acfe fraud prevention check-up - BKD

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Sample Fraud PolicyREPORTINGPROCEDURESGreat care must be taken in the investigation of suspectedimproprieties or irregularities so as to avoid mistaken accusationsor alerting suspected individuals that an investigation is underway.An employee who discovers or suspects <strong>fraud</strong>ulent activity willcontact the _____________ Unit immediately. The employee orother complainant may remain anonymous. All inquiriesconcerning the activity under investigation from the suspectedindividual, his or her attorney or representative, or any otherinquirer should be directed to the Investigations Unit or theLegal Department. No information concerning the status of aninvestigation will be given out. The proper response to anyinquiries is: “I am not at liberty to discuss this matter.” Underno circumstances should any reference be made to “theallegation,” “the crime,” “the <strong>fraud</strong>,” “the forgery,” “themisappropriation,” or any other specific reference.The reporting individual should be informed of the following:• Do not contact the suspected individual in an effort todetermine facts or demand restitution.• Do not discuss the case, facts, suspicions, or allegations withanyone unless specifically asked to do so by the LegalDepartment or ____________ Unit.TERMINATIONIf an investigation results in a recommendation to terminate anindividual, the recommendation will be reviewed for approval bythe designated representatives from Human Resources and theLegal Department and, if necessary, by outside counsel, before anysuch action is taken. The ___________ Unit does not have theauthority to terminate an employee. The decision to terminate anemployee is made by the employee's management. Should the_____________ Unit believe the management decisioninappropriate for the facts presented, the facts will be presented toexecutive level management for a decision.ADMINISTRATIONThe Director of ___________ is responsible for the administration,revision, interpretation, and application of this policy. The policywill be reviewed annually and revised as needed.APPROVAL________________________________(CEO/Senior Vice President/Executive_______________DatePage 4
Sample Fraud PolicyFraud Policy Decision MatrixInvestigation Internal Finance/ Executive Line Risk Legal Public EmployeeAction Required Unit Audit Accounting Mgmt Mgmt Mgmt Relations Relations1. Controls to Prevent Fraud S S S SR SR S S S S2. Incident Reporting P S S S S S S S S3. Investigation of Fraud P S S S4. Referrals to Law Enforcement P S5. Recovery of Monies due to Fraud P6. Recommendations to Prevent Fraud SR SR S S S S S S S7. Internal Control Reviews P8. Handle Cases of a Sensitive Nature P S S S S S9. Publicity/Press Releases S S P10. Civil Litigation S S P11. Corrective Action/RecommendationsTo Prevent Recurrences SR SR S SR S S12. Monitor Recoveries S P13. Pro-active Fraud Auditing S P14. Fraud Education/Training P S S S15. Risk Analysis of Areas ofVulnerability S S P16. Case Analysis P S17. Hotline P S18. EthicsLine S S PP (Primary Responsibility) S(Secondary Responsibility) SR (Shared Responsibility)Page 5
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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
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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 and 118: Sample Fraud PolicyAssociation of C
Page 119: Sample Fraud PolicyCONFIDENTIALITYT
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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