auditing for fraud or what does fraud look like presented by: dennis f. dycus, cpa, cfe, cgfm...
TRANSCRIPT
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Auditing For Fraudor
What Does Fraud Look Like
Presented by:
Dennis F. Dycus, CPA, CFE, CGFM
NSAA/NASC Joint Middle Management Conference
Nashville, TN
April 21, 2009
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RED FLAG
A set of circumstances that are unusual in nature or vary from the “normal activity”
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CAUTION
Do not ignore a red flag Conduct inquiry to
determine reason for abnormal circumstances
Sometimes an error is just an error Is there intent?
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Quote of the Day
Fraud and Stupid
Often Look
Exactly the Same
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Fraud TriangleFraud Triangle
Need Rationale
Opportunity
Control Environment
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Controlling OpportunityPrevent
DeterDeter
MonitorMonitorControlControl
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How Fraudsters Think
Concoct a Scheme“Can IT be done?”
Perception of Detection
(will I get caught)YesFuggetaboutit No
Maybe
Control Environment
Mgmnt. Oversight
Tone at the topFraud Hotline
Aggressive Investigation
Need Rationale
Opportunity
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Corruption Schemes and Fraud in Compliance Programs
# 1 Reason Fraud Occurs
Blind Trust
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EMPLOYEE RED FLAGS Lifestyles changes Significant personal debt and
credit problems Behavioral changes
Drug or alcohol related Gambling Fear of losing job
High employee turnover Refusal to take vacation or sick
leave Lack of segregation of duties
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EMPLOYEE RED FLAGS
Low or inadequate salary Difficulty in obtaining
audit evidence Severe disciplinary actions Lack of respect or
appreciation by superiors Open-ended contracts Resentment for not being
treated fairly
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What Does Fraud Look LikeRemember that employees will
circumvent internal controls not for the purpose of committing fraud, but because …..
It makes their job easierBut by doing so, an opportunity is
provided
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What Does Fraud Look LikeSooner or latter, an employee will have
a needThey only need to be able to rationalize
in order to take advantage of the opportunity
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DANGER!
BEWARE OF BLACK
HOLES AHEAD
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MANAGEMENT RED FLAGS
Reluctance to provide information to auditors
Excessive number of checking accounts
Frequent changes in banking accounts
Frequent changes in external auditors
Company assets sold under market value
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MANAGEMENT RED FLAGS
1. Significant downsizing in a healthy market
2. Continuous rollover of loans
3. Excessive number of year-end transactions
4. High employee turnover rate
5. Unexpected overdrafts or declines in cash balance
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MANAGEMENT RED FLAGS
6. Refusal by company or division to use serial numbered documents
7. Compensation program out of proportion with its profits
8. Any transaction that does not make sense
9. Photocopied or missing documents
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RED FLAGS IN CASH/
ACCOUNTS RECEIVABLES
Excessive number of voids, discounts and returns
Unauthorized bank accounts in company name
Sudden activity in dormant banking accounts
Customers receiving late notices on accounts where payments have been made
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RED FLAGS IN CASH/ACCOUNTS RECEIVABLE
Discrepancies between bank deposits and posting to the account
Abnormal number of expense items or supplies reimbursement by employees
Presence of employee checks in petty cash for the employee who is responsible for petty cash
Unjustified cash transactionsLarge number of written-off accountsBank accounts that are not reconciled on a timely
basis
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RED FLAGS IN CASH R/DACCOUNTS RECEIVABLE
Unusual checksAny check for an even amount in excess of $50Any deposit of currency in a large amountAny non-payroll or expense reimbursement check
made payable to an employeeExcessive use of clearing accountsExcessive purchases of small toolsBids/High-Low/Same Ones/Splitting
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RED FLAGS IN CASH R/DACCOUNTS RECEIVABLE
Large and frequent change ordersHigh level approval of a low level
transactionOdd purchasesCopies of invoices rather than originals
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RED FLAGS IN PAYROLLInconsistent overtime
hours for a cost centerOvertime charged
during a slack periodOvertime charged for
employees who normally would not have overtime pay
Budget variations for payroll by cost center
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RED FLAGS IN PAYROLL
Employees with:Duplicate Social
Security numbersSame namesSame addresses
Employees with few or no payroll deductions
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RED FLAGS IN PURCHASING/INVENTORY
Increasing number of complaints about products or service
Increase in purchasing inventory but no increase in sales
Abnormal inventory shrinkage
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Red Flags in Purchasing/Inventory
Increase in scrap materials and then reorders for the same items
Lack of physical security over assets/inventory
Sales without shipping documentsPayments to vendors who aren’t on an
approved listHigh volume of purchases from new
vendors
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Red Flags in Purchasing/Inventory
Purchases that bypass the normal proceduresVendors without physical addressesVendor addresses that match employee
addressesExcessive inventory and inventory slow to
turnoverPurchasing agents that pick up vendor
payments
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Reasons Auditors Fail To Detect Fraud
We mechanically “tick and turn,” and we are darn good at it!
We don’t perform the basic, traditional audit tests and procedures
Lack of substantive testingWe avoid those “high risk” areas, especially if
immaterial in amountInadequate time budgets
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Reasons Auditors Fail To Detect Fraud
Lack of training to recognize fraud indicators (But we sure can follow that audit program!)
We don’t have adequate training in order to recognize basic internal control weaknesses and what can happen as a result of such
We just don’t want to find fraud
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Reasons Auditors Fail To Detect Fraud
We tend to accept any “Reasonable” auditee explanation for an audit exception. (Sounds good to me!)
We ASSUME!
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ANALYZING RED FLAGSRecognizing the red flag is
not sufficient Action must be taken to
determine the cause and possible effect
Evaluate by Financial analysis Observation Techniques which will
mitigate the apparent weakness
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ANALYZING RED FLAGSDetermine the effect on
the business Red flags are most likely a
warning that something is wrong
If can not be explained, the next step is to conduct an examination
Financial analysis is conducted to establish workable leads
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ANALYZING RED FLAGSComputer AnalysisListing of discounts,
voids and refunds by employee
Actual vs budgeted reimbursements by employee
Unusual payment by vendor
Duplicate or fake SS No. by employee/vendor
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ANALYZING RED FLAGS
Computer AnalysisCustomer complaintsUnusual patterns in
overtime payments
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ANALYZING RED FLAGS
Observation
Correct the situationEducate the
responsible area
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ANALYZING RED FLAGSCONCLUSION
Red Flags are “Warnings”Do not ignore (They will be waiting for
you!)There are no “Little Frauds”
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Hope You All
Sleep Well Tonight!(Sweet Dreams – Or Night Mares)
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When Leadership Fails
Presented by:
Dennis F. Dycus, CPA, CFE, CGFM
NSAA/NASC Joint Middle Management Conference
Nashville, TN
April 21, 2009
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When Leadership Fails
By statute, the members of a governing body of a political subdivision of the State of Tennessee, be it a county, city, town, utility district, or a local board of education are responsible for the entity's operations.
As President Harry Truman once said….
The Buck Stops Here
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When Leadership Fails
The members of the governing body (board) are responsible for establishing the policies and procedures (P&P) the governmental entity operates under The board is also responsible for
seeing that the entity is operated in
accordance with such P&P
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When Leadership Fails
The board may delegate such responsibility, but in the end, they are responsible
When the board either: Fails to adopt adequate P&PAdopts inadequate P&PAdopts P&P but fails to see that they are
compiled with
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When Leadership Fails
BAD THINGS
CAN HAPPEN
AND OFTEN DO
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When Leadership Fails
SUCH AS Inefficient operation of the entity Failure to adequately maintain the
entity’s infrastructure Misappropriation of the entity’s assets
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When Leadership Fails
This presentation will focus on frauds/problems that have occurred
in such entity’s because the members of the governing board failed to carry out their oversight
responsibilities
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When Leadership Fails
How Does It Happen Most frauds are
committed by “Honest
People”
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When Leadership Fails
In order for an “Honest Person” to commit fraud, three things must always be present:
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When Leadership Fails
NEED
RATIONALIZATION
OPPORTUNITY
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When Leadership Fails
Of the three things that must be present, which one does the board members ALWAYS provide?
OPPORTUNITY
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When Leadership Fails
That’s why that members of the board often
try to keep the fraud quiet – because they share in the responsibility in that they either: Had no P&P Had inadequate P&P Did not see that the P&P were complied with
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When Leadership Fails
The best laid plan (P&P) is worthless unless it is put into operation and monitoredFrom time to time (once a month would be good) at least one member of the BOC should look at the records to make sure that:
Adequate collection records are being created and retained;
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When Leadership Fails
Adequate supporting documentation for disbursements is being obtained and retained
If there is a documentation problem, it should not be discovered when the BOC reads their annual audit report
The poorest response to such a finding is we were not aware of this
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When Leadership Fails
It’s your job to be aware of it because you are the leader and the buck stops with you
The members of the board should be familiar with the functioning of the office staff
The members of the board should bring issues to the attention of the auditor, not the other way around
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When Leadership Fails
Documentation deficiencies identified during the periodic reviews should not be tolerated Such deficiencies may very well provide
an opportunity
There should not be any excuses for inadequate records
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When Leadership Fails
If discrepancies are blamed on computer software glitches, have the software vendor come out immediately and determine if the problems are with the software
If reports are not printed because of printer problems, investigate the problem, and if necessary replace the printer
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When Leadership Fails
If discrepancies are blamed on a bank error, contact the banker and get the issue straightened our immediately
Noncompliance with district P&P should not be tolerated One warning, and then they are gone
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When Leadership Fails
Do not allow an employee to entrench themselves with certain tasks Resistance to giving up a task should be
viewed with suspicion So should resistance to change in
procedures; especially in strengthening
internal controls
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When Leadership Fails
Be suspicious of procedures that serve no purpose other than, we’ve always done it this way
The above suggestions may appear to be a lot of extra work; but which is worse, the extra work or the embarrassment of a fraud occurring on your watch
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When Leadership Fails
Now let’s talk about some of the opportunities Municipal Audit staff have noted either as a result of disclosures in the district’s annual audit or through investigations they conducted
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When Leadership Fails
Always No. 1 on the list of OPPORTUNITIES – Lack of the proper segregation of duties;
Cash receipts not deposited on a timely basis;
A member of the board was involved in a conflict of interest with the UD
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When Leadership Fails
Failure to observe bid requirements Failure to maintain capital asset records
If you don’t know what you have, you also don’t know what you’re missing
Failure to either itemize or make deposits intact
Using cash to make small purchases
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When Leadership Fails
No approval of billing adjustments or such approval made by the billing clerk
Failure to stamp Date Paid on billing stubs
Failure to reconcile the bank account or failure to reconcile on a timely basis
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When Leadership Fails
Failure to reconcile A/R subsidiary records to the general ledger
The water utility has a water loss rate in excess of 20%
Allowing the individual who opens the mail to make the bank deposits
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When Leadership Fails
Cashing personal checks through either the petty cash fund or daily receipts
Allowing more than one employee access to the same cash drawer
Allowing the individual who collects receipts to also post those receipts
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When Leadership Fails
Failure to run a background check on employees, especially those responsible for handling cash
Failure of the members of the board to comply with the district’s P&P
Failure by the designated individual to properly review invoices prior to payment
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When Leadership Fails
Presigning checks Failure to review credit card/gas card
charges/payments Failure to have an adequate travel
reimbursement policy Allowing personal use of district assets
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When Leadership Fails
Failure to bill members of the board or district employees for services provided by the utility (monthly water bill or tap fee)
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Remember, as a member of the governing board, YOU are responsible for setting/carrying out the entity’s P&P
YOU set the TONE for the organization and its operations
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When Leadership Fails
Presented by:
Dennis F. Dycus, CPA, CFE, CGFM
NSAA/NASC Joint Middle Management Conference
Nashville, TN
April 21, 2009