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acfe fraud prevention check-up - BKD

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• Results of employee or other stakeholder surveys concerning the integrity or culture of the organization.• Resources used by the organization.Appropriate measurement techniques will vary by organization based on factors, such as controls in place, <strong>fraud</strong>risks identified, and resources available. Examples of specific measurement techniques are:• The recurrence of <strong>fraud</strong>s uncovered.• The timeliness of implementation of remediation plans.• Timeliness in implementing additional controls to prevent new <strong>fraud</strong>s.• Assessment of the likelihood that <strong>fraud</strong>s perpetrated against other organizations in the same industry willoccur in the organization.• Comparison of <strong>fraud</strong> versus complaints, grievances, etc., via hotline calls.• Comparison of the number of <strong>fraud</strong>s discovered versus the number of <strong>fraud</strong> audits performed.• Ratios of problems revealed in background <strong>check</strong>s versus the number of <strong>check</strong>s performed.A senior member of management should be assigned as the process owner for each technique implemented. Eachprocess owner should:• Evaluate the effectiveness of the technique regularly.• Adjust the technique as required.• Document any adjustments.• Report immediately through the appropriate channels details of any modification necessary or anytechnique that becomes less effective.SECTION 5: <strong>fraud</strong> INVESTIGATION AND CORRECTIVE ACTIONPrinciple 5: A reporting process should be in place to solicit input on potential <strong>fraud</strong>, and a coordinatedapproach to investigation and corrective action should be used to help ensure potential <strong>fraud</strong> isaddressed appropriately and timely.It is essential that any violations, deviations, or other breaches of the code of conduct or controls, regardlessof where in the organization, or by whom, they are committed, be reported and dealt with in a timely manner.Appropriate punishment must be imposed, and suitable remediation completed. The board should ensure that thesame rules are applied at all levels of the organization, including senior management.Fraud Investigation and Response ProtocolsReceiving the AllegationPotential <strong>fraud</strong> may come to the organization’s attention in many ways, including tips from employees, customers, orvendors; internal audits; process control identification; external audits; or by accident. The board should ensure thatthe organization develops a system for prompt, competent, and confidential review, investigation, and resolution ofallegations involving potential <strong>fraud</strong> or misconduct. Protocols for the board’s involvement in such cases — which39

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