Occupational fraud is an ever-increasing cost to organizations in the United States
and worldwide. The Association of Certified Fraud Examiners (ACFE) estimates that a
typical organization loses approximately 5 percent of its gross revenues to fraud
annually, that's $2.9 trillion in gross world product.
So what does this mean to an average U.S.
company? According to the ACFE, more
than 56 percent of the cases investigated
and reported during 2009 and 2010
occurred in the U.S. Th e U.S. had the
lowest median loss per case at $105,000,
with the majority of fraud schemes
involving cash misappropriation. Europe
had the highest median loss of $600,000
with the highest amount of fraud
schemes involving corruption. A startling
25 percent of the cases investigated from 2007-2010 resulted in losses in excess of
$1 million, with the typical fraud scheme
underway at least two years prior to its
detection. Small businesses in the U.S.
are particularly vulnerable and realized
significantly higher median loss per case
at $150,000.
Larger and medium-sized organizations tend to have integrated financial systems that
replace manual processes typically found in smaller organizations. An integrated system
serves operational and anti-fraud control purposes. Solid financial systems have
controls built within that help ensure that subledgers reconcile to the general ledger,
transactions cannot be reopened and subsequently modified, and most importantly a
sophisticated audit trail. Audit trails keep a history of transactions, changes to
transactions and identifies the person involved and date and time of transactions. These trails enable critical forensic examiners to research questionable
transactions.
Increase anti-fraud controls
Anti-fraud internal controls in the following areas can help all businesses reduce
their fraud risks:
-
Cash schemes - Billing, skimming, larcenies,
check tampering, cash on hand, register disbursements and payments to employees
(expense reimbursement, benefits and payroll)
-
Non-cash - Inventory
-
Financial statement frauds
Understand occupational fraud
A solid anti-fraud program can reduce risk, deter employees considering fraudulent
activities, provide a mechanism for reporting suspected fraud, and demonstrate the
organization's intolerance policy. Anti-fraud measures and internal controls should be
customized based on specific risks faced by the organization and its operations.
The following fairly standard controls can easily be tailored and implemented
quickly and cost-effectively to help companies reduce their risk of fraud:
Fraud risk reductions
Code of business conduct and ethics
Establish a code of business conduct and ethics and disseminate it to all employees
annually for review and sign off . The code promotes honesty, ethics and integrity
within the organization, with demonstrated action by the senior officials and modeled
by each and every employee. Consult with your legal counsel before releasing your
company code to ensure it complies with applicable federal and state laws.
Employee handbook
Employee handbooks provide written guidance of the company's policies. Handbooks may
also contain methods to report violations of company policies. Again, consult with your
legal counsel to ensure federal and state employment law compliance.
Background checks
Verify an applicant's prior employment history and education as well as involvement in
any criminal and civil action. Oftentimes individuals who committed fraudulent actions
at a prior employer were not criminally prosecuted. However, they may have been sued
for damages in a civil action.
Job rotation and mandatory vacations
Requiring job rotation and mandatory vacations is one of the most impactful anti-fraud
controls a company can implement. Most asset misappropriation fraud schemes occur for a
considerable period of time prior to detection, generally 18 to 24 months, and need
constant attention from the perpetrator to avoid discovery.
Monitoring of bookkeeping
Careful monitoring of bookkeeping services performed by an outsourced service provider
is essential. Bookkeepers have access to cash receipts, cash disbursements and payroll
processing, areas at high risk of fraud. Management should consider requiring the firm
to provide proof of professional liability insurance. In addition, conduct background
checks on any individual the bookkeeping firm has working on your account, including
verification of their current CPA license with the Board of Accountancy. Monitor
individuals without CPA licensure to ensure they have the proper accounting knowledge
to perform these services. Currently, there are no licensing requirements for
bookkeeping services so additional diligence is practical.
What should you do if you suspect fraud?
Employee should discuss concerns with their immediate supervisor. If you believe
your supervisor might be involved, consider following the organization's procedures for
reporting concerns related to accounting, auditing and internal accounting controls. Be
as specific as possible, include the names of individuals you believe are involved,
dates the transactions occurred, identify information about the transactions (e.g.,
vendor name, vendor invoice number, journal entry reference number) and why you believe
the transactions were inappropriate.
Most organizations have a non-retaliation policy for reporting in good faith and
mechanisms to research and resolve reports of accounting, auditing and internal
accounting control concerns. If your organization does not have a reporting mechanism,
consider discussing your concerns with another member of management.
If you are part of a CPA firm hired by the organization, discuss your concerns
within the hierarchy of the firm. If you are the firm owner, discuss your concerns
with your client. These conversations can be a difficult; approach them with caution
and thought. Whether you discuss your concerns internally within the firm or directly
with the client, provide specific examples of the transactions. Focus on why the
transactions concern you rather than focusing on the individual or individuals who may
have been involved. Your client should discuss the matter with their legal counsel.
Business owners think fraud will never happen in their company, and when it does, it
can be devastating, both financially and through violation of trust. Oftentimes the
fraudster is in a position of trust and has been with the company for several years.
You are in the role of trusted advisor with a fiduciary responsibility to your client.
You must balance this responsibility with the risks you encounter if the person is
innocent. Determination of fraud is the role of a judge or jury during criminal
prosecution.
A proactive approach to fraud prevention reduces your company or your
clients' risk, protects their investment and conveys a high standard
of ethics and integrity within the organization. CPAs and internal audit experts play a
critical role in designing the appropriate internal controls based on the size and type
of organization as well as your product or service provided.
Abigail Grenfell is president of Internal Control & Anti-Fraud Experts, LLC,
a firm specializing in fraud prevention, detection and investigation, development of
anti-fraud programs, design and assessment of internal controls. She is a member of the
MNCPA and can be reached at abby.grenfell@icafemn.com.