acfe fraud prevention check-up - BKD

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Sample Fraud PolicyACTIONSCONSTITUTINGFRAUDOTHERIRREGULARITIESThe terms defalcation, misappropriation, and other fiscalirregularities refer to, but are not limited to:• Any dishonest or fraudulent act• Misappropriation of funds, securities, supplies, or otherassets• Impropriety in the handling or reporting of money orfinancial transactions• Profiteering as a result of insider knowledge of companyactivities• Disclosing confidential and proprietary information tooutside parties• Disclosing to other persons securities activities engaged in orcontemplated by the company• Accepting or seeking anything of material value fromcontractors, vendors, or persons providing services/materialsto the Company. Exception: Gifts less than $50 in value.• Destruction, removal, or inappropriate use of records,furniture, fixtures, and equipment; and/or• Any similar or related irregularityIrregularities concerning an employee’s moral, ethical, orbehavioral conduct should by resolved by departmentalmanagement and the Employee Relations Unit of HumanResources rather than the _________________ Unit.If there is any question as to whether an action constitutes fraud,contact the Director of ______________ for guidance.INVESTIGATIONRESPONSIBILITIESThe ____________ Unit has the primary responsibility for theinvestigation of all suspected fraudulent acts as defined in thepolicy. If the investigation substantiates that fraudulent activitieshave occurred, the ______________ Unit will issue reports toappropriate designated personnel and, if appropriate, to the Boardof Directors through the Audit Committee.Decisions to prosecute or refer the examination results to theappropriate law enforcement and/or regulatory agencies forindependent investigation will be made in conjunction with legalcounsel and senior management, as will final decisions ondisposition of the case.Page 2
Sample Fraud PolicyCONFIDENTIALITYThe ______________ Unit treats all information receivedconfidentially. Any employee who suspects dishonest orfraudulent activity will notify the _____________ Unitimmediately, and should not attempt to personally conductinvestigations or interviews/interrogations related to anysuspected fraudulent act (see REPORTING PROCEDUREsection below).Investigation results will not be disclosed or discussed withanyone other than those who have a legitimate need to know. Thisis important in order to avoid damaging the reputations of personssuspected but subsequently found innocent of wrongful conductand to protect the Company from potential civil liability.AUTHORIZATION FORINVESTIGATINGSUSPECTED FRAUDMembers of the Investigation Unit will have:• Free and unrestricted access to all Company records andpremises, whether owned or rented; and• The authority to examine, copy, and/or remove all or anyportion of the contents of files, desks, cabinets, and otherstorage facilities on the premises without prior knowledge orconsent of any individual who might use or have custody ofany such items or facilities when it is within the scope oftheir investigation.Page 3
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ACFE FRAUD PREVENTIONCHECK-UP
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ACFE FRAUD PREVENTIONCHECK-UPThe Be
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ACFE FRAUD PREVENTIONCHECK-UPACFE F
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Sponsored by:The Institute of Inter
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Team Members:Toby J.F. Bishop, CPA,
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Managing the Business Risk of Fraud
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establish their own fraud risk mana
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Fraud risk identification may inclu
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Thus, to properly address fraud ris
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The board also has the responsibili
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• Implementing adequate internal
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Fraud Risk Management Program Compo
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ecently been hired in the purchasin
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Organizations can identify and asse
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The Risk Assessment TeamA good risk
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This also involves understanding th
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- Invoices for goods not received o
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Other RisksRegulatory and Legal Mis
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SECTION 3: FRAUD PREVENTIONPrincipl
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An organization’s HR group is oft
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SECTION 4: FRAUD DETECTIONPrinciple
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Process ControlsProcess controls sp
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keep such information confidential.
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will vary depending on the nature,
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Conducting the InvestigationPlannin
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• Extended investigation — Cond
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Fraud ControlsDeloitte Forensic Cen
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APPENDIX B: SAMPLE FRAMEWORK FOR A
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APPENDIX C: SAMPLE FRAUD POLICY 41N
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CONFIDENTIALITYThe ______________ U
Page 67 and 68: Sample Fraud Policy Decision Matrix
Page 69 and 70: Identified Fraud Risksand Schemes (
Page 71 and 72: 2) Misappropriation of:a) Tangible
Page 73 and 74: ) Embezzlement(1) False accounting
Page 75 and 76: Fraud Prevention Area, Factor, or C
Page 83 and 84: O-Organization / PersonnelO1-Leader
Page 85 and 86: O4.3 Enhance Operational Skills & C
Page 87 and 88: PR-Prevent, Protect & PreparePR1-Ge
Page 89 and 90: E-Periodic EvaluationE1-Evaluation
Page 91 and 92: I2-CommunicationI2.1 Develop Commun
Page 93 and 94: CriminologyFraud Prevention Program
Page 117: Sample Fraud PolicyAssociation of C
Page 121 and 122: Sample Fraud PolicyFraud Policy Dec
Page 123 and 124: Fraud’s Worst Enemyhttp://www.fra
Page 125 and 126: ACFE Insights - ACFE Insightshttp:/
Page 127: ACFE Insights - ACFE Insightshttp:/
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