While there is no sure-fire way to eliminate fraud - and
if there were, the cost would be prohibitive - with proper attention by management it can be
minimized. This article explores various steps we can all take to sharpen our fraud detection
and prevention skills.
Part of the fraud problem is perception. For example,
one controller said that "2% shrinkage is normal in our
industry; we are pleased that our experience is just under
that amount." When asked what caused the shrinkage, she
had no idea. She had already decided not to worry about
it - even though the loss totaled about $1.5 million a
year - because the unstated assumption was that it wasn't
possible in her industry to reduce shrinkage below the
2% "normal amount." When it was pointed out that
real issue was acceptable theft levels rather than acceptable
shrinkage levels, she changed her thinking. After an investigation,
she discovered that the inventory was systematically being
stolen from warehouses.
Employees and
managers who review all transactions are in the best position to notice when something is
fishy. Effective managers should issue policy guidelines that, in effect, tell each employee, "You are responsible for being aware of what can go wrong in your area. You are also
responsible for detecting wrongdoing when it does occur." Everyone - including auditors -
should be on the alert and at least look for those frauds that only he or she is in a position
to detect.
To get better at finding fraud, auditors, employees and managers should follow
the following four-step approach.
1. FOCUS ON THE POSSIBILITIES
Before getting down to the detailed job of devising controls, do some
research on what can go wrong. Employees are very good at finding the signs of problems - once
they are told what to look for. Most financial and operating professionals have only a passing
knowledge of the specific cons used by white-collar thieves. We hear about schemes involving
credit cards, fake vendors, inventory theft, kickbacks, bad loans, earnings manipulation, and
other cases, but few managers and employees really know the details of these deceptions.
Managers
who have been defrauded often say, "But we had controls in place to prevent this from happening!" Hard as it is to accept, most prevention controls can be beaten by a motivated thief. And when
thieves are inside the organization, they may be part of the control effort itself.
Start with
finding out how past defrauders have pulled off their crooked acts. What was the thief's role
in or relationship with the organization that gave him or her the freedom to commit the act?
Ask yourself how management steps like downsizing, outsourcing, computerization and globalization
affect the reliability of controls - as wells as the attitudes of those who have access to the assets.
Other places to look for help include industry sources.
Many industry organizations maintain data on fraud cases.
Since banks, insurers and others all support prevention,
they keep useful information on the subject. In addition,
seek out the security professionals working in your industry
for guidance.
Keep and
share files on news reports of fraud. These articles often contain enough detail to allow you to
understand how the deed was done. But be careful not to get caught up in the drama of the fraud:
Put less emphasis on the thieves and their reasons for stealing, focusing instead on the modus operandi.
Certainly take advantage of any formal training on fraud detection that's available. The American
Institute of CPAs, Institute of Internal Auditors, Association of Certified Fraud Examiners and
other professional associations frequently sponsor educational programs on this subject.
To begin the research in your own organization, first
check with those that might have been involved in handling
fraud: security, audit, legal, information systems, human
resources and other pertinent departments. Confidentiality
of past cases can be maintained because you do not need
to know who did what. All you need to know is what happened
and how.
Next examine potential fraud exposures
by functional area. Start with current job positions in each area. Include external parties.
Then brainstorm with colleagues how individuals in each of these positions could defraud the
organization - focusing on the opportunities presented by the position, not the identity of the
individual who currently occupies the position.
Typical questions you should ask:
What jobs are likely to provide opportunities for fraud?
What opportunities exist for employees, executives, vendors,
contractors, agents, customers and others?
How could they get around approval or transaction confirmation controls?
What general ledger accounts and cost centers could the fraud be
charged to?
How could the thief deceive the manager in charge of those cost centers
when the month end cost center reports are reviewed in detail?
After completing such research, begin to look at the controls that are in place.
Make sure the current controls go beyond preventing fraud.
Tell employees who to contact when they suspect fraud.
2. KNOW THE INDICATORS
Fraud indicators - the specific observable signs that fraud may be
present - may be of the actual fraud or of the cover-up attempt.
The easiest indicators to spot involve cash and inventory shortages.
But even there, clever thieves find ways to obscure the indicator.
For example, it's hard to tell immediately whether missing original
documentation may be due to filing errors or because someone destroyed
the documents to cover up a theft.
Here's a short list of some fraud indicators:
Missing or inadequate documentation.
Multiple endorsements on commercial checks.
The use of common or repetitive names for refunds - such as Smith or
Jones - or a commercial name that is very similar to one in the
industry but has slightly different spelling.
Line items in standard reconciliations that don't go away.
Customer complaints about having paid invoices for which
they are being dunned.
Adjustments to either inventory records or customer accounts.
The address of a vendor is the same as the address of an employee.
No proceeds are received from the sale of used assets.
Accounting entries after the books are closed that have a
significant effect on results.
When one of these indicators appears, use caution. Often there
are reasonable explanations and they usually don't lead to a thief -
just an error or a poorly designed process. So don't jump to
conclusions. Instead, track down the cause for the indicator.
3. DESIGN CONTROLS AND AUDIT PROCEDURES
TO LOOK FOR INDICATORS
The conventional control procedures used to identify
errors or irregularities include quality assurance programs, sampling and reperforming
the work of subordinates, review of unusual transactions on edit and cost center reports,
and detail review and approval of reconciliations. When segregation of duties is
impractical, and in areas offering high opportunity - such as cash handling, funds
transfer and inventory - pay extra attention, asking detailed questions about the process
and the controls.
In developing procedures, be sure to include specific steps calculated
to look for fraud indicators. And while measuring fraud exposure, assess the reliability
of such controls.
Auditors should include steps in their programs designed
to both identify fraud indicators and to bring them to
the surface. Testing plans should consider both the fraud
exposures and the reliability of internal controls. Building
audit programs to look for fraud indicators (as is required
by Statement of Auditing Standards 99, Consideration of
Fraud in a Financial Statement Audit) includes selecting
large samples to look for fraud indicators and the use
of computer retrieval and matching techniques.
Auditors must remember
that in deciding sample sizes, they are also deciding the probability of having the opportunity
to detect fraud and other problems. The probability depends on the amount of fraud, the size
of the population, and the number of sample items selected for testing. Stratification of the
population, directed sampling and discovery sampling may prove helpful.
4. FOLLOW THROUGH ON ALL INDICATORS OBSERVED
Whoever finds an indicator of fraud - the external
or internal auditor or an employee of the organization - should resolve the
situation before going on. Operate with an attitude of healthy professional
skepticism. Beware of pressures to complete work within unreasonable deadlines.
Be aware that the single indicator you have discovered may not be an isolated
occurrence; it may be one of many.
If you believe the follow-up is beyond your
capabilities, consider giving the problem to a professional investigator. There
are legal and other dangers inherent in mishandling possible fraud cases.
The
bottom line is this: The only way to protect against fraud is to be sure that
the organization's managers and employees stay alert to the possibilities and
maintain a proactive role.
The construction company's project manager engineered
a simple scam that earned him about $250,000 before he was unmasked. Here's how
he did it - and how he was tripped up: The project manager opened a bank account
using a name very similar to the name of the construction project he was managing.
He then approached three major suppliers and requested cash rebates in excess of
normal industry practice. In exchange, he guaranteed each would be the sole source
for their respective products. In addition, he promised that they would be paid
promptly for all materials delivered. He told them that rebates were due on the
first of each month for all transactions of the preceding month. The checks were
to be made payable to the name on the bogus bank account. The suppliers agreed
to the unusual terms in order to secure the business. None questioned the name
on the checks because it was close enough to the actual project name. The arrangement
worked smoothly for several months. Rebate checks were delivered to the project
manager each month, and he deposited them into his account. After the checks
cleared, he withdrew most of the funds using cashier's checks. The scheme came to
light when a supervisor in the construction company's accounts payable department
questioned why the three suppliers weren't offering prompt-payment discounts.
She had just attended a fraud awareness seminar and remembered that such an unusual
arrangement might be an indicator of fraud. Rather than question either the project
manager or the suppliers, she correctly referred the matter to the corporate audit
department for investigation. The auditors made simultaneous unannounced visits to
all three suppliers. Two wouldn't talk, but the third explained the relationship
and provided copies of the cancelled rebate checks.
Lessons learned from the case:
It's relatively easy to open unauthorized bank accounts because
most banks have limited ability to verify the identity of the person opening an account.
Scam artists know how to cash checks - to any payee, in any amount.
Schemes that involve relationships with suppliers are
particularly hard to prevent and detect.
When contracting with suppliers, try to secure the right to
review any appropriate records. While this "right to audit"
is fairly common in the contracting environment, it's also
something to consider for other relationships in which purchase
orders are used.