          Perceived Opportunity
                     Auditor’s Domain




                       Who Commits Fraud?

                       What type of individual commits FRAUD?
                       It is not limited to any one type of person.




       www.cfe-in-practice.org




Married
Active religious
members
Children
Good education
First-time offenders
Good employees
Don’t abuse alcohol




                                                                             6
3/19/2009




        Optimistic
        High self-esteem
        Achieving
        Family harmony
        Socially conforming
        Self control
        Kind
        Sympathetic




  Conclusion: Fraud Perpetrators Look Exactly Like Us!




                               Who Commits Fraud?


While people who commit rape, murder, bank robbery and other
 property offenses have distinguishing characteristics, fraud
   perpetrators look more like more citizens than criminals!

                                                                       Bank Robbers
            Normal Citizens                Fraud Perpetrators
                                                                            Sample
                      Sample
                      S   l                         Sample
                                                    S   l




                                                              Major Differences
               No Significant Differences




  The “Red Flags” of fraud
  www.cfe-in-practice.net




  Given the “right
  circumstances”,
  circumstances”,                            Alcohol
                                                                      Gambling
  almost
  everyone can
  rationalize that it
  is OK to
                                     Profile of A Person
  commit fraud..Text
                                       Who Commits
                                            Fraud
                                                            Drugs

                               Sex




                                                       21




                                                                                             7
3/19/2009




                                                              1




STEP 1: EVALUATE THE ORGANIZATION'S FRAUD RISK FACTORS

To identify which factors increase the risk for fraud within
an organization, examiners should analyze industry and
business operations hold discussions with management
           operations,                         management,
review previous frauds committed against or on behalf of
the company, review company performance, and evaluate
similar frauds that occurred at competitors' organizations.




                                                              7




STEP 2: IDENTIFY POSSIBLE FRAUD SCHEMES

The ability to identify specific schemes resulting from fraud
risk factors depends on the examiner's knowledge of this
area. F d specialists, i l di
       Fraud       i li    including i di id l with certified
                                     individuals i h      ifi d
fraud examiner (CFE) designations and Certified Systems
Investigator (CSI) are ideal for this step of the process, as
they possess specialized knowledge of fraud detection and
investigation.



                                                              8




                                                                         8
3/19/2009




STEP    3:   PRIORITIZE     IDENTIFIED     FRAUD     RISKS

Fraud is not just an ordinary risk, but also an inherent and
significant one. Once the fraud schemes database is
populated, management and internal auditing should
identify the frauds that pose the greatest risk for the
organization.




                                                           9




Examiners should consider the following factors when
prioritizing fraud risks:

  Financial impact to the organization.

 Reputation risk of negative publicity associated with fraud.

 Loss of productivity.

 Potential criminal/civil actions taken against the
     organization. (Such as Data Breach EU95/46 on PII)

 Loss of company assets.
                                                           11




STEP 4: EVALUATE MITIGATING CONTROLS

Internal s Auditors with CFE qualifications are well-
positioned to review and counsel on the existence
and operational effectiveness of internal controls. In
      p
step four, the examiner/auditor should evaluate the
high-priority frauds and determine if the necessary
controls are in place to reduce the risk of
occurrence. This step takes time, as the auditor
should attempt to identify more than one control for
each fraud scheme.
                                                           12




                                                                       9
3/19/2009




www.cfe-in-practice.net




  Determination by                                                   Determination by
  Area                                                               Scheme




                                                                28




Fraud Consideration at all stages of engagement


                                   Perform Pre-Engagement
       PROFESSIONAL SKEPTICISIM




                                           Activities
                                             GATHER AN ASEESS




                                                                                 MENTATION
                                                FRAUD RISKS




                                  Perform Preliminary Planning
                                                     ND




                                                                             DOCUM




                                       Develop Audit Plan




                                       Perform Audit Plan



                                       Conclude & Report




                                    Fraud Risk Factors
                                             &
                                       Risk of Fraud




                                                                                                   10
3/19/2009




                   Questions?




CFE-In-Practice                               www.cfe-in-practice.net




                  Tommy Seah
                  Managing Partner
                  CFE-In-Practice
                  www.cfe-in-practice.com
                  phone +65 65171900
                    www.cfe-in-practice.net




                                                              32




                                                                              11

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Fraud Risk Management - Road Show in KL, Malaysia

  • 1. 3/19/2009 ACFE Regent Emeritus Tommy Seah presents Fraud Risk Management A Paradigm Shift 2009 1 “………….. financial institutions must have in place, all the necessary measures to deter or prevent fraud and constantly review all its controls and measures and also have in place a f d management function t fraud tf ti to prevent loopholes that fraudsters can exploit.” …… who said that ? 2 march 05, 2009 at Shangri-La hotel and the guest of honour was Ms Teo Swee Lian, Deputy Managing Di t MAS M i Director, MAS. 3 1
  • 2. 3/19/2009 Why is Internal Control Important? Financial Reporting • Promotes integrity of data used in making business decisions • Assists in fraud prevention and detection through the creation of an auditable trail of evidence Operations Promotes efficiency and effectiveness of operations through standardized Laws and Regulations processes Ensures the safeguarding of • Helps maintain compliance assets through control with laws and regulations through periodic monitoring activities 4 Limitations of Internal Control Errors may arise from misunderstandings of instructions, mistakes of judgment, fatigue, etc. Controls that depend on the segregation of duties may be circumvented by collusion Management may override the structure Compliance may deteriorate over time The Existing model Financial Control The Fraud Examiner The Certified System Investigator CFE CSI Compliance The Risk Management CPA,LLB, CSI Trinity CPA,CFA CSI of Controls Internal Audit CPA(CIA) CSI, CISA 6 2
  • 3. 3/19/2009 The Spectrum of Risk www.cfe-in-practice.net Liquidity Risk B A C Operational Credit Risk Risk What is Risk ? D E Reputational Market Risk Risk 7 www.cfe-in-practice.net “External” Audit Internal audit (COSO + COBIT+ ISO… Forensic audit Investigative auditing (Specific, Post event) ( suspicious, unusual activities, allegations) Eg. NKF, CAO E.g.. Money Laundering penetration Test 8 Fraud Control Principle F dC t lP i i l 3
  • 4. 3/19/2009 If an organisation accepts that it is exposed to fraud – and no organisation is immune to fraud – the next step is to apportion responsibility for fraud risk management. Copyright (c)2006 www.cfe-in-practice.net 10 The Paradigm Shift Financial Control The Fraud Examiner The Certified The CPA System Investigator CFE CSI Risk Compliance Management CPA,LLB, CSI CPA,CFA CSI S.T.A.R Strategic Tracking and Resolution Investigation FRM Unit Internal Audit Unit CPA(CIA) CSI, CISA 11 WHY is there a need for the paradigm shift ? Historically, the management of fraud risk does not lie with any one particular department or practitioner. Copyright (c)2006 www.cfe-in-practice.net 12 4
  • 5. 3/19/2009 It can be handled internally or be outsourced, and how it is handled is affected by many variables such as organizational size, industry sector, geographical location, cultural dynamics - and management perception of the problem. Copyright (c)2006 www.cfe-in-practice.net 13 Regardless of these variables, any fraud prevention and control model should aim to achieve one, or all, of the five primary objectives: Copyright (c)2006 www.cfe-in-practice.net 14 The five primary objectives: _ Prevention _ Deterrence _ Disruption – _ Identification _ Civil action/criminal prosecution Copyright (c)2006 www.cfe-in-practice.net 15 5
  • 6. 3/19/2009 The Fraud Triangle. Fraud Risk Fraud Risk Management Management Perceived Opportunity Auditor’s Domain Who Commits Fraud? What type of individual commits FRAUD? It is not limited to any one type of person. www.cfe-in-practice.org Married Active religious members Children Good education First-time offenders Good employees Don’t abuse alcohol 6
  • 7. 3/19/2009 Optimistic High self-esteem Achieving Family harmony Socially conforming Self control Kind Sympathetic Conclusion: Fraud Perpetrators Look Exactly Like Us! Who Commits Fraud? While people who commit rape, murder, bank robbery and other property offenses have distinguishing characteristics, fraud perpetrators look more like more citizens than criminals! Bank Robbers Normal Citizens Fraud Perpetrators Sample Sample S l Sample S l Major Differences No Significant Differences The “Red Flags” of fraud www.cfe-in-practice.net Given the “right circumstances”, circumstances”, Alcohol Gambling almost everyone can rationalize that it is OK to Profile of A Person commit fraud..Text Who Commits Fraud Drugs Sex 21 7
  • 8. 3/19/2009 1 STEP 1: EVALUATE THE ORGANIZATION'S FRAUD RISK FACTORS To identify which factors increase the risk for fraud within an organization, examiners should analyze industry and business operations hold discussions with management operations, management, review previous frauds committed against or on behalf of the company, review company performance, and evaluate similar frauds that occurred at competitors' organizations. 7 STEP 2: IDENTIFY POSSIBLE FRAUD SCHEMES The ability to identify specific schemes resulting from fraud risk factors depends on the examiner's knowledge of this area. F d specialists, i l di Fraud i li including i di id l with certified individuals i h ifi d fraud examiner (CFE) designations and Certified Systems Investigator (CSI) are ideal for this step of the process, as they possess specialized knowledge of fraud detection and investigation. 8 8
  • 9. 3/19/2009 STEP 3: PRIORITIZE IDENTIFIED FRAUD RISKS Fraud is not just an ordinary risk, but also an inherent and significant one. Once the fraud schemes database is populated, management and internal auditing should identify the frauds that pose the greatest risk for the organization. 9 Examiners should consider the following factors when prioritizing fraud risks: Financial impact to the organization. Reputation risk of negative publicity associated with fraud. Loss of productivity. Potential criminal/civil actions taken against the organization. (Such as Data Breach EU95/46 on PII) Loss of company assets. 11 STEP 4: EVALUATE MITIGATING CONTROLS Internal s Auditors with CFE qualifications are well- positioned to review and counsel on the existence and operational effectiveness of internal controls. In p step four, the examiner/auditor should evaluate the high-priority frauds and determine if the necessary controls are in place to reduce the risk of occurrence. This step takes time, as the auditor should attempt to identify more than one control for each fraud scheme. 12 9
  • 10. 3/19/2009 www.cfe-in-practice.net Determination by Determination by Area Scheme 28 Fraud Consideration at all stages of engagement Perform Pre-Engagement PROFESSIONAL SKEPTICISIM Activities GATHER AN ASEESS MENTATION FRAUD RISKS Perform Preliminary Planning ND DOCUM Develop Audit Plan Perform Audit Plan Conclude & Report Fraud Risk Factors & Risk of Fraud 10
  • 11. 3/19/2009 Questions? CFE-In-Practice www.cfe-in-practice.net Tommy Seah Managing Partner CFE-In-Practice www.cfe-in-practice.com phone +65 65171900 www.cfe-in-practice.net 32 11