Fraud and Risk Management

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Fraud and Risk Management document sample

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							      Business Practices for Fraud Risk
               Management




     Jeffrey S. Zanzig
Jacksonville State University

            And

      Dale L. Flesher
The University of Mississippi
      Presentation
         Topics
 I.   Background Information

   II. Risk Assessment and
     Common Control Activities

 III. Fraud Case Management

IV. Controlling Employee Fraud

      V. Closing the Gaps
I. Background Information
          A. Motivation of Research

          B. Development of Survey
              Topics and Ratings

                C. Gender of
                 Respondents

           D. Organization Types
                 Represented
         A. Motivation of Research




Deficiencies in the fraud risk practices of organizations
  should be clearly identified in order to show where
         emphasis for improvement is needed.
B. Development of Survey Topics and
             Ratings




                      Gaps
C. Gender of Respondents
          No
       Response
          2%




                  Male
                  39%



     Female
      59%
D. Organization Types Represented

35                         33

30

25

20     18                            19

15

10
                  6
5

0
     Industry Education Financial   Other
II. Risk Assessment and Common
          Control Activities
           Risk Assessment and Controls
     1. An organizational process is in place to
  perform a cost-benefit analysis of implementing
      controls for significant fraud exposures.

  Organizations are unlikely to invest in controls unless they
   feel like they are getting something for their investment.


              1         2          3         4          5
          Strongly                                  Strongly
          Disagree   Disagree   Uncertain   Agree    Agree     Mean
Current    5.3%       30.3%      18.3%      39.5%    6.6%       3.12
Desired      --       3.9%        1.4%      57.9%    36.8%      4.28
           Risk Assessment and Controls
   2. Organizational policies for fraud detection
     include technology controls that perform
   continuous operations auditing by identifying
     unusual situations in large populations of
                   transactions.
     Fraud detection can be difficult when occurrences are
                 isolated and cleverly hidden.

              1         2          3         4          5
          Strongly                                  Strongly
          Disagree   Disagree   Uncertain   Agree    Agree     Mean
Current    6.6%       11.8%      13.2%      50.0%    18.4%      3.62
Desired      --         --        2.6%      38.2%    59.2%      4.57
            Risk Assessment and Controls
     3. An organizational process is in place to
  identify and assess the potential significance of
                  fraud-related risks.

     An effective system of risk assessment is needed to
             establish proper control procedures.



              1         2          3         4          5
          Strongly                                  Strongly
          Disagree   Disagree   Uncertain   Agree    Agree     Mean
Current    2.6%       5.3%       13.1%      48.7%    30.3%      3.99
Desired      --         --        2.6%      21.1%    76.3%      4.74
              Risk Assessment and Controls
  4. Organizational policies for fraud detection include
     organizational process controls such as periodic
    reconciliation of assets with records and physical
     asset inspections that are regularly performed.

   Verification of records against assets is a long-accepted
                        practice in audit.


              1         2          3         4          5
          Strongly                                  Strongly
          Disagree   Disagree   Uncertain   Agree    Agree     Mean
Current    1.3%       3.9%        6.6%      42.1%    46.1%      4.28
Desired      --         --        1.3%      34.2%    64.5%      4.63
III. Fraud Case Management
             Fraud Case Management
 1. The organization maintains a fraud investigation
program that logs all allegations of fraud into a case
               management system.

  An integrated and standardized case management system
          assists in proper evaluation and follow-up.

              1         2          3         4          5
          Strongly                                  Strongly
          Disagree   Disagree   Uncertain   Agree    Agree     Mean
Current    3.9%       13.2%      11.8%      38.2%    32.9%      3.83
Desired      --         --        3.9%      38.2%    57.9%      4.54
              Fraud Case Management
 2. The organization maintains a fraud investigation
 program that includes personnel with appropriate
authority and training to evaluate allegations of fraud
   and determine appropriate courses of actions.

 Personnel with appropriate authority and talent are necessary
    to ensure that fraud issues are appropriately handled.

               1         2          3         4          5
           Strongly                                  Strongly
           Disagree   Disagree   Uncertain   Agree    Agree     Mean
 Current    1.3%       10.5%       6.6%      46.1%    35.5%      4.04
 Desired      --         --         --       38.2%    61.8%     4.62*
             Fraud Case Management
3. The organization maintains a fraud investigation
 program that ensures that any material findings
   are reported to appropriate parties such as a
 company board of directors or audit committee.

  Ensuring high enough level personnel can help ensure that
there is appropriate discipline and changes in company policy.

              1         2          3         4          5
          Strongly                                  Strongly
          Disagree   Disagree   Uncertain   Agree    Agree     Mean
Current    1.3%       3.9%       14.5%      38.2%    42.1%      4.16
Desired      --         --         --       31.6%    68.4%     4.68*
              Fraud Case Management
4. Organizational policies for fraud detection include
providing a process for the submission of anonymous
       tips regarding the occurrence of fraud.

Preserving the anonymity of reporting parties can make people
              more willing to report fraud issues.


              1         2          3         4          5
          Strongly                                  Strongly
          Disagree   Disagree   Uncertain   Agree    Agree     Mean
Current    2.6%       1.3%        5.4%      36.8%    53.9%      4.38
Desired      --         --         --       30.3%    69.7%      4.70
 IV. Controlling
Employee Fraud
           Controlling Employee Fraud
 1. Employees normally understand how their job
  procedures are designed to manage fraud risks.
  Control procedures over fraud could be
      circumvented when situational
  pressures tempt employees to bypass
     normal procedures due to time
               constraints.

              1             2              3               4            5
          Strongly                                                  Strongly
          Disagree      Disagree       Uncertain        Agree        Agree     Mean
Current    1.3%          28.9%           18.5%          48.7%        2.6%       3.22
Desired      --           2.6%           1.4%           42.1%        53.9%     4.47*

                     * Distributions are significantly different.
            Controlling Employee Fraud
2. Employee policies include a requirement that all
employees receive initial and ongoing education in
the organization’s fraud risk management program.

 Organizations sometimes feel a conflict between trust and
                 working against fraud.

              1             2              3              4             5
          Strongly                                                  Strongly
          Disagree      Disagree       Uncertain        Agree        Agree     Mean
Current    5.3%          27.6%           21.0%          25.0%        21.1%      3.29
Desired      --           2.6%           3.9%           50.0%        43.5%     4.34*

                     * Distributions are significantly different.
              Controlling Employee Fraud
          3. Employees normally have a basic
          understanding of indicators of fraud.

    Despite the level of integrity of individual employees, a
  failure to recognize certain indicators of fraud could result
              in many situations going undetected.


              1             2              3               4            5
          Strongly                                                  Strongly
          Disagree      Disagree       Uncertain        Agree        Agree     Mean
Current      --          22.4%           9.2%           56.6%        11.8%      3.58
Desired      --           2.6%           2.6%           25.0%        69.8%     4.62*

                     * Distributions are significantly different.
           Controlling Employee Fraud
 4. Employee policies include compensation and
  promotion practices that emphasize long-run
performance on a variety of measures, rather than
  short-run performance using financial results.

  People often put more emphasis on what is measured as
          opposed to what is said to be important.

              1             2              3              4             5
          Strongly                                                  Strongly
          Disagree      Disagree       Uncertain        Agree        Agree     Mean
Current    2.6%          13.2%           21.0%          50.0%        13.2%      3.58
Desired      --             --           5.3%           43.4%        51.3%     4.46*

                     * Distributions are significantly different.
            Controlling Employee Fraud
    5. Employees normally know how to report
         suspicions or incidences of fraud.

 Fraud awareness may do little if employees are unaware
                of how to report fraud.




              1              2              3              4            5
          Strongly                                                  Strongly
          Disagree       Disagree      Uncertain         Agree       Agree     Mean
Current      --           10.5%           9.2%           46.1%       34.2%      4.04
Desired    1.3%            1.3%           1.3%           15.8%       80.3%     4.72*

                     * Distributions are significantly different.
            Controlling Employee Fraud
  6. Employee policies include verification of the
   work history and education of job applicants.


    Verification can provide evidence of both the personal
      integrity and competence of potential employees.


              1         2          3         4          5
          Strongly                                  Strongly
          Disagree   Disagree   Uncertain   Agree    Agree     Mean
Current    1.3%         --       15.8%      36.8%    46.1%      4.26
Desired      --         --        2.6%      32.9%    64.5%      4.62
      V. Closing the Gaps

A. Risk Assessment and
         Controls

    B. Fraud Case
      Management

C. Controlling Employee
          Fraud
              A. Risk Assessment and Controls
 Concept                                       Desired       Current        Mean
 Number                Concept                  Mean          Mean          Gap
               Cost-benefit analysis of
     1         implementing controls             4.28          3.12         1.16 *
               Technology controls for
     2         continuous operations             4.57          3.62         0.97 *
                      auditing

               Fraud identification and
     3             risk assessment               4.74          3.99         0.75 *
               Periodic reconciliation of
     4           assets with records             4.63          4.28          0.35


* Distributions are significantly different between current and desired situations.
            1. Cost Benefit Analysis
  Consider both a quantitative and
           qualitative analysis.
 Management could quantify known
benefits and compute a net present value.
 The needed soft benefits could then be
   estimated (see illustration below).
                               Illustration

Assume that management is considering implementing a control procedure over
   the next five years and has computed a negative net present value (NPV)
     $10,701.20. They could estimate the needed soft benefits as follows:


    $10,701.20 negative NPV =     $2,895.42 needed annual soft benefits
   3.6959 (PVIFA 11%, 5 years)
2. Implementing Technology Controls
                    Computer-based controls are such
                      that they can be made a part of
                     routine processing and be applied
                     to all transactions relevant to the
                        processing being conducted:
                      Payroll to terminated employees -
                    termination date is less than the date of
                             the current payroll period.
                    Fictitious vendors - match between the
                      phone numbers and/or addresses of
                              employees and vendors.
“Fraud Prevention and Detection in an Automated World” published
                   by the IIA in December 2009.
                   B. Fraud Case Management
 Concept                                       Desired       Current        Mean
 Number                Concept                  Mean          Mean          Gap
                  Case logging into
     1           management system               4.54          3.83         0.71 *
               Investigation personnel
     2        with authority and training        4.62          4.04         0.58 *

                   Reporting material
     3          findings to appropriate          4.68          4.16         0.52 *
                        parties
              Submission of anonymous
     4                  tips                     4.70          4.38          0.32

* Distributions are significantly different between current and desired situations.
   1. Logging Into a Case Management System
                                       “Our organization is
                                        very decentralized
                                          which makes it
                                         difficult to ensure
                                        that all frauds are
                                           investigated.”

                               Standardized Processing
   Integrated Storage        Standardization to some extent
Appropriate persons need to     is also necessary to ensure
   have access to consistent      that important company
        records of case        policies and laws are adhered
  information and evidence.    to regarding case processing.
                 C. Controlling Employee Fraud
 Concept                                         Desired       Current        Mean
 Number                  Concept                  Mean          Mean          Gap
                  Understand how job
     1          procedures manage fraud            4.47          3.22         1.25 *
               Ongoing education in fraud
     2             risk management                 4.34          3.29         1.05 *
                 Understanding of fraud
     3                 indicators                  4.62          3.58         1.04 *
              Long-run compensation and
     4           promotion practices               4.46          3.58         0.88 *
                Understand how to report
     5                   fraud                     4.72          4.04         0.68 *
               Verification of job applicant
     6                  information                4.62          4.26          0.36
* Distributions are significantly different between current and desired situations.
1-3. Fraud Understanding and Education
                        “I believe that education
                           of employees is key in
                            providing an effective
                               fraud program.
                                 Additionally,
                             management needs
                             to stand behind the
                                 program and
                            demonstrate support
                            through talking about
                              the program and
                               holding people
                                 responsible.”
                                                   1-3. Fraud
   One internal audit director holds classes
                                                 Understanding
 dealing with the prevention and detection of    and Education
fraud and ends the sessions with an unusual       (Continued)
    twist that the director calls “Rip Off the
   Organization”. During this exercise the
 professionals are asked to think like crooks
  and consider how they could defraud their
     company either internally or from the
                     outside.

  Banks, D.G. (2004). The Fight Against
  Fraud. Internal Auditor, April, pp. 34-39.
     4. Compensation and Promotion
               Practices



 Although equity-based compensation increases the
    productive effort of management, it also has the
  undesirable result of making fraud more attractive
                      to managers.
Bruner, D., McKee M. and Santore R. (2008). Hand in the Cookie Jar: An
     Experimental Investigation of Equity-Based Compensation and
   Managerial Fraud. Southern Economic Journal, 75(1), pp. 261-278.
4. Compensation and Promotion
     Practices (Continued)        The concept of a
                                 balanced scorecard
              People care more   considers both past
               about how their   financial results and
               performance is
               measured than
                                    forward-looking
             what someone says        areas such as
                is important!            process
                                  improvements and
                                     organizational
                                        learning.
We wish to express our sincere appreciation to the
 Birmingham Chapter of the Institute of Internal
      Auditors and their membership whose
    contributions made this research possible.

						
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