Frauds
Fraud elements;
- Materiality
- Representation is knowingly false
- Reasonably placed reliance on the representation by someone else
- Result in financial damages
DOJ defines illegally activities;
- Obscure invesigations
- Inside dealings
- Accounting fraud (aka occupational fraud)
Obscure invesigations;
- Delete computer files
- Shred, alter, refuse to provide documents
- Bribery
Inside dealings:
- Bids
- Executive loans
- Share trading
Accounting frauds reported by ACFE;
- Asset misappropriations
- Corruptions
- Fraudulent financial reportings (Sales/AR + Payment/AP + Payroll/T&E)
Position of fraud auditors;
- Internal and External auditing: risk assessment, internal control, COSO, SOX 2002, ISACA,
- Fraud auditor: red flags, detection, data analytics,
- Forensic accountants: known facts, confess/witness, FCPA,
Fraud risk assessment SAS99
Enterprise risk management;
- Business risk: Objective (startup going concern issue, IPO), activity process,
- Inherent risk: Industry issues,
- Management risk: Risk appetite,
Fraud triangle/Fraud diamond;
- Pressure: incentive, life style,
- Opportunity: weak internal control
- Rationalization: personal feeling
Internal controls SAS78;
- Whitstlebower system: tips from suppleirs and customers
- Duty segregation
- Sudden internal process changes (accounting circle)
- Don’t exercise stipulated controls (approved suppliers list)
Red flags of transactions;
- Timing: frequency
- Amount: too much, same amount, round numbers, below limit,
- Counterparties: unknown
- Voided checks: no explanation
- Insufficient supervision: signature
- Adjustment to accounts: pattern
- Vendors: same vendors’ names with different address, one of customers,
Level of audit risk;
- CR + IR + DR = AR
- Audit assertions: completeness, existence,
Asset misappropriations
Cash;
- Theft, embezzlement
- Skimming: unrecorded cash sales
- Larceny: steal before deposited to the bank
- Billing: shell company
- Check tampering: intercept outgoing checks (pre-signed checks)
Inventories;
- Theft
- Weight of inventories
- Damaged good returned vs purchases (quanlity measurement)
- Defect sold products as inventories
Payroll;
- Ghost staffs (staff count, starter vs leaver)
- Falsified work hours
- Commission computation
T&E;
- Personal expenses
- Inflated expenses for reimbursement (keep cash or voucher)
- Fictitious expenses (blank receipts, letterhead, paid by clients)
- Multiple payments (every two weeks for expense claims, 30 days limit)
- Mileage claims computation
Payroll/T&E controls;
- Hiring function vs Payroll duties: keep seperate hire reocrds
- Payroll preparation vs approval vs distribution payment vs reconcilaition
Seperate payroll bank accounts
- Pay changes approved by manager and HR
- Excessive overtime
- Regular comparison (trend, budget/forecast, peers, departments, production schedule, improve productivity)
- Holiday/leaves/weakends
Forged signature
- Commission vs sales vs unrealized sales
linear correlation
- Approved travling (SAP Concur)
- Use P-Card for individual expense exceeding the threshold (not cash)
- Detailed expense claim reports (when, where, who, what, how much)
- Original supporting documents required (not scanned copy)
- Poor quality receipts (consecutiely numbered receipts)
Spot-check (client records, never appear)
Corrpution
- Conflict of interest
- Bribery (record as a part of COGS)
- Kickback (construction bids)
Fraudulent financial reportings
Revenue;
- Sale incentive, sales price, sales promotion,
- Recognition: premature
- Cut-off: unearned revenue, POC, unshipped goods,
- Classification: one-time gain
- Existence: bogus sales
- Round-tripping trades: purchase unnecessary inventories and sell back to supplier later (slow-moving AR).
- Parked sales: goods shipped to other warehouses owned by the firm
- Channel stuffing/side deals: overselling products to customers with hidden terms (discounts, return, cancel)
Ratios;
- AR turnover (days)
- GP/Net Sales, Net Sales/AR
- Return/Gross Sales (reverse after YE), Discount/ Gross Sales
- Adjustment: write-offs
Asset/liability misstatements;
- Capitalized expenses
- Non-existent PPE
- Improper assets valuation (IA, wastes, unauthorised PPE sales, dispose leased firm cars to RPT not at arm’s length)
- Overstated cash by forged bank statements
- Overaccrued restructuring reserves offset expenses
- Transactions with unconsolidated SPV (debts, impairment assets)
- Record barter transactions as sales
- Service contracts have less audit trails as compared to physical transactions
- Deferred expenses (improperly record salary across border)