certified fraud examiner's fraud prevention check up

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002 Association of Certified Fraud Examiners. All rights reserved. The Certified Fraud Examiners’ Fraud Prevention Checkup - An Introduction Toby J.F. Bishop CFE CPA FCA President & Chief Executive Officer Association of Certified Fraud Examiners

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  • 1. The Certified Fraud Examiners Fraud Prevention Checkup - An Introduction Toby J.F. Bishop CFE CPA FCA President & Chief Executive Officer Association of Certified Fraud Examiners

2. Current Fraud Concerns

  • Fraudulent financial reporting
  • Legal risks for executives
    • Civil liability
    • Criminal (jail time)
  • Financial losses for investors
  • Reputation damage to companies/brands
  • Crisis of confidence

3. An Appropriate Response

  • Fraud prevention is 80% of the solution
  • Objective evaluation of an entitys fraud prevention processes
  • Prompt action to fix gaps/breakdowns
  • Annual testing
  • Ongoing fraud education and training

4. The Certified Fraud Examiners Fraud Prevention Checkup

  • A high-level checkup of an entitys fraud prevention processes
  • Form available free atwww.CFEnet.com
  • Identifies major gaps
  • Provides an overall score

5. Benefits to Entities That Use This Tool

  • It provides insights that senior management, the board of directors and audit committee will value highly
  • It could save the entity from catastrophic financial and reputational losses
  • It could help build confidence in the entity internally and by the public
  • Its simple and inexpensive

6. Benefits for CFEs Who Apply This Tool

  • It provides insights that senior management, boards of directors and audit committees will value highly
  • It can be performed very inexpensively
  • It can help you win new clients and deepen existing relationships
  • It is being promoted in the media by the ACFE

7. But CFEs Should Manage Their Liability Risks

  • Risk of false perception of assurance
  • Be careful not to guarantee no fraud
  • Anti-fraud controls in existence vs. operating effectively
  • Ongoing frauds may be uncovered
  • Legal risks to entity evaluated if control gaps are identified but not fixed

8. Who Should Perform the Checkup?

  • Ideally a collaboration between a Certified Fraud Examiner and knowledgeable people inside the entity (e.g., internal auditors)
  • Helpful to interview senior management
  • But also talk to other levels of employees to get a reality check

9. The Certified Fraud Examiners Fraud Prevention Checkup

  • The seven elements:
    • Fraud risk oversight (20 pts)
    • Fraud risk ownership (10 pts)
    • Fraud risk assessment (10 pts)
    • Fraud risk tolerance and risk management policy (10 pts)
    • Process level controls/anti-fraud re-engineering (10 pts)
    • Environment level controls (30 pts)
    • Proactive fraud detection (10 pts)

10. Fraud Risk Oversight

  • To what extenthas the entity established aprocessfor oversight of fraud risks by theboard of directors orothers charged with governance (e.g., anaudit committee )?

11. Scoring Risk Oversight

  • Score: Award from 0 (process not in place) to 20 points (process fully implemented, tested within the past year and working effectively).
  • Note: For all questions, awardno more than half the available pointsif the process has not been tested within the past year.

12. Fraud Risk Ownership

  • To what extent has the entity created ownership of fraud risks?
  • Chief Executive currently owns the risk, but needs to make others responsible too
  • A member of senior management,and
  • All business unit managers

13. Fraud Risk Assessment

  • To what extent has the entity created anongoing processfor identifying thesignificantfraud risks to whichthe entityis exposed?
    • Potentially catastrophic risks
    • Costly risks
    • Tailored to the particular entity
    • Can be part of enterprise risk management

14. Fraud Risk Tolerance and Risk Management Policy

  • To what extent has the entity identified and had approved by the board of directors:
    • Itstolerancefor different types of fraud risks?
    • Apolicyonhowit willmanageits fraud risks?
  • Align risk toleranceof management with that of board of directors & audit committee
  • Business decisions to reduce fraud risks

15. Process Level Controls/ Anti-Fraud Re-engineering

  • To what extent has the entity implemented measures to reduce each of the significant fraud risks identified in its risk assessment, through:
    • Anti-fraud process re-engineering (removing the opportunity)?
    • Process level controls to prevent, deter and detect fraud

16. Environment LevelAnti-Fraud Controls

  • To what extent has the entity implemented a process to promote ethical decisions, deter wrongdoing and facilitate two-way communication on difficult issues?
  • Most difficult area to evaluate
  • Difference between existence and operating effectiveness of controls can be crucial
  • Employee surveys are highly desirable

17. Key Elements of Environment Level Controls

  • Senior member of management responsible
  • Values-based code of conduct
  • Regular training (including fraud)
  • Advice and reporting systems
  • Investigation plans
  • Monitoring of compliance

18. Key Elements of Environment Level Controls

  • Regular measurement of achievement of ethics/compliance and fraud prevention goals
    • Employee attitude surveys, fraud measures
  • Incorporate ethics/compliance and fraud prevention goals into performance measures for evaluating/compensating employees

19. Proactive Fraud Detection

  • To what extent has the entity established a process to detect, investigate and resolve potentially significant fraud?
    • Proactive fraud detection testing
    • Targeted at significant fraud risks identified in the fraud risk assessment
    • Embedded fraud detection/audit hooks
    • Automated e-mail monitoring (where legal)

20. Interpreting the Entitys Overall Score

  • Desirable score is 100 points
  • Most entities will fall short initially
  • Not currently considered a material weakness in internal controls that is a reportable condition
  • But significant gaps should be closed promptly to avoid disaster

21. Recommended Next Steps

  • Study the ACFE Fraud Prevention Checkup
  • Promote it to your current and target clients
  • Perform checkups and identify major gaps in clients fraud prevention processes
  • Providing anti-fraud consulting services to help clients fix those gaps

22. Thank You

  • Any questions?
  • ACFE Fraud Prevention Checkup pdf file available atwww.CFEnet.com .PowerPoint presentation available to members shortly.
  • +1 (512) 478-9070