acfe fraud prevention check-up - BKD

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Fraud Prevention Area, Factor, or Consideration Score NotesOur human resources department conducts background investigations with thespecific objective of assuring that persons with inappropriate records or charactersinconsistent with our corporate culture and ethics are identified and eliminated fromthe hiring process.Our human resources department conducts background investigations with respectto promotions or transfers into positions of responsibility.Personnel involved in the financial reporting process have been assessed with regardto their competencies and integrity and have been found to be of the highest caliber.All of our employees, vendors, contractors, and business partners have beenmade aware of our zero-tolerance policies related to fraud and are aware of theappropriate steps to take in the event that any evidence of possible fraud comes totheir attention.We have a rigorous program for communicating our fraud prevention policies andprocedures to all employees, vendors, contractors, and business partners.We have policies and procedures in place for authorization and approvals of certaintypes of transactions and for certain values of transactions to help prevent and detectthe occurrences of fraud.Our performance measurement and evaluation process includes an elementspecifically addressing ethics and integrity as well as adherence to the Code ofOrganizational Conduct.All new hires must undergo rigorous ethics and fraud awareness and fraudprevention training.All employees must attend periodic (at least annual) ethics and fraud awarenessand fraud prevention training, and the effectiveness of this training is affirmedthrough testing.Terminated, resigning, or retiring employees participate in an exit interview processdesigned to identify potential fraud and vulnerabilities to fraud that may be takingplace in our organization. A specific focus of these interviews is an assessment ofmanagement’s integrity and adherence to the Code of Organizational Conduct. Allconcerns resulting from these interviews are communicated to our audit committee.63
Fraud Prevention Area, Factor, or Consideration Score NotesWe have an effective whistleblower protection program and fraud hotline in place,and its existence and procedures are known to all employees, vendors, contractors,and business partners.We review the above fraud preventive mechanisms on an ongoing basis anddocument these reviews as well as the communication with the audit committeeregarding areas that need improvement.We have a fraud response plan in place and know how to respond if a fraudallegation is made. The fraud response plan considers:• Who should perform the investigation.• How the investigation should be performed.• When a voluntary disclosure to the government should be made.• How to determine the remedial action.• How to remedy control deficiencies identified.• How to administer disciplinary action.64
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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
Page 25 and 26: The board also has the responsibili
Page 27 and 28: • Implementing adequate internal
Page 29 and 30: Fraud Risk Management Program Compo
Page 31 and 32: ecently been hired in the purchasin
Page 33 and 34: Organizations can identify and asse
Page 35 and 36: The Risk Assessment TeamA good risk
Page 37 and 38: This also involves understanding th
Page 39 and 40: - Invoices for goods not received o
Page 41 and 42: Other RisksRegulatory and Legal Mis
Page 43 and 44: SECTION 3: FRAUD PREVENTIONPrincipl
Page 45 and 46: An organization’s HR group is oft
Page 47 and 48: SECTION 4: FRAUD DETECTIONPrinciple
Page 49 and 50: Process ControlsProcess controls sp
Page 51 and 52: keep such information confidential.
Page 53 and 54: will vary depending on the nature,
Page 55 and 56: Conducting the InvestigationPlannin
Page 57 and 58: • Extended investigation — Cond
Page 59 and 60: Fraud ControlsDeloitte Forensic Cen
Page 61 and 62: APPENDIX B: SAMPLE FRAMEWORK FOR A
Page 63 and 64: APPENDIX C: SAMPLE FRAUD POLICY 41N
Page 65 and 66: 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: Fraud Prevention Area, Factor, or C
Page 79 and 80: Fraud Prevention Area, Factor, or C
Page 81 and 82: 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 and 120: Sample Fraud PolicyCONFIDENTIALITYT
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:/
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ACFE Insights - ACFE Insightshttp:/
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