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Tag Archives: Fraud Detection
Do We Owe It?
April 29, 2019 Accounts Payable Fraud, Billing Fraud, Forensic Accounting, Fraud Detection, Fraud Examination, theinnerauditor BlogAccounts Payable Fraud, Billing Fraud, forensic accounting, Fraud Detection, fraud examination, Fraud Preventionclawver
During one of our past May training events, our speaker, shared a fascinating, real life example from her own practice of how detailed analytic analysis could be especially helpful in addressing false billing frauds. In addition, she explained at length just how this type of fraud works.
In a false billing scheme, an employee or outside party creates false vouchers or submits false invoices to a target organizational payer. These documents cause the payer to issue payments for goods or services that are either completely fictitious or overstated in price. The perpetrator then collects the fraudulent payments/checks and converts them for personal use. Another common billing fraud involves buying personal goods or services with company money.
A false billing fraud affects the purchasing cycle, causing the company to pay for nonexistent or non-essential goods or services. Most false billing frauds involve a service, since it is easier to conceal a service that is never performed than to conceal goods never received. As our speaker's example demonstrated, the most common billing scheme, is setting up one or more bogus vendors. There are several ways to do this. The most common is to create a fictitious vendor (often called a shell company), open a bank account in the shell company's name, and bill the victimized company. The perpetrator then creates an invoice and sends it to his/her employer. Invoices can be professionally produced via computer and desktop publishing software, typewritten, or even prepared manually. Often, the most difficult aspect of a fraudulent billing scheme is getting the false invoice approved and paid. In many instances of billing fraud, the person perpetrating the fraud is also the person in the company who is authorized to approve invoices for payment. Another popular means of getting invoice approval is to submit invoices to an inattentive, trusting, or "rubber-stamp" manager. Furthermore, perpetrators often create false supporting documents to facilitate approvals and payments, e.g., voucher packages.
A perpetrator can also use a shell company to perpetrate a pass-through billing scheme: the perpetrator places orders for goods with his shell company, has his shell company order the goods from a legitimate supplier at market prices, and then sells those goods to his employer at inflated prices. The fraud lies in the fact that the victimized company is buying the goods it needs from an unauthorized vendor at inflated prices. The perpetrator "profits" from the inflated prices gained while acting as an unauthorized middle-man in a necessary company transaction.
Rather than utilizing shell companies to overbill, some employees generate false disbursements through invoices of non-accomplice vendors. In what is called a pay and return scheme, the perpetrator makes an error in a vendor payment to facilitate the theft. One way to do that is to overpay or double-up on payments, request a check from the vendor for the excess, and steal the check when it arrives. Another scenario is to pay the wrong vendor by placing vendor checks in the wrong envelopes, then calling the vendors to explain the mistake and requesting the return of the checks. When the checks return, they are stolen. The support documents are sent through the accounts payable system a second time; and these checks are sent to the proper vendors.
Another scheme involves purchasing personal items with company money. One popular way to do this is to make a personal purchase, then run the unauthorized invoice through the accounts payable system. If the perpetrator is not in a position to approve the purchase, s/he may have to create a false purchase order to make the transaction appear legitimate or alter an existing purchase order and have an accomplice in receiving remove the excess merchandise.
Another way to purchase personal items with company money is to have the company order merchandise, then intercept the goods when they are delivered. To avoid having the merchandise delivered to the company, the perpetrator often will have it diverted to their home or some other address, such as a spouse's business address. A third way to purchase personal items with company money is to make personal purchases on company credit cards. No matter which of the approaches is used, the perpetrator will either keep the purchases for personal use or turn the purchase into cash (or a credit card refund) by returning the merchandise.
Our event speaker pointed out that, in some ways, it's easier to conceal a billing fraud than other frauds, but in other ways, it's harder. It's easier in that the perpetrator does not have to remove cash or inventory from company premises; instead, the company mails her a check. It's more difficult in that, when the perpetrator creates a bogus vendor or shell company, s/he has to come up with a name, mailing address (often the fraudster's home address or a postal box), and phone number (often a home phone number); open a bank account in the shell company's name (usually requiring him or her to file or forge articles of incorporation) or in his own name; deposit and withdraw money; and create and send vendor invoices. Any of these can lead back to the perpetrator, making it easier to find him once the fraud is detected and the shell company identified.
Depending on the scheme and organizational controls in place, the perpetrator may have to falsify or alter a purchase requisition, purchase order, receiving report, or vendor invoice, or fool or force the authorizing person to approve or forge an authorization. Perpetrators involved in a pay and return fraud usually have to intercept any checks that are returned.
Our speaker additionally presented a number of red flags usually present when a false billing fraud is taking place, including:
• An unexplained increase in services performed (services that were paid for, but never performed);
• Payments to unapproved vendors;
• Invoices approved without supporting documents;
• Falsified or altered voucher documents; for example, altering a purchase order after its approval;
• Inflated prices on purchases or orders of unnecessary goods and services;
• Payments to an entity controlled by an employee;
• Multiple payments on the same invoice or over payments on an invoice;
• Personal purchases with company credit cards or charge accounts;
• Excessive returns to vendors, or full payment not received for items returned;
• A vendor with a post office box address (many post office box addresses are legitimate, but a smart.
On May 15-16th, 2019 our Chapter will be hosting a two-day ACFE lead seminar entitled, 'How to Testify'. Our speaker, Hugo Holland, wants to make a courtroom pro out of you! Learn how to testify effectively on direct and cross examination, basic courtroom procedures, and most important, tricks for surviving on the witness stand. Improve your techniques on how to offer testimony about damages and restitution while learning to know when to draw the line between aggressive testimony and improper advocacy. Walk away with more effective report writing skills and explore the different types of evidence and legal remedies in this 2-day, ACFE instructor-led course. To review the event content and to register to attend, click here. Hope you can join us!
Fraudsters, All Too Human
April 23, 2019 Anti-Fraud Training, Auditing for Fraud, Conducting Internal Investigations, Continuing Professional Education, Forensic Accounting, Fraud Detection, Fraud Examination, theinnerauditor Blogauditing of fraud, forensic accounting, Fraud Detection, fraud examination, fraud interviewingclawver
Our certified Chapter members often get questions from clients and employers related to why a fraudster who's victimized them did what he or she did. Examiners with the most experience in the process of interviewing those later convicted of fraud comment again and again about the usefulness to their overall investigation of a basic understanding of the fraudster's basic mind set. Such knowledge can aid the examiner in narrowing down the preliminary pool of suspects, and, most importantly, assist in gaining an admission in a subsequent admissions seeking interview. ACFE experts regard fraud (and the process of interviewing) primarily as human constructs, and especially within the content of the interview process, to be able to tie in the pressure that the individual might have been under (as they perceived it) to the interview process; to understand that individual with regard to their rationalization as they were able to affect it, significantly increases the possibility of getting the compliance and cooperation that the examiner wants from the interviewee.
During your investigation, it's important to remember that people do things for a reason. The fraud examiner might not understand the reasons a fraudster commits his or her crime, but the motivations certainly make sense to the perpetrator. For example, a perpetrator might commit fraud because her life has spiraled out of control, although it might not be out of control under a objective, reasonable person's definition. But in the perpetrator's view, her life has become so problematic that fraud is the only way she can see to restore balance. And during the fraud examination, if the examiner can get the suspected perpetrator to talk about the lack of control in her life, the examiner can often use this information to compel the fraudster to admit guilt and provide valuable insight into ways that similar frauds might be prevented in the future.
As a continuation of this line of thought, the examiner should consider possible human motives when examining evidence. Motive is the power that prompts a person to act. Motive, however, should not be confused with intent, which refers to the state of mind of the accused when performing the act. Motive, unlike intent, is not an essential element of crime, and criminal law generally treats a person's motive as irrelevant in determining guilt or innocence. Even so, motive is relevant for other purposes. It can help identify the perpetrator; it will often guide the examiner to the proper rationalization; it further incriminates the accused, and it can be helpful in ensuring successful prosecution.
The examiner should search relevant documents to determine a possible motive. For example, if a fraud examiner has evidence in the form of a paycheck written to a ghost employee, she might suspect a payroll employee who recently complained about not receiving a raise in the past two years. Although such information doesn't mean that the payroll employee committed fraud, the possible motive can guide the examiner.
ACFE experts also agree that interviewers should seek to understand the possible motives of the various suspects they encounter during an examination. To do this, interviewers should suspend their own value system. This will better position the interviewer to persuade the suspect(s) to reveal information providing insight into what might have pressured or motivated them and how they might have rationalized their actions. In an interview situation, the examiner should not suggest reasons for the crime. Instead, the examiner should let the individual share his motivations, even if the suspect reveals her motivations in an indirect manner. So when conducting an interview with a suspect, the interviewer should begin by asking questions about the standard procedures and the actual practice of the operations at issue. This is necessary to gain an understanding of the way the relevant process is intended to work as opposed to how it actually works. Additionally, asking such basic questions early in the interview will help the interviewer observe the interviewee's normal behavior so that the interviewer can notice any changes in the subject's mannerisms and word choice.
Always remember that there are times when rational people behave irrationally. This is important in the interview process because it will help humanize the misconduct. As indicated above, unless the perpetrator has a mental or emotional disorder, it is acceptable to expect that the perpetrator committed the fraud for a reason. Situational fraudsters (those who rationalize their right to an illegal enrichment and perpetrate fraud when the opportunity arises) do not tend to view themselves as criminals. In contrast to deviant fraudsters, who are more proactive than situational fraudsters and who are always on the alert for opportunities to commit fraud, situational fraudsters rationalize their crimes. Situational fraudsters feel that they need to commit fraud to regain control over their lives. Thus, an interviewer will be more likely to obtain a confession from a situational fraudster if she can genuinely communicate that she understands how anyone under similar circumstances might commit such a crime. Genuineness, however, is key. If the fraudster in any way detects that the interviewer is presenting a trap, he generally will not make any admission of wrongdoing.
So, in your examinations, never lose sight of the human element; that by definition, fraud involves human deception for personal gain. Why do people deceive to get what they want, or in some cases, what they need? Most humans commit deceptive acts to protect themselves from various consequences of the truth. Avoiding punishment is the most common reason for deception, but there are other reasons, including to protect another person, to win the admiration or respect of others, to avoid embarrassment, enjoy the thrill of accomplishment and to avoid hard work to achieve goals. When people feel that their self-security is threatened, they might resort to deception to preserve their image. Further, people can become so engaged in managing how others perceive them that they become unable to separate the truth from fiction in their own minds.
The ability to sympathetically cast oneself into the human situation of others is one of the most valuable skills that a fraud examiner can have in our efforts to determine the truth.
Detect and Prevent
January 14, 2019 Analytical Techniques, Anti-Fraud Policy, Employee Theft, Forensic Accounting, Fraud Detection, Fraud Examination, Fraud Prevention, theinnerauditor BlogEmployee Theft, forensic accounting, Fraud Detection, fraud examination, Fraud Preventionclawver
I got a call last week from a long term colleague, one of whose smaller client firms recently discovered a long running key-employee initiated fraud. My friend has been asked to assist her client in developing approaches to strengthen controls to, hopefully, prevent such disasters in the future.
ACFE training has consistently told us over the years, and daily experience repeatedly confirmed, that it is simply not possible or economical to stop all fraud before it happens. The only way for a retail concern to absolutely stop shoplifting might be to close and accept orders only over the Internet. Similarly, the only way for a bank to absolutely stop all loan fraud might be for it to stop lending money.
In general, my friend and I agreed during our conversation, that increasing preventive security can reduce fraud losses, but beyond some point, the cost of additional preventive security will exceed the related savings from reduced fraud losses. This is where detection comes in; it may be economical when prevention is not. One way to prevent a salesclerk from stealing from the register would be for the security department to carefully monitor, review, and approve every one of the clerk's sales. However, it would likely be much more cost effective instead to implement a simple detective control: an end-of-shift reconciliation between the cash in the register and the transactions logged by the cash register during the clerk's shift. If refunds are not given at the point of sale, the end-of-shift balance of cash in the register should equal the shift's sales per the transaction logs minus the balance of cash in the register at the beginning of the shift. Any significant failure of these numbers to reconcile would amount to a red flag. Of course, further investigation could show that the clerk simply made an error and so did not commit fraud.
But the cost effectiveness of detective controls, like preventive controls, imposes limits. First, such controls are not cost free to implement, and improving detective controls may cost more than the results they provide. Second, detective controls produce both false positives and false negatives. A false positive occurs when a detective control signals a possible fraud that upon investigation turns up a reasonable explanation for the indicator. A false negative occurs when a detective control fails to signal a possible fraud when one exists. Reducing false negatives means increasing the fraud detection rate.
Similarly, the cost effectiveness of increasing preventive security has a limit as does the benefit of increasing the fraud detection rate. To increase the detection rate, it's necessary to increase the frequency at which the detective control signals possible fraud. The result is more expensive investigations, and the cost of such additional investigations can exceed the resulting reduction in fraud losses.
As we all learned in undergraduate auditing, controls are essentially policies and procedures designed to minimize losses due to fraud or to other events such as errors or acts of nature. Corrective controls are merely special control types involved once a loss is known to exist. With respect to fraud, an important corrective control involves the investigation of potential frauds and the investigation and recovery process from discovered frauds.
More generally speaking, fraud investigations themselves serve not only a corrective function but also detective and preventive functions. Such investigations are detective of fraud to the extent that they follow up on fraud signals or red flags in order to confirm or disconfirm the presence of fraud. But once fraud is confirmed to exist, fraud examinations shift toward gathering evidence and become corrective by assisting in recovery from the perpetrator and other sources such as from insurance. Fraud investigations are also corrective in that they can lead to the revelation and repair of heretofore unknown weaknesses.
The end result is that the fraud investigation functions to correct the original loss, and the related discovery of the fraud scenario leads to prevention of similar losses in the future. In summary, the fraud examination has served to detect, correct, and prevent fraud. However, fraud investigations are not normally thought of as detective controls. This so is because fraud investigations tend to be much more costly than standard detective controls and therefore are normally used only when there is already some predication in the form of a fraud indicator triggered by a typical detective control. Therefore, the primary functions of fraud investigations are to address existing frauds and help to prevent future ones.
In some cases, the primary benefit of a fraud investigation might be to prevent future frauds. Even when recovery is impossible or impractical (e.g., because the thief has no assets), unwinding the fraud scheme may still have the benefit of leading to the prevention of the same scheme in the future. Furthermore, a company might benefit from spending a very large sum of money to investigate and prosecute a very small theft in order to deter other individuals from defrauding the company in the same way. Many State governments have statutes specifying that every fraud affecting governmental assets, whether large or small, must be fully investigated because taxpayer funds are involved (the assets affected are public property).
There is never a guarantee that investigating a fraud indicator will lead to the discovery of fraud. Depending on the situation, an investigation might lead to nothing at all (i.e., produce a reasonable explanation for the original red flag) or to the discovery of losses due to simple errors, waste, inefficiencies, or even uncontrollable events like acts of nature. If a lender is considering a loan application, a fraud indicator might indicate nothing, fraud, or an error. On the other hand, in regard to the possible theft of raw materials in a production process, a fraud indicator just might indicate undocumented waste or scrap.
Two important factors to consider concerning the general design of a fraud detection process are not only the costs and benefits of detecting, correcting, and preventing a given fraud scenario but also the costs and benefits of detecting, correcting, and preventing errors, waste, uncontrollable events, and inefficiencies in general. Of course, the particular costs that are relevant will vary from one type of business process to another.
As a general rule, we can say that both preventive controls and detective controls cost less than corrective controls. Corrective controls tend to involve hands-on, resource-intensive investigations, and in many cases, such investigations do not result in recovering the loss. On the other hand, preventive controls can also be quite costly. Banks pay armed guards and incur costs to maintain expensive vaults and alarm systems. Companies surround their headquarters with high fences and armed guards, and use security checkpoints and biometric key card systems inside. On the information technology side, firms use sophisticated firewalls and multi-layer access controls. The costs of all these preventive measures can add up to staggering sums in large companies. Of course, losses that are not prevented or corrected in a timely fashion can lead to the ultimate corrective measure: bankruptcy. In fact, some ACFE estimates show that about one-third of all business failures relate to some form of fraudulent activity.
One positive aspect of the cost of preventive controls is that unlike detective controls, they do not generate fraud indicators that lead to costly investigations. In fact, they tend to do their job in complete silence so that management never even knows when they prevent a fraud. The thick door of a bank vault with a time lock prevents bank employees from entering the building at night to steal its contents. Similarly, passwords, pin numbers, and biometric data silently provide access to authorized individuals and prevent access from others.
The problem with preventive controls is that they are always subject to circumvention by determined and cunning fraudsters. There is no perfect solution to preventing acts of fraud, so detection is necessary as a secondary line of defense, and in some cases, as the primary line of defense. Consider a lending company that accepts online loan applications. It may be difficult or impossible to prevent fraudulent applications, but the company can certainly put a sophisticated (and expensive) system in place to analyze applications and provide indicators that suggest when an application may be fraudulent.
In general, the optimal allocation of resources to prevention versus detection depends on the particular business process under consideration. So, there is no general rule that dictates the optimal allocation of resources between prevention versus detection. But there are some general steps that can assist in making the allocation:
1. Analyze the target business process and identify threats and vulnerabilities.
2. Select reasonable preventive controls according to the business process and customs within the client's industry.
3. Estimate fraud losses given the assumed preventive controls.
4. Identify and add a basic set of detective controls to the system.
5. For a given set of detective controls, identify the optimal mix of false negatives versus false positives. The optimal mix depends on the costs of investigations versus the costs of losses. Large losses and small investigation costs favor relatively low false negatives and high false positives for red flags.
6. Given the assumed mix of false negative and false positive errors, estimate the incremental cost associated with adding the detective (and related corrective) controls, and estimate the resulting reduction in fraud losses.
7. Compare the reduction in fraud losses with the increase in costs associated with adding the optimal mix of detection and correction controls.
8. If increase in costs is significantly lower than the related reduction in fraud losses, consider adding more detective controls. Otherwise, accept the set of detective controls under consideration.
Concealment Strategies & Fraud Scenarios
June 4, 2018 Asset Recovery, Auditing for Fraud, Concealment of Assets, Concealment Strategies, Financial Fraud, Forensic Accounting, Fraud Detection, Fraud Examination, theinnerauditor BlogConcealment Strategy, financial fraud, forensic accounting, Fraud Detection, fraud examinationclawver
I remember Joseph Wells mentioning at an ACFE conference years ago that identifying the specific asset concealment strategy selected by a fraudster was often key to the investigator's subsequent understanding of the entire fraud scenario the fraudster had chosen to implement. What Joe meant was that a fraud scenario is the unique way the inherent fraud scheme has occurred (or can occur) at an examined entity; therefore, a fraud scenario describes how an inherent fraud risk will occur under specific circumstances. Upon identification, a specific fraud scenario, and its associated concealment strategy, become the basis for fraud risk assessment and for the examiner's subsequent fraud examination program.
Fraud concealment involves the strategies used by the perpetrator of the fraud scenario to conceal the true intent of his or her transaction(s). Common concealment strategies include false documents, false representations, false approvals, avoiding or circumventing control levels, internal control evasion, blocking access to information, enhancing the effects of geographic distance between documents and controls, and the application of both real and perceived pressure. Wells also pointed out that an important aspect of fraud concealment pertains to the level of sophistication demonstrated by the perpetrator; the connection between concealment strategies and fraud scenarios is essential in any discussion of fraud risk structure.
As an example, consider a rights of return fraud scenario related to ordered merchandise. Most industries allow customers to return products for any number of reasons. Rights of return refers to circumstances, whether as a matter of contract or of existing practice, under which a product may be returned after its sale either in exchange for a cash refund, or for a credit applied to amounts owed or to be owed for other products, or in exchange for other products. GAAP allows companies to recognize revenue in certain cases, even though the customer may have a right of return. When customers are given a right of return, revenue may be recognized at the time of sale if the sales price is substantially fixed or determinable at the date of sale, the buyer has paid or is obligated to pay the seller, the obligation to pay is not contingent on resale of the product, the buyer's obligation to the seller does not change in the event of theft or physical destruction or damage of the product, the buyer acquiring the product for resale is economically separate from the seller, the seller does not have significant obligations for future performance or to bring about resale of the product by the buyer, and the amount of future returns can be reasonably estimated.
Sales revenue not recognizable at the time of sale is recognized either once the return privilege has substantially expired or if the conditions have been subsequently met. Companies sometimes stray by establishing accounting policies or sales agreements that grant customers vague or liberal rights of returns, refunds, or exchanges; that fail to fix the sales price; or that make payment contingent upon resale of the product, receipt of funding from a lender, or some other future event. Payment terms that extend over a substantial portion of the period in which the customer is expected to use or market the purchased products may also create problems. These terms effectively create consignment arrangements, because, no economic risk has been transferred to the purchaser.
Frauds in connection with rights of return typically involve concealment of the existence of the right, either by contract or arising from accepted practice, and/or departure from GAAP specified conditions. Concealment usually takes one or more of the following forms:
• Use of side letters: created and maintained separate and apart from the sales contract, that provide the buyer with a right of return;
• Obligations by oral promise or some other form of understanding between seller and buyer that is honored as a customary practice but arranged covertly and hidden;
• Misrepresentations designed to mischaracterize the nature of arrangements, particularly in respect of:
–Consignment arrangements made to appear to be final sales;
–Concealment of contingencies, under which the buyer can return the products, including failure to resell the products, trial periods, and product performance conditions;
–Failure to disclose the existence, or extent, of stock rotation rights, price protection concessions, or annual returned-goods limitations;
–Arrangement of transactions, with straw counterparties, agents, related parties, or other special purpose entities in which the true nature of the arrangements is concealed or obscured, but, ultimately, the counterparty does not actually have any significant economic risk in the "sale".
Sometimes the purchaser is complicit in the act of concealment, for example, by negotiating a side letter, and this makes detection of the fraud even more difficult. Further, such frauds often involve collusion among several individuals within an organization, such as salespersons, their supervisors, and possibly both marketing and financial managers.
It's easy to see that once a CFE has identified one or more of these concealment strategies as operative in a given entity, the process of developing a descriptive fraud scenario, completing a related risk assessment and constructing a fraud examination program will be a relatively straight forward process. As a working example, of a senario and related concealment strategies …
Over two decades ago the SEC charged a major computer equipment manufacturer with overstating revenue in the amount of $500,000 on transactions for which products had been shipped, but for which, at the time of shipment, the company had no reasonable expectation that the customer would accept and pay for the products. The company eventually accepted back most of the product as sales returns during the following quarter.
The SEC noted that the manufacturer's written distribution agreements generally allowed the distributor wide latitude to return product to the company for credit whenever the product was, in the distributor's opinion, damaged, obsolete, or otherwise unable to be sold. According to the SEC, in preparing the manufacturer's financial statements for the target year, company personnel submitted a proposed allowance for future product returns that was unreasonably low in light of the high level of returns the manufacturer had received in the first several months of the year.
The SEC determined that various officers and employees in the accounting and sales departments knew the exact amount of returns the company had received before the year end, when the company's independent auditors finished their fieldwork on the annual audit. Had the manufacturer revised the allowance for sales returns to reflect the returns information, the SEC concluded it would have had to reduce the net revenue reported for the fiscal year. Instead, the SEC found that several of the manufacturer's officers and employees devised schemes to prevent the auditors from discovering the true amount of the returns, including 1), keeping the auditors away from the area at the manufacturer's headquarters where the returned goods were stored, and 2), accounting personnel altering records in the computer system to reduce the level of returns. After all the facts were assembled, the SEC took disciplinary action against several company executives.
As with side agreements, a broad base of inquiry into company practices may be one of the best assessment techniques the CFE has regarding possible concealment strategies supporting fraud scenarios involving returns and exchanges. In addition to inquiries of this kind, the ACFE recommends that CFE's may consider using analytics like:
• Compare returns in the current period with prior periods and ask about unusual increases.
• Because companies may slow the return process to avoid reducing sales in the current period, determine whether returns are processed in timely fashion. The facts can also be double-checked by confirming with customers.
• Calculate the sales return percentage (sales returns divided by total sales) and ask about any unusual increase.
• Compare returns after a reporting period with both the return reserve and the monthly returns to determine if they appear reasonable.
• Determine whether sales commissions are paid at the time of sale or at the time of collection. Sales commissions paid at the time of sale provide incentives to inflate sales artificially to meet internal and external market pressures.
• Determine whether product returns are adjusted from sales commissions. Sales returns processed through the so-called house account may provide a hidden mechanism to inflate sales to phony customers, collect undue commissions, and return the product to the vendor without being penalized by having commissions adjusted for the returned goods.
A Blueprint for Fraud Risk Assessment
November 27, 2017 Fraud Detection, Fraud Examination, Fraud Management, Fraud Prevention, Fraud Reporting, theinnerauditor Bloganti-fraud program, Fraud Detection, fraud management, Fraud Prevention, Fraud Reporting, Fraud Risk Assessmentclawver
It appears that several of our Chapter members have been requested these last few months to assist their employers in conducting several types of fraud risk assessments. They usually do so as the Certified Fraud Examiner (CFE) member of their employing company's internal audit-lead assessment team. There is a consensus emerging among anti-fraud experts that conducting a fraud risk assessment (FRA) is critical to the process of detecting, and ultimately designing controls to prevent the ever-evolving types of fraud threatening organizations.
The ACFE tells us that FRAs do not necessarily specify what types of fraud are occurring in an organization. Instead, they are designed to focus detection efforts on specific fraud schemes and scenarios that could occur as well as on incidents that are known to have occurred in the past. Once these are identified, the audit team can proceed with the series of basic and specific fraud detection exercises that broad experience has shown to be effective. The objective of these exercises is to hopefully reveal the specific fraud schemes to which the organization is most exposed. This information will enable the organization's audit team to recommend to management and to support the implementation of antifraud controls designed to address exactly those risks that have been identified. It's important to emphasize that fraud risk assessments are not meant to prevent fraud directly in and of themselves. They are exercises for identifying those specific fraud schemes and scenarios to which an organization is most vulnerable. That information is in turn used to conduct fraud audit exercises to highlight the circumstances that have allowed actual, known past frauds to occur or to blueprint future frauds that could occur so that the necessary controls can be put in place to prevent similar future illegal activity.
In the past, those FRAs that were conducted were usually performed by the firm's external auditors. Increasingly, however, internal audit departments are being pressured by senior management to conduct FRAs of their own. Since internal audit departments are increasingly employing CFEs or have their expertise available to them through other company departments (like loss prevention or security), this effort can be effective since internal auditors have the tenure and experience with their organizations to know better than anyone how its financial and business operations function and can understand more readily how fraud could occur in particular processes, transactions, and business cycles.
Internal audit employed CFE's and CIA's aren't involved by requirement of their professional standards in daily operations and can, therefore, provide an independent check on their organization's overall risk management process. Audits can be considered a second channel of information on how well the enterprise's anti-fraud controls are functioning and whether there are any deficiencies that need to be corrected. To ensure this channel remains independent, it is important that the audit function report directly to the Audit Committee or to the board of directors and not to the chief executive officer or company president who may have responsibility for her company's internal controls.
The Institute of Internal Auditors has endorsed audit standards that outline the techniques and procedures for conducting an FRA, specifically those contained in Statement of Auditing Standards 99 (SAS 99). By this (and other) key guidelines, an FRA is meant to assist auditors and/or fraud examiners in adjusting their audit and investigation plans to focus on gathering evidence of potential fraud schemes and scenarios identified by the FRA.
Responding to FRA findings requires the auditor to adjust the timing, nature, and extent of testing in such ways as:
• Performing procedures at physical locations on a surprise or unannounced basis by, for example, counting cash at different subsidiary locations on a surprise basis or reviewing loan portfolios of random loan officers or divisions of a savings and loan on a surprise basis;
• Requesting that financial performance data be evaluated at the end of the reporting period or on a date closer to period-end, in order, for example, to minimize the risk of manipulation of records in the period between the dates of account closings and the end of the reporting period;
• Making oral inquiries of major customers and vendors in addition to sending written confirmations, or sending confirmation requests to a specific party within vendor or customer organization;
• Performing substantive analytical procedures using disaggregated data by, for example, comparing gross profit or operating margins by branch office, type of service, line of business, or month to auditor-developed expectations;
• Interviewing personnel involved in activities in areas where a risk of material misstatement due to fraud has been identified in the past (such as at the country or regional level) to obtain their insights about the risk and how controls could address the risk.
CFE team members can make a substantial contribution to the internal audit lead team effort since it's essential that financial operations managers and internal audit professionals understand how to conduct an FRA and to thoroughly assess the organization's exposure to specific frauds. That contribution can add value to management's eventual formulation and implementation of specific, customized controls designed to mitigate each type of fraud risk identified in the FRA. These are the measures that go beyond the basic, essential control checklists followed by many external auditors; they optimize the organization's defenses against these risks. As such, they must vary from organization to organization, in accordance with the particular processes and procedures that are identified as vulnerable to fraud.
As an example, company A may process invoices in such a tightly controlled way, with double or triple approvals of new vendors, manual review of all invoices, and so on, that an FRA reveals few if any areas where red flags of vendor fraud can be identified. Company B, on the other hand, may process invoices simply by having the appropriate department head review and approve them. In the latter case, an FRA would raise red flags of potential fraud that could occur through double billing, sham company schemes, or collusion between a dishonest vendor and a company insider. For that reason, SAS 99 indicates that some risks are inherent in the environment of the entity, but most can be addressed with an appropriate system of internal control. Once fraud risk assessment has taken place, the entity can identify the processes, controls, and other procedures that are needed to mitigate the identified risks. Effective internal controls will include a well-developed control environment, an effective and secure information system, and appropriate control and monitoring activities. Because of the importance of information technology in supporting operations and the processing of transactions, management also needs to implement and maintain appropriate controls, whether automated or manual, over computer generated information.
The ACFE tells us that the heart of an effective internal controls system and the effectiveness of an anti-fraud program are contingent on an effective risk management assessment. Although conducting an FRA is not terribly difficult, it does require careful planning and methodical execution. The structure and culture of the organization dictate how the FRA is formulated. In general, however, there is a basic, generally accepted form of the FRA that the audit and fraud prevention communities have agreed on and about which every experienced CFE is expected to be knowledgeable. Assessing the likelihood and significance of each potential fraud risk is a subjective process that should consider not only monetary significance, but also significance to an organization's reputation and its legal and regulatory compliance requirements. An initial assessment of fraud risk should consider the inherent risk of a particular fraud in the absence of any known controls that may address the risk. An organization can cost-effectively manage its fraud risks by assessing the likelihood and significance of fraudulent behavior.
The FRA team should include a senior internal auditor (or the chief internal auditor, if feasible) and/or an experienced inside or outside certified fraud examiner with substantial experience in conducting FRAs for organizations in the company's industry. The management of the internal audit department should prepare a plan for all the assignments to be performed. The audit plan includes the timing and frequency of planned internal audit work. This audit plan is based on a methodical control risk assessment A control risk assessment documents the internal auditor's understanding of the institution's significant activities and their associated risks. The management of the internal audit department should establish the principles of the risk assessment methodology in writing and regularly update them to reflect changes to the system of internal control or work process, and to incorporate new lines of business. The risk analysis examines all the entity's activities, and the complete internal control system. Based on the results of the risk analysis, an audit plan for several years is established, considering the degree of risk inherent in the activities. The plan also considers expected developments and innovations, the generally higher degree of risk of new activities, and the intention to audit all significant activities and entities within a reasonable time period (audit cycle principle for example, three
years). All those concerns will determine the extent, nature and frequency of the assignments to be performed.
• A fraud risk assessment is an analysis of an organization's risks of being victimized by specific types of fraud;
• Approaches to FRAs will differ from organization to organization, but most FRAs focus on identifying fraud risks in six key categories:
— Fraudulent financial reporting;
— Misappropriation of assets;
— Expenditures and liabilities for an improper purpose;
— Revenue and assets obtained by fraud;
— Costs and expenses avoided by fraud;
— Financial misconduct by senior management.
• A properly conducted FRA guides auditors in adjusting their audit plans and testing to focus specifically on gathering evidence of possible fraud;
• The capability to conduct an FRA is essential to effective assessment of the viability of existing anti-fraud controls and to strengthen the organization's inadequate controls, as identified by the results of the FRA;
• In addition to assessing the types of fraud for which the organization is at risk, the FRA assesses the likelihood that each of those frauds might occur;
• After the FRA and subsequent fraud auditing work is completed, the FRA team should have a good idea of the specific controls needed to minimize the organization's vulnerability to fraud;
• Auditing for fraud is a critical next step after assessing fraud risks, and this requires auditing for evidence of frauds that may exist according to the red flags identified by the FRA.


text:
Sommelsdijk is een dorp in de gemeente Goeree-Overflakkee, in de Nederlandse provincie Zuid-Holland, gelegen op het gelijknamige eiland Goeree-Overflakkee. Vroeger maakte het als enige dorp op het eiland deel uit van het gewest Zeeland. In 1805 werd Sommelsdijk Hollands (later Zuid-Hollands), en dat bleef zo bij de grondwetswijziging van 1814. Op  had Sommelsdijk  inwoners, waarmee het (na Middelharnis) op een na grootste dorp van Goeree-Overflakkee is. Het dorp is vastgegroeid aan Middelharnis. Tot 1966 vormde Sommelsdijk een aparte gemeente, nadien maakte het deel uit van gemeente Middelharnis en inmiddels van gemeente Goeree-Overflakkee.

In de Tweede Wereldoorlog werden begin maart 1941 bijna tweehonderd jonge mannen uit Sommelsdijk een maand in Kamp Schoorl geïnterneerd wegens belediging van het Duitse leger en de Nederlandse politie.

Etymologie
Sommelsdijk heette eerder Sonnemaresdijk. Het lag in het historische decanaat Voorne tussen Masaland en Scaldemarland. Goeree-Overflakkee vormde vroeger als Westvoorn (Goeree) en Zuidvoorn (Overflakkee) met het tegenwoordige Voorne onderdeel van het Land van Voorne. Dit hele gebied werd eerder Sunnonmeriland genoemd: land 'ten zuiden van' (sunnon) 'zee of water' (meri)'. Oorspronkelijk was het dan ook een plaatsaanduiding ten zuiden van de zeearm het Haringvliet, rondom de voormalige hoofdplaats Ouddorp. Later ging de naam vanwege het belang van die plaats over op het hele land van Voorne. De naam is wellicht (gedeeltelijk) gelijk te stellen met de al in 985 genoemde villa Sunnemeri, waarin goederen lagen die keizer Otto III (983-1002) aan de Hollandse graaf Dirk II (939-988) schonk. Vergelijk ook Zonnemaire. Sommeldijk betekent dus: dijk van Sunnonmeriland, waarmee oorspronkelijk land werd bedoeld ten zuiden van de zee.

Bezienswaardig
De kerk met omgeving van Sommelsdijk is een beschermd dorpsgezicht samen met Middelharnis. De Hervormde Kerk aan de Ring was ooit de grootste kerk van het eiland Goeree-Overflakkee, maar na diverse branden en andere beschadigingen is er van het oorspronkelijke gebouw niet veel meer over.

Naast de kerk is in zeven onderling verbonden historische panden het Streekmuseum Goeree-Overflakkee gevestigd. De Voorstraat heeft enkele monumentale panden uit de zeventiende, achttiende en negentiende eeuw. Aan de Westdijk staat een stellingmolen genaamd De Korenbloem.

Verder telt de plaats tientallen rijksmonumenten.

Hervormd Sommelsdijk
De geschiedenis van de hervormde gemeente begint in 1573 met de overkomst van ds. A. F. de Steur. Tijdens de ambtsperiode van ds. Wilhelmus à Brakel van der Kluit, kleinzoon van de bekende Wilhelmus à Brakel, maakte de gemeente een turbulente tijd mee. In 1739, tegen het einde van zijn ambtsperiode waarschuwde hij de gemeente vanaf de preekstoel tegen het omstreden boekje van Johannes Eswijler, Zielseenzame meditatiën. Eswijler leverde kritiek op de kerk en predikanten van zijn tijd, de late 17e eeuw. Hij keerde zich tegen een vorm van christendom die zich vooral bezighield met uiterlijke regels en wetten en pleitte voor een innig christendom, zoals dat later ook door Wilhelmus Schortinghuis werd verkondigd. Eswijlers boekje werd door velen gretig gelezen en veroorzaakte in vele gemeenten conflicten. De grote nadruk waarmee À Brakel maar bleef waarschuwen tegen de piëtistische opvattingen uit het boekje, dat nauwelijks bekend was bij zijn gemeenteleden, werkte juist averechts. Velen keerden zich van zijn prediking af. Jarenlang heeft deze kwestie de gemeente beroerd. Vooral omdat À Brakel zich ook na zijn emeritaat in 1748 meer dan eens openlijk verzette tegen de prediking van zijn opvolgers, waarin hij opnieuw piëtistische opvattingen meende aan te treffen. Ook na zijn dood in 1762 duurde het nog zeker vijftien jaar voordat de eenheid in de gemeente werd hersteld.

Afscheiding en Doleantie gingen niet zonder meer aan Sommelsdijk voorbij. Tijdens de periode van ds. M. L. Reyerkerk (1838-1874) kwam het tot een ingrijpende confrontatie tussen de liberale overmacht en een orthodoxe minderheid. De liberale prediking van ds. Reyerkerk stuitte op toenemend verzet. Men verzocht deze predikant zijn ambt neer te leggen. Uiteindelijk brokkelde de liberale hegemonie af. De daaropvolgende predikanten waren meer confessioneel getint. Vanaf 1921 werd de gemeente gediend door predikanten behorend tot de Gereformeerde Bond. In 2004 vond in de gemeente een grote scheuring plaats. Een derde van de gemeenteleden vertrok naar de Hersteld Hervormde Kerk. Inmiddels heeft er groei in de gemeente plaatsgevonden door aanwas vanuit andere kerkverbanden. De gemeenschap van Sommelsdijk staat bekend als een van de meest kerkelijke binnen Nederland. De zondagsrust wordt nog sterk in acht genomen en de kerkdiensten in de plaatselijke kerken worden druk bezocht. Sommelsdijk en Middelharnis tellen dan ook 14 verschillende kerkgenootschappen, variërend van evangelisch, remonstrants, gereformeerd tot de Jehovagetuigen. Er zijn ook twee basisscholen: De school met de Bijbel (reformatorisch/protestants- christelijk) en de (openbare) J.C. van Gentschool.

De Westplaat
De Westplaat is de nieuwbouwwijk van Sommelsdijk en Middelharnis. Begin 2000 is men begonnen om de toenmalige landbouwgronden om te vormen naar een nieuwe woonwijk. Door deze ontwikkeling is het dorp sterk gegroeid. Er worden bijna nog jaarlijks huizen bijgebouwd.

Dorpen in de buurt
Nieuwe-Tonge, Melissant, Middelharnis, Herkingen, Stad aan 't Haringvliet en Dirksland.

Geboren in Sommelsdijk

 Jan Knape Mzn (1900-1979), romanschrijver en bestuurder
 J.B. Philibert (1931-2020), scriba van de Oud Gereformeerde Gemeenten in Nederland
 Theo van den Doel (1952), politicus (VVD)
 Maarten Vonder (1953), dramaturg, toneelschrijver/-vertaler
 Arie Luyendyk (1953), autocoureur
 Dustin Mijnders (1995), voetballer

Overleden in Sommelsdijk
 Pim van der Harst (1994), politicus

Zie ook
 Lijst van burgemeesters van Sommelsdijk

Externe links
 Website Goeree-Overflakkee
 Geschiedenis van de grenzen van Zuid-Holland
 Website Hervormde Gemeente Sommelsdijk
 Website Streekmuseum Goeree-Overflakkee

Plaats in Zuid-Holland
Geografie van Goeree-Overflakkee
Voormalige gemeente in Zuid-Holland

redpajama_set_name: RedPajamaWikipedia


ISW's India Day celebration on August 13, 2016 at the DCU Center, Worcester was a great success. people from the Worcester community and beyond attended. Hundreds of performers put on a diverse mix of song and dances from more than 25 different States of India. The food vendors provided a delicious variety of foods from chaat, chicken pops, noodles, sabzis, and much more. And those who love to shop were not disappointed: they had plenty of saris, jewelry, and crafts to choose from.
Mayor Joseph Petty of Worcester read a declaration recognizing India Day and the 69th anniversary of India's independence.
ISW did their first ever hike to top of Mt. Wachusett. A lot of children, and adults joined the hike. We started from the ski lodge and took the Old Indian Trail to the top. The top is at about 2200 Feet. The trail was rockey and steep and people found the hike invigorating. Once at the top, everyone shared the snacks they had brought, enjoyed the nice weather and then everyone hiked back down. A group of people took the Pine Hill Trail down the mountain and some others went down the main road.
We had another successful event of Satsang/ Sadhana this month. Pushpa Joshi and Nisha Bawa graciously sponsored this event at India Center.
Another attraction of this event was RathYatra organized by Raj Heda and his group. This was the very first time that RathYatra was held in Shrewsbury, The procession started with Arati and Shankhnaad (शंखनाद ). All devotees did join in the procession along with Jagannath ji's chanting and bhajans. The devotees included all folks from ages 5 to 90.
The fourth annual ISW camping trip to Camp Resolute, a Boy scout Reservation in Bolton, MA was a great success. It was great to see many first time campers. It was nice to see several families with small children and grandparents. Activities included Archery, Riffle Shooting, Canoeing, Kayaking and field sports. Playing Antakshari around the campfire while the kids had fun making Smores in the campfire added a cerian uniqueness to the trip. There was of course lots of India food and desserts.
We had another successful event this month in our Sadhana Series of Religious activity at ISW.
This Sadhana was dedicated to Graduates to celebrate a great success of their High School Graduation. There were 6 students from ISW family who performed Ganesh Puja guided by our very own Anu Deshpande. Mrs Deshpande explained the meaning of all small rituals involved in puja vidhi and also explained the significance of it in relation to day to day life. The students also did Arati along with all the parents and attendees.


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VultureHound Magazine | Entertainment & Wrestling
Filmhounds Magazine
Iceage – Beyondless (Album Review)
Published on : 11/05/2018 by Jake Doolin
Since the release of their first LP, New Brigade, the Danish quartet Iceage has always seemed to be on the precipice of achieving something great. This isn't to say that their previous work was bad, on the contrary, since the start of the decade the band has maintained one of the most consistently great discographies in rock music. They've achieved this feat by constantly pushing themselves to newer territories, be it a more mature lyrical pallet on 2013's You're Nothing or exploring the sounds of Americana on 2014's Plowing Into The Fields of Love.
But for as great as each of those records were, there was always slight bumps that prevented the band from fully delivering on their promise. And yet four years after that last leap the band have made their biggest push yet with Beyondless a record that finally feels like the band taking a giant leap forward to a new level of greatness.
That shift is immediately felt on opener "Hurrah" where the band's trademark punk sound is met with horn and brass that wouldn't sound of place on a Nick Cave record. Lyrically the track is a little more straightforward than past Iceage tracks, which works wonders. Frontman Elias Bender Rønnenfelt mood clearly hasn't shifted from its permanent sour in the past four years as he growls about a soldier who discovers an evil inside of him that he more than willing to let out.
Self-destruction is a theme on many of the tracks on Beyondless with Rønnenfelt's lyrics painting toxic relationships, addiction and anxiety in a dark yet somewhat cheeky style. Take lead single "Painkiller" for example, Rønnenfelt with some vocal help from Sky Ferreira sing of a couple so involved that they crave each other's saliva and find a self-medicating quality to their time together. It's a dark track for sure but it never veers into complete despair instead finding new turns with every verse.
In an interview earlier this year Rønnenfelt talked about Beyondless saying, "We always try and push whatever we already have into some sort of unknown territory." And this is key to the success of the album, where most bands might stick to their guns Iceage revel in the chance to dig deeper into themselves. Elements of their past releases are more refined, like on the track "Catch It" which takes the Americana explored on their previous release and tackles it with a more refined style.
If there is one complaint that could be leveled at the album it's track lengths. Clearly, the band was trying something new with stretching out some of these songs to four sometimes five minutes. And while for the most part this doesn't damper the songs, it's hard not to see where cutting some fat might of made for a better album.
Still, what is here is just too good to ignore. Iceage clearly understands what it takes to remain exciting to listen to and with Beyondless it's easy to see why they won't be leaving the conversation anytime soon.
RATING: ****
Beyondless is out now on Matador Records.
album, Music, Music Reviewsalbum review, beyondless, iceage, Matador Records, new music
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I have connected a shaw cable box, VCR, and Smart TV. I am able to play pre-recorded tapes on the TV, but I am unable to record onto the tape. I have tried several different cable combinations, but I am thinking that what I am trying to do might be impossible because there is no "Video Out" on this ROKU Smart TV. Is there some set-up that can make this work, or is it impossible?
Welcome to our community! Recording your favorite shows can make it easier to catch up later. We'd be happy to see what suggestions we can make for you.
Can you please share the model numbers of the items you have? We'd be happy to take a peek to see what insight we can shed on this for you. Have you checked out our informational guide about Recording Your Favorites? There's many changes over the last couple of years that make recording TV not as easy for a variety of reasons, but it may still be possible in some cases.
The issue is that your VCR is old technology and does not have the proper decoder to record from cable TV. Programs streamed via the Smart TV are going to be encoded that prevent recording by a VCR as you signals are now digital and your VCR only can undestand Analog.
What you might be able to do. If your Cable box has a RCA outputs also. (i.e. Red, yellow, & White) you can connect that to your VCR inputs. However you will have to select the channel you want to record with the cable box, and not change it. then manually start recording the program.
Whom is your cable provider?
Thank-you for the response. What you suggested was about the second configuration I tried. When I played back, the smart Tv just gave the message "no signal found".
I also tried setting the channel on the VCR and running the co-ax directly into the VCR and out from the VCR to the TV. When I played back, all I got was a grainy blue picture and scratchy noise.
I have since learned that what I am trying to do is not possible in combination with a smart tv. I have to find a set with video out RCA connections.
The smart TV I purchased has been returned to Best Buy. It would have been a great time-saver if the sales person at Best Buy had been knowledgeable enough to tell me of the bat that what I was trying to do would not work.
you need to run the RCA's from your cable box. The VCR would not be able to decode the TV output.
I have tried running RCA from the cable box to the VCR and I still cannot get the VCR to record. Have you actually done this and gotten it to work, or are you advising me about what should work theoretically?
What do you think of the advice to use a DTV converter as shown on https://www.lifewire.com/dtv-converter-vcr-use-3276298?
As your VCR does not most likey have the proper decoder you need to set the channel on your Cable Box to the channel you want and then start recording on your VCR. You will need to have your VCR inputs configured properly.
Yes I have done this in the past but I gave up on a VCR 15 years ago and went DVR.


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Bombay Mix is a superior Bangladeshi / Indian Takeaway located in Whitchurch, Cardiff. We only use the finest ingredients to produce the most authentic Indian sub-continental dishes. An award winning takeaway, we have been nominated for the South Wales Echo takeaway of the year, amongst many other awards, on numerous occassions.
Order food online. It's so easy to use, fast and convenient. Our innovative online website contains our entire takeaway menu, including all your favourite dishes and many more new delicious options.
This online ordering facility will allow your order to be sent to us with the option to 'Collect' or have it 'Delivered' to your home. You can also pay for your purchase securely online, in confidence, ensuring that your privacy is maintained, or you can simply pay by Cash on Delivery. (Sorry we do not except cheques). Please feel free to browse our website and place your order online. Remember to regularly check our website to get up to date prices and exclusive special offers, limited to our online customers only!
Should you have any queries during your online ordering process, (such as with your payment or with the online ordering procedure), simply click on the 'Live Chat' icon at the bottom of the page to have a real-time Live Chat with our technical team. They will be only too pleased to help.
We are pleased to announce that we have received the honour of being 'Highly Commended' by the South Wales Echo Food & Drinks Award 2013/2014! We would like to thank all our customers for their nominations and continued support and custom.
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Award winning takeaway - 'Highly Commended' by the South Wales Echo Food & Drinks Award.
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