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A Global Reach with a Local Perspective




                           University of North Alabama
                    19th Annual Decosimo Accounting Forum
                                  July 22, 2011

                                                                     www.decosimo.com

Fraud Prevention and Internal Controls
– A Winning Combination
PAM MANTONE, CPA, CFF, CFE, FCPA, CITP
Senior Assurance Manager
ACFE 2010 Report to the Nation
 Financial statement fraud cases were less than 5%
  of the total fraud cases reported

                       However

 Financial statement fraud cases were the most
  costly of all fraud cases reported, causing a median
  loss of more than $4 Million!
Percent of Total Dollar Losses




                     20.8%
                                      Asset Missapropriation

                             11.30%   Corruption
67.90%
                                      Financial Statement
                                      Fraud
Spotting Creative Accounting
 Why boost the Balance Sheet?
   Create appearance of a strong financial position –
          More easily obtain lines of credit at low interest rates
          Easier to issue debt financing or issue bonds on better terms
          Maintain compliance with existing loan covenants
    Increase earnings power in future periods
    Increase earnings power in current period
    Keep investors happy!
    Food for thought – Why decrease the Balance Sheet?
Financial Statement Fraud
 The deliberate misrepresentation of the financial
  condition of an entity.
 Intentional misstatement or omission of amounts or
  disclosures in the financial statements in order to
  deceive financial statement users
 Objectives
    Overstate profits, revenues or assets
    Understate losses, expenses or liabilities
    What about reversing these – would you think
     financial statement fraud in this case?
 Committed at the upper-management level
Common Schemes
 Improper revenue recognition
    End result – overvaluing assets
 Improper asset valuation
    Provision for doubtful accounts
    Inventory manipulation
    Fixed Assets
 Concealed expenses and liabilities
    In July 2002, the SEC charged Adelphia with fraudulently
     excluding over $2.3B in bank debt by deliberately shifting
     liabilities to off-balance sheet unconsolidated entities
 Improper disclosures or omissions
Common Schemes
 Additional concerns
    Subsidiaries and Joint Ventures – consolidation or
     equity method
Overvaluing Assets
 My hints for the day:
   Inventory increasing faster than sales
   Inventory rising faster than total assets and falling
    cost of sales as a percentage of sales
   Balance sheet item growing at a faster pace than the
    income statement item
   Equity method limits available information-easier to
    conceal or overstate
Improper Disclosures or Omissions
 Loan covenants or contingent liabilities
 Subsequent events
 Significant fraud committed by officers, executives,
  and others in key positions of trust
 Changes in accounting principles, estimates, and
  reporting entities
 Related party transactions
    Tyco – failed to disclose hundreds of millions of
     dollars of low-interest and interest-free loans. Also
     CEO forgave $50M in loans to himself and another
     $56M for 51 favored employees
Preventive Controls
 Effective oversight a must!
    Gain a solid understanding of the business
    Maintain appropriate levels of skepticism
    Consider incentives, pressures, opportunities and
     rationalizations to commit fraud
    Explore fraud risk scenarios
    Assess the financial reporting culture
 Organizational Structure
 “Tone at the Top”
 Zero Tolerance
 Ethics Policy
Preventive Controls
 Related Parties
 My hint for the day:
    Search for Inter-relationships (see next slide)
Co. B                    Board       Co. A
                          Member


Board                      Your         Board      Co. C
Member                    Operation     Member

          Board                Board
          Member               Member

  Co. F           Co. E

          Co. G             Board Member Inter-relationships
Accounts Payable Detection and Prevention
 Potential Fraud schemes
    Employees Committing Purchase Fraud
          Fictitious Vendors
          Personal purchases with company funds
     Vendors Committing Fraud
          Over-charging for goods purchases
          Duplicate billings
          Billing for goods not ordered or shipped
     Collusion
          Kickbacks
Identification of Red Flags
 Employees committing purchasing fraud
    Vendor name, address = employee name, address
    Undisclosed conflicts of interest
 Vendors committing fraud
    Documentation does not exist or lacks appropriate
     detail
    Pricing does not agree with contracts
    Duplicate invoices
    Invoices submitted for materials not ordered or
     delivered
Preventive Controls
 Implement a fraud hotline and notify employees and
  vendors of its existence
 Separate duties of A/P processing, vendor file
  maintenance, check stock custody, check
  preparation, check signing, check mailing and bank
  reconciliation
 Separate purchasing and receiving functions
 Require mandatory vacations and cross train
  employees so that someone else can fill in for these
  positions
Preventive Controls
 Use physical and software controls to restrict
  access to A/P and cash disbursements systems,
  including access to banking software
 Maintain an approved vendor list independently of
  the purchasing department
 Restrict access to the vendor master file and flag
  any changes to the file
 Periodically purge the vendor master file to maintain
  only active approved vendors
 Require proper authorization of all transactions
 Do not pay from statements!
Preventive Controls
   Never sign blank checks!
   Severely restrict the use of manual checks
   Use positive pay or reverse positive pay systems
   Use quality check stock
   Investigate and void and reissue checks more than
    90 days outstanding
   Deface voided checks
   Use pre-numbered, multi-part checks
   Do not allow access to blank checks to those with
    signatory authority
   Lock up check stock, signature stamps, plates
Preventive Controls
 Require dual signatures for payments over an
  established threshold
 Request bank notification if a duplicate debit is
  pending posting
Detection
 My hints for the day:
   Use dimensional testing
   Use geo-coding
Standard Detection Testing
 Employees as Vendors:

                                
                   Common
                                 
                   Common
                                 
                               
Dimensional Testing Technique
 Employee Networks as Vendors:

                                     
       
              
                                  
                                     
     
                                    
Searching for Addresses: Geo-Coding
 Must be consistent in entering data for both the
  Employee Master and the Vendor Master files for
  matching
 Obstacles
    St. vs. Street
    NE vs. North East
    123 Main Street, Apartment B vs. 123 Main Street B
     or
    123 Main Street
    Apartment B
Geo-Coding
 http://www.gpsvisualizer.com/geocode

 I enter: 1089 East Harrison Street, Martinsville, IN

 The Google geocoder found:
    1089 E Harrison St, Martinsville, IN 46151, USA street
     address: 1089 E Harrison St ZIP/postal code: 46151 city:
     Martinsville state/province: IN country: USA latitude,
     longitude: 39.429443, -86.415746
    39.429443 -86.415746
    N39° 25.7666', W086° 24.9448'
    (precision: address)
 By themselves, internal controls will not prevent
  fraud.

 - Yet -

 The perception of detection through monitoring of
  internal controls is a great way of discouraging
  fraud.
Connect with me

                                          Pamela S. Mantone, CPA, CFF, CITP,
                                          CFE, FCPA,
                                          Senior Assurance Manager
                                          423.756.7100
                                          pammantone@decosimo.com

                                          On LinkedIn:
                                          http://www.linkedin.com/pub/pamela
                                          -mantone/10/824/807

   Disclaimer: The contents of this presentation are for informational purposes only. The information is not intended to be a substitute for
  professional accounting counsel. Always seek the advice of your accountant or other financial planner with any questions you may have
  regarding your financial goals or specific situations.

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Fraud Prevention and Internal Controls - A Winning Combination

  • 1. A Global Reach with a Local Perspective University of North Alabama 19th Annual Decosimo Accounting Forum July 22, 2011 www.decosimo.com Fraud Prevention and Internal Controls – A Winning Combination PAM MANTONE, CPA, CFF, CFE, FCPA, CITP Senior Assurance Manager
  • 2. ACFE 2010 Report to the Nation  Financial statement fraud cases were less than 5% of the total fraud cases reported  However  Financial statement fraud cases were the most costly of all fraud cases reported, causing a median loss of more than $4 Million!
  • 3. Percent of Total Dollar Losses 20.8% Asset Missapropriation 11.30% Corruption 67.90% Financial Statement Fraud
  • 4. Spotting Creative Accounting  Why boost the Balance Sheet?  Create appearance of a strong financial position –  More easily obtain lines of credit at low interest rates  Easier to issue debt financing or issue bonds on better terms  Maintain compliance with existing loan covenants  Increase earnings power in future periods  Increase earnings power in current period  Keep investors happy!  Food for thought – Why decrease the Balance Sheet?
  • 5. Financial Statement Fraud  The deliberate misrepresentation of the financial condition of an entity.  Intentional misstatement or omission of amounts or disclosures in the financial statements in order to deceive financial statement users  Objectives  Overstate profits, revenues or assets  Understate losses, expenses or liabilities  What about reversing these – would you think financial statement fraud in this case?  Committed at the upper-management level
  • 6. Common Schemes  Improper revenue recognition  End result – overvaluing assets  Improper asset valuation  Provision for doubtful accounts  Inventory manipulation  Fixed Assets  Concealed expenses and liabilities  In July 2002, the SEC charged Adelphia with fraudulently excluding over $2.3B in bank debt by deliberately shifting liabilities to off-balance sheet unconsolidated entities  Improper disclosures or omissions
  • 7. Common Schemes  Additional concerns  Subsidiaries and Joint Ventures – consolidation or equity method
  • 8. Overvaluing Assets  My hints for the day:  Inventory increasing faster than sales  Inventory rising faster than total assets and falling cost of sales as a percentage of sales  Balance sheet item growing at a faster pace than the income statement item  Equity method limits available information-easier to conceal or overstate
  • 9. Improper Disclosures or Omissions  Loan covenants or contingent liabilities  Subsequent events  Significant fraud committed by officers, executives, and others in key positions of trust  Changes in accounting principles, estimates, and reporting entities  Related party transactions  Tyco – failed to disclose hundreds of millions of dollars of low-interest and interest-free loans. Also CEO forgave $50M in loans to himself and another $56M for 51 favored employees
  • 10. Preventive Controls  Effective oversight a must!  Gain a solid understanding of the business  Maintain appropriate levels of skepticism  Consider incentives, pressures, opportunities and rationalizations to commit fraud  Explore fraud risk scenarios  Assess the financial reporting culture  Organizational Structure  “Tone at the Top”  Zero Tolerance  Ethics Policy
  • 11. Preventive Controls  Related Parties  My hint for the day:  Search for Inter-relationships (see next slide)
  • 12. Co. B Board Co. A Member Board Your Board Co. C Member Operation Member Board Board Member Member Co. F Co. E Co. G Board Member Inter-relationships
  • 13. Accounts Payable Detection and Prevention  Potential Fraud schemes  Employees Committing Purchase Fraud  Fictitious Vendors  Personal purchases with company funds  Vendors Committing Fraud  Over-charging for goods purchases  Duplicate billings  Billing for goods not ordered or shipped  Collusion  Kickbacks
  • 14. Identification of Red Flags  Employees committing purchasing fraud  Vendor name, address = employee name, address  Undisclosed conflicts of interest  Vendors committing fraud  Documentation does not exist or lacks appropriate detail  Pricing does not agree with contracts  Duplicate invoices  Invoices submitted for materials not ordered or delivered
  • 15. Preventive Controls  Implement a fraud hotline and notify employees and vendors of its existence  Separate duties of A/P processing, vendor file maintenance, check stock custody, check preparation, check signing, check mailing and bank reconciliation  Separate purchasing and receiving functions  Require mandatory vacations and cross train employees so that someone else can fill in for these positions
  • 16. Preventive Controls  Use physical and software controls to restrict access to A/P and cash disbursements systems, including access to banking software  Maintain an approved vendor list independently of the purchasing department  Restrict access to the vendor master file and flag any changes to the file  Periodically purge the vendor master file to maintain only active approved vendors  Require proper authorization of all transactions  Do not pay from statements!
  • 17. Preventive Controls  Never sign blank checks!  Severely restrict the use of manual checks  Use positive pay or reverse positive pay systems  Use quality check stock  Investigate and void and reissue checks more than 90 days outstanding  Deface voided checks  Use pre-numbered, multi-part checks  Do not allow access to blank checks to those with signatory authority  Lock up check stock, signature stamps, plates
  • 18. Preventive Controls  Require dual signatures for payments over an established threshold  Request bank notification if a duplicate debit is pending posting
  • 19. Detection  My hints for the day:  Use dimensional testing  Use geo-coding
  • 20. Standard Detection Testing  Employees as Vendors:    Common   Common    
  • 21. Dimensional Testing Technique  Employee Networks as Vendors:           
  • 22. Searching for Addresses: Geo-Coding  Must be consistent in entering data for both the Employee Master and the Vendor Master files for matching  Obstacles  St. vs. Street  NE vs. North East  123 Main Street, Apartment B vs. 123 Main Street B or  123 Main Street  Apartment B
  • 23. Geo-Coding  http://www.gpsvisualizer.com/geocode  I enter: 1089 East Harrison Street, Martinsville, IN  The Google geocoder found:  1089 E Harrison St, Martinsville, IN 46151, USA street address: 1089 E Harrison St ZIP/postal code: 46151 city: Martinsville state/province: IN country: USA latitude, longitude: 39.429443, -86.415746  39.429443 -86.415746  N39° 25.7666', W086° 24.9448'  (precision: address)
  • 24.  By themselves, internal controls will not prevent fraud.  - Yet -  The perception of detection through monitoring of internal controls is a great way of discouraging fraud.
  • 25. Connect with me Pamela S. Mantone, CPA, CFF, CITP, CFE, FCPA, Senior Assurance Manager 423.756.7100 pammantone@decosimo.com On LinkedIn: http://www.linkedin.com/pub/pamela -mantone/10/824/807 Disclaimer: The contents of this presentation are for informational purposes only. The information is not intended to be a substitute for professional accounting counsel. Always seek the advice of your accountant or other financial planner with any questions you may have regarding your financial goals or specific situations.