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Auditing for Fraud Planning & Approaches

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Auditing for Fraud

Planning & Approaches

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Introductions What is Fraud? Today’s Fraud, Internal audit, IT and fraud Managing Fraud as an organization; How Technology changed the game

Today’s Agenda

3

Introductions

Clark Schaefer Consulting

Regional consultancy headquartered in

Cincinnati, Ohio

Clients range from Fortune 100 to large

private companies

Specializing in project work that is centered

around three core competencies:

Accounting & Finance

Control/Risk (i.e. Internal Audit/IT Audit)

Technology (i.e. Systems Changes/IT Security) 4

Introductions

Sarah Ackerman, CISSP, CISA Technology practice leader Responsible for overall engagement quality

of services provided to clients

Areas of expertise include information

security, risk management, IT audit, and

other technology and risk/control services,

with in-depth knowledge of a variety of

standards, frameworks, and regulations

Introductions

6

Rich Thompson, CPA, CIA

Senior Consultant

Specializes in Audit, Risk Assessment, and Accounting

Internal Audit experience in Healthcare, Retail , &

Government

Sara O’Banion Consultant

Specializes in IT, Fraud and Audit

Works with clients to improve processes, analyze data

and develop effect solutions.

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What is Fraud?

Today’s Agenda

What do you think of when

you think of fraud?

© 2015 American Institute of CPAs - All Rights Reserved, Why Employees Commit Fraud

Why Does Fraud Occur?

Opportunity

Rationalization Pressure

Fraud

Triangle

Understand Fraud on Two Levels

Definition

– fraud

noun \ˈfro ̇d\

: the crime of using dishonest methods to take something

valuable from another person

: deliberate deception to secure unfair or unlawful gain

: a copy of something that is meant to look like the real thing in

order to trick people

Reality

– Limited only by your imagination

• How would you hide it?

• How would you move it?

10

Improper segregation of duties

Lack of/weak internal controls

Too much trust

Poor “tone at the top”

Flexible, uncontrolled management override

Opportunity

Element that companies have the most control over

Copyright © 2015, Association of Government Accountants

How has IT changed this theory?

Ability to create fraudulent documents

Potential for exposure (e.g., hacking, phishing, viruses)

Data mining

Internal

Meeting shareholder

expectations

Too much work

Consequences of poor

performance

Pressure

Copyright © 2015, Association of Government Accountants

External

Personal financial problems

Lifestyle needs

Illicit activities

Hostility toward employer

Unfair wages

Following along with everyone else

“Intending” to pay it back

Belief that the company won’t miss the money

Rationalization

Copyright © 2015, Association of Government Accountants

Impact of Fraud

Annual Revenue (Trillions)

© 2015 Time Inc. All rights reserved

© 2012 Certified Fraud Examiners Inc. Report to the Nations

0 1 2 3 4

$3.7

$0.49

$0.38

$0.20

$0.19

$0.18

Global Fraud

Data analysis

– Complex and occasionally time consuming

investigations

Data collection – Large samples/ clusters of data if misread could give a

false negative or a false positive.

Traditional Ways to Identify Fraud

How can internal audit work to minimize risk?

How can you “fix” it?

Non-Traditional ways to Identify Fraud

Data Analysis

– Automation: Data analysis software

• Allows management to identify and respond quickly to red

flags, reducing the risk of fraud escalation.

Data Collection

– Cloud technology and advanced computing tools

• Effective automation of data collection, improved data quality,

and a reduction in the time required for data validation.

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Non-Traditional Ways to Identify Fraud with IT

Let data mining work FOR you

Link analysis

Data visualization

Predictive modeling

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Corruption:

Dishonest or illegal behavior, especially by powerful

people. The misuse of entrusted power for personal

gain.

Asset Misappropriation: Theft or embezzlement of company assets

Financial Statement Fraud:

Deliberate misrepresentation, misstatement or omission

of financial statement data

Fraud Tree

Median Loss Per Case $

Percent of Cases

0 25 50 75 100

Asset

Misappropriation

85.4%

32.8% Corruption

Financial

Statement

Fraud

4.8%

$4,100,000

0 $3M $6M

$130,000

$250,000

What Do Fraudsters Look Like?

87% first time offenders with

clean employment histories

84% never punished or

terminated for fraud

Perpetrators of Fraud

Position

The majority of occupational frauds were

committed by staff at the employee or managerial

level

19% 36% 42%

Owner/Executive Manager Employee

Median Loss by Position

The higher the perpetrator’s level of authority,

the greater the losses tend to be.

Employee: $75,000

Manager: $130,000

Owner/ Executive: $500,000

Department * 77% of frauds originated in

one of these departments

FRAUD IS NOT LIMITED

TO ANY ONE DEPARTMENT

Accounting: 17% Operations: 15%

Sales: 13% Executives/Upper

Management: 12%

Customer Service: 8% Purchasing: 7%

Finance: 5% All Other Depts.: 23%

Fraud Indicators: A few to consider

General

– Too good to be true? It is

– Lack of transparency

– Lack of oversight

Personal

– Financial difficulties – borrowing money from fellow employees

– Someone with extraordinary investment losses or medical expenses

– Changes in a staff member’s lifestyle or behavior

– Overly defensive or argumentative

– Failure to accept a promotion or transfer

Organization

– Management regularly overriding internal controls

– High personnel turnover

– Inventory shortages

– Unrealistic performance expectations

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Internal Audit, IT and Fraud

Today’s Fraud

Reasons Why Audits Don’t Catch Fraud

Detecting Fraud is HARD!

Lack of skill and experience

Improper planning

Inappropriate design of audit program, sample

selection, or target assertions

Inability to gather sufficient, appropriate audit

evidence

Failure to exercise professional skepticism

Traditional Training

Day-to-day coaching

Intercompany training

– New hire training process, training individuals as they obtain

more responsibility, etc.

IIA/ACFE auditing courses

Seminars/conferences

Certifications

– CIA, CFE, CISA

Continuing education

Non-Traditional Training

Advance interviewing techniques

Forensic accounting

Trend analysis

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Audit Plan

Pre-work

Narrative Interviews

Process Flows &

Walkthroughs

Risk Assessment

Test Fieldwork

Review

Reporting

Follow Up

Standard Audit Steps

Annual Audit Plan

How much of IA’s budget is dedicated to “canned”

audits?

How much is spent with management mandated

activities (e.g., MAR, 10-Q assistance)?

How much time set aside for consultative and ad-hoc

activities?

How are you incorporating your IT audits?

– Together as part of the team or separate?

Fraud Planning – High Level

Enterprise-wide risk assessment

What risks are associated with the company’s

overarching goals?

What are the positive and negative outcomes of

meeting/failing to meet those goals?

What message does upper management send about

meeting goals (“tone at the top”)?

Fraud Planning – High Level (cont.)

Enterprise-Wide Risk Assessment

Incentives

Attached to performance goals, used as motivational

tool

Increase risk that an employee will act fraudulently in

order to obtain them

Especially if consequences of not meeting goals are

severe enough

Risk Assessment

Assess the likelihood and significance of

inherent and residual fraud risk

Should include period of fraud brainstorming

where auditors consider all of the controls

identified

This is also a time to consider the personnel

involved with the processes being audited

Are there any non-remediated items?

Are there any solutions that are different from the

audit recommendation?

Were there any “agree to disagree” items?

Are the previous tests insufficient for the current

audit?

Prior Audits

Planning: Identify the Culture

Tone at the Top

– What message does senior level management send to employees

in regards to ethical behavior?

Fraud is NOT OKAY!

– Are resources being provided to employees telling them how they

can identify fraud and help stop it?

Is there an affirmation process for upper

management’s compliance with code of conduct,

fraud, etc.?

Do policies deter fraud by detailing the consequences

of committing fraud?

Are there annual anti-fraud trainings?

Are there authority limitations on employees and

managers? Are there restrictions on management

overrides?

Are the appropriate internal controls in place (e.g.,

segregation of duties) to prevent fraud?

Identifying Fraud Prevention

Are there anonymous opportunities for whistleblowers?

Are there process controls to detect fraud, such as physical inventory counts, reconciliations, etc.?

Are there technological measures (e.g., data analysis) to detect anomalies or trends that could indicate fraud?

Can the internal audit function assist in detecting fraud?

Pre-Work: Identifying Fraud Detection

Techniques

Preventative Controls Deter Fraud

Opportunity… But at What Cost?

Audit Plan

Pre-work

Narrative Interviews

Process Flows &

Walkthroughs

Risk Assessment

Test Fieldwork

Review

Reporting

Follow - Up

Standard Audit Steps

Obtain process flow charts in order to identify potential

control weaknesses, lack of segregation of duties, etc.

Process Flows and Walkthroughs

Performs walkthroughs to

examine that the processes

are being performed as

designed, and controls listed

exist and are effective

Audit Plan

Pre-work

Narrative Interviews

Process Flows &

Walkthroughs

Risk Assessment

Test Fieldwork

Review

Reporting

Follow - Up

Standard Audit Steps

Audit – Risk Assessment

For repeated audits

– Are previous tests adequate?

– Can a redesign give you greater assurance?

For new audits

– Are the controls well thought out?

– Are the controls too cumbersome?

Don’t hesitate to actually…….

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Think Like A Thief!!!

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Audit Plan

Pre-work

Narrative Interviews

Process Flows &

Walkthroughs

Risk Assessment

Test Fieldwork

Review

Reporting

Follow - Up

Standard Audit Steps

Test Planning & Design

Reperformance

Examination

Confirmation

Analytical Procedures

Observation

Cost

($)

Design your audit to have the strongest level of testing

available, taking into consideration budget and scope.

Reliability Level

Interview /

Inquiry

Set clear expectations

Discuss the nature, timing, and extent of audit

procedures

Ensure procedures are performed efficiently and

effectively

Review documentation to make sure it sufficiently

details tests performed

Don’t be afraid to discuss fraud!

Supervision

Audit Plan

Pre-work

Narrative Interviews

Process Flows &

Walkthroughs

Risk Assessment

Test Fieldwork

Review

Reporting

Follow - Up

Standard Audit Steps

What is the overall risk of the process being audited?

Are there any other conclusions that can be drawn

from the completed testing?

Was testing designed to uncover red flags?

Do any tests need to be re-performed or redesigned?

Has the audit team fully thought through the

implications of any unexpected items?

Fieldwork Review

If no exceptions were found the first time, was the

sample accurate for the:

Period tested

Specific transaction amounts

–Round dollar amounts

–Common amounts

Specific vendors

–High # of transactions

–High # of disputes

Substantive Testing

Audit Plan

Pre-work

Narrative Interviews

Process Flows &

Walkthroughs

Risk Assessment

Test Fieldwork

Review

Reporting

Follow - Up

Standard Audit Steps

“Tone at the Top”

While no manager or process owner is going to be

happy about a potential finding being brought to

them, their response and the way that they address the

matter can be an indicator of fraud or other problems.

Potential Findings Meetings

Audit Plan

Pre-work

Narrative Interviews

Process Flows &

Walkthroughs

Risk Assessment

Test Fieldwork

Review

Reporting

Follow Up

Standard Audit Steps

Avoid the temptation to skip this step

Look for remediation that has not been completed

Thoroughly assess all “alternative” remediation plans

Follow Up

Either assurance gained or

improvements made to

existing audit process

Fraud detected

Additional process

improvement

recommendations

Improved internal

controls

Possible recovery of

stolen funds

Key Outcomes

Fraud investigation post mortem – lessons learned

Need for a peer review?

Opportunity of continuous monitoring or process

automation?

Final Opportunities

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Managing fraud as an organization and how technology changed the game

The NEW Fraud Challenge

End User Risk

Company information is now accessed by and

saved to non-company devices

Company information is now accessed anywhere

at any time, on personal devices with software

that is not owned or approved by organization

Project Risk

Subsidiary systems may not

be equipped to handle the

larger volume of the parent

company

Aggressive deadlines could result in short-cutting

the systems development and/or change

management process

Systems may not be properly secured

NDA Compliance

Change Management

Vendor Selection

Device Registration

Device Monitoring

Intrusion Detection

Project Management

Access Controls

Access Monitoring

Possible Fraud Testing

Creating a culture to prevent fraud

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Governance

Risk

Assessment

Prevention &

Detection

Investigate &

Resolve

Create ever evolving

procedures

Identify major new initiatives

and assess impact on the

organization

Actively work to

acquire/create systems to

minimize risk

For identified instances of

fraud, review and adjust

process as required

Creating a culture to prevent fraud (cont.)

Governance

Develop a fraud risk program

with written policies to set clear

expectations

Roles and responsibilities documented for all areas of the organization,

including:

– Board of Directors

– Audit Committee

– Management

– Staff

Documentation should include escalation and investigation procedures

to cover what to do if fraud is identified

Consider the changing face of IT:

o Last year’s program may not work this year

o Update controls continuously to ensure they are current

Creating a culture to prevent fraud (cont.)

63

Risk

Assessment

Fraud risk assessments should

include three key elements.

Risks to the organization should be periodically

assessed to identify areas to focus mitigation

Indentify Inherent Risk

Assess Impact, Likelihood

Address significant

risks

Creating a culture to prevent fraud (cont.)

64

Prevention &

Detection

Preventative controls should be established to

prevent (or at least minimize) key risks identified

during the risk assessment.

Examples of controls:

HR procedures (hiring,

terminations, etc)

Anti-fraud training

Authority limits

Transaction level procedures

KEY IS DOCUMENTATION

Creating a culture to prevent fraud (cont.)

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Prevention &

Detection

In addition, controls should be established to

detect fraud when preventative controls fail

Examples of controls:

Whistleblower hotlines

Process controls

Proactive procedures

(continuous auditing)

AGAIN: KEY IS

DOCUMENTATION

Creating a culture to prevent fraud (cont.)

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Investigate &

Resolve

For each fraud item communicated,

procedures need to be established to:

Receive the allegation

Evaluate the allegation

Escalate the allegation

All items should be investigated and

resolved using standardized process in a

timely manner.

Reporting should be established with a formal

investigation process.

Key Takeaway

INTERNAL AUDIT

SHOULD BE A PARTNER,

NOT THE POLICE

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Questions?

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For More Information

If you wish to discuss any aspects of this presentation in

more detail, please feel free to contact us:

Clark Schaefer Consulting, LLC.

120 East 4th Street, Suite 1100

Cincinnati, Ohio 45202

www.clarkschaefer.com

Or send an e-mail directly to Sarah at:

[email protected]

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Building Your Toolkit Series: Managing

Risk While Improving Your Operations

Date: Wednesday December 2, 2015

Time: 8:00 AM to 12:30 PM

Location: Radisson Cincinnati Riverfront, West Fifth

Street Covington, KY 41011

Cost: $99/per person; includes breakfast and lunch

To register: https://Building Your Toolkit Series:

Managing Risk While Improving Your Operations/register

CPE: Earn up to 4 CPE credits

For any questions regarding this event or how to register

please contact:

DeAnna Bird, [email protected], (513) 768-7100

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Building Your Toolkit Series: Managing

Risk While Improving Your Operations

71

Risk and Governance Accounting IT and Security

Maximizing Your

Enterprise and IT Risk

Assessment Process

Checking the Pulse of

Your Accounting

Function

Protecting Your

Intellectual Property

Internal Audit: How to

Prioritize and Get the

Biggest Bang for Your

Buck

Improving Your

Financial Reporting

Process: An Exercise in

Process Improvements

Building an Effective

Security Awareness

Program

Understanding and

Addressing Your Cyber

Risk

Building Your

Accounting Tools for

Fraud Prevention/

Detection

Essential Building

Blocks: Data

Classification and

Management

Round Table Lunch:

Can’t We Just All Get Along? Creating A Workplace For Boomers,

Millennials and Everyone In Between