acfe fraud prevention check-up - BKD

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ACFE FRAUD PREVENTIONCHECK-UPACFE FRAUD PREVENTION CHECK-UP6. Environment-level anti-fraudcontrolsMajor frauds usually involve senior membersof management who are able to override process-levelcontrols through their high level ofauthority. Preventing major frauds thereforerequires a strong emphasis on creating aworkplace environment that promotes ethicalbehavior, deters wrongdoing and encouragesall employees to communicate anyknown or suspected wrongdoing to the appropriateperson. Senior managers may beunable to perpetrate certain fraud schemesif employees decline to aid and abet them incommitting a crime. Although “soft” controlsto promote appropriate workplace behaviorare more difficult to implement and evaluatethan traditional “hard” controls, they appearto be the best defense against fraud involvingsenior management.Results❑❑To what extent has the organization implementeda process to promote ethicalbehavior, deter wrongdoing and facilitatetwo-way communication on difficult issues?Such a process typically includes:——Having a senior member of managementwho is responsible for the organization’sprocesses to promote ethical behavior, deterwrongdoing and communicate appropriatelyon difficult issues. In large publiccompanies, this may be a full-time position,such as ethics officer or complianceofficer. In smaller companies, this will be anadditional responsibility held by an existingmember of management.ACFE.com (800) 245-3321 / +1 (512) 478-9000 8
ACFE FRAUD PREVENTIONCHECK-UPACFE FRAUD PREVENTION CHECK-UP——A code of conduct for employees at all levels,based on the company’s core values,which gives clear guidance on what behaviorand actions are permitted and whichones are prohibited. The code should identifyhow employees should seek additionaladvice when faced with uncertain ethicaldecisions and how they should communicateconcerns about known or potentialwrongdoing.——Training for all personnel upon hiring, andregularly thereafter, concerning the code ofconduct, seeking advice and communicatingpotential wrongdoing.——Communication systems to enable employeesto seek advice where necessary priorto making difficult ethical decisions and toexpress concern about known or potentialwrongdoing. Advice systems may includean ethics or compliance telephone help lineor email to an ethics or compliance office/officer. The same or similar systems may beused to enable employees (and sometimesvendors, customers and others) to communicateconcerns about known or potentialwrongdoing. Provision should be made toenable such communications to be madeanonymously, though strenuous effortsshould be made to create an environmentin which callers feel sufficiently confident toexpress their concerns openly. Open communicationmakes it easier to resolve theissues raised, but protecting callers fromretribution is an important concern.ResultsACFE.com (800) 245-3321 / +1 (512) 478-9000 9
Page 1 and 2: ACFE FRAUD PREVENTIONCHECK-UP
Page 3 and 4: ACFE FRAUD PREVENTIONCHECK-UPThe Be
Page 5 and 6: ACFE FRAUD PREVENTIONCHECK-UPACFE F
Page 7: ACFE FRAUD PREVENTIONCHECK-UPACFE F
Page 11 and 12: ACFE FRAUD PREVENTIONCHECK-UPACFE F
Page 13 and 14: Sponsored by:The Institute of Inter
Page 15 and 16: Team Members:Toby J.F. Bishop, CPA,
Page 17 and 18: Managing the Business Risk of Fraud
Page 19 and 20: establish their own fraud risk mana
Page 21 and 22: Fraud risk identification may inclu
Page 23 and 24: 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
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APPENDIX B: SAMPLE FRAMEWORK FOR A
Page 63 and 64:
APPENDIX C: SAMPLE FRAUD POLICY 41N
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CONFIDENTIALITYThe ______________ U
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Sample Fraud Policy Decision Matrix
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Identified Fraud Risksand Schemes (
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2) Misappropriation of:a) Tangible
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) Embezzlement(1) False accounting
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Fraud Prevention Area, Factor, or C
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O-Organization / PersonnelO1-Leader
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O4.3 Enhance Operational Skills & C
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PR-Prevent, Protect & PreparePR1-Ge
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E-Periodic EvaluationE1-Evaluation
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I2-CommunicationI2.1 Develop Commun
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CriminologyFraud Prevention Program
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Sample Fraud PolicyAssociation of C
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Sample Fraud PolicyCONFIDENTIALITYT
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Sample Fraud PolicyFraud Policy Dec
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Fraud’s Worst Enemyhttp://www.fra
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ACFE Insights - ACFE Insightshttp:/
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ACFE Insights - ACFE Insightshttp:/
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