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acfe fraud prevention check-up - BKD

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O-Organization / PersonnelO1-Leadership & ChampionsO1.1 Define Leadership & Champion Responsibilities to include communicating how <strong>fraud</strong> risk managementprogram objectives facilitate organizational objectives, how individuals contribute to achieving program objectivesand why the program is and should be s<strong>up</strong>ported enterprise wide.O1.2 Screen & Select Program Leadership & Champions to assure that the leaders and champions are qualified toserve as advocates for anti-<strong>fraud</strong> messaging based <strong>up</strong>on prior <strong>up</strong>standing conduct or remorseful transformationfrom prior <strong>fraud</strong>ulent/corr<strong>up</strong>t or otherwise inappropriate conduct.O1.3 Enhance Champion Skills & Competencies to include a thorough understanding of <strong>fraud</strong>, stressors that trigger<strong>fraud</strong>ulent conduct, and the scope, parameters and activities of the <strong>fraud</strong> risk management program.O2-Oversight PersonnelO2.1 Define Oversight Structure & Responsibilities to:• include in the appropriate charter documents whether the entire board, a board member, or a boardcommittee has been assigned oversight responsibilities for directing the activities of the <strong>fraud</strong> riskmanagement program,• evidence a commitment to a proactive approach to <strong>fraud</strong> risk management.• play an active role in the risk assessment process, and using internal audit, and external auditors, asmonitors of <strong>fraud</strong> risks.• appoint one executive-level member of management to be responsible for <strong>fraud</strong> risk management.• approve sufficient resources in the budget and long-range plans to enable the organization to achieve theseobjectives.• ensure that management designs effective <strong>fraud</strong> risk management policies to encourage ethical behaviorand to empower employees, customers, and vendors to insist those standards are met everyday.• model good board governance practices (like board independence, ) as a component of the <strong>fraud</strong> riskmanagement program.• require that the audit committee meet separately with the external audit firm and chief audit executive todiscuss the results of the anti-<strong>fraud</strong> program on the entity’s financial statements.• ensure the board is receiving accurate and timely information from management, employees, internal andexternal auditors, and other stakeholders regarding potential <strong>fraud</strong> occurrences.• assure protection of all requisite privileges and adherence to information management policy forcommunications related to <strong>fraud</strong> investigations and audit committee discussions.O2.2 Screen & Select Oversight Personnel to identify the board member(s) best suited based <strong>up</strong>on skills, experience,knowledge, and character (based in part <strong>up</strong>on the results of background <strong>check</strong>s) to provide anti-<strong>fraud</strong> programoversight.O2.3 Enhance Oversight Skills & Competencies so the board:• has a thorough understanding of what constitutes <strong>fraud</strong> and corr<strong>up</strong>tion risk.• sets the appropriate “tone at the top” in its own independent practices and through the CEO jobdescription, evaluation, and succession-planning processes.• maintains oversight of the <strong>fraud</strong> and corr<strong>up</strong>tion risk assessment.• evaluates management’s identification of <strong>fraud</strong> and corr<strong>up</strong>tion risks.70

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