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Preface This phase of the project aims to develop ideas about the role of SAIs in the detection of corruption and money laundering. We have selected five respondents to answer the corruption questionnaire and five other to answer money laundering questionnaire, all of them are employees of FBSA. Also we have drawn conclusions according to the respondents answer.


The table below shows the details of the selected respondents:The table below shows the details of the selected respondents:

Anti-money laundering respondentName Designation Academic degree

Salah noori Director General Legal accountant Muhsin kata’a Director General Legal accountantWathib toma oraha Director General

assistant Legal accountant

Khamel khadum rashad

Senior cheif of audit team

Legal accountant

Najlaa sabri Abeer abdulilaah

Senior directorlegal

Legal Statistics

Anti-corruption respondent

Name Designation Academic degree

Saeed mohammed salman

Director General Legal accountant

Salah noori Director General Legal accountant

Entisaar fadheel fatoohi

Director General Legal accountant

Farooq tobia Director General Legal accountant

Sabah hasan khalaf Director General Legal accountant


EVALUATION OF THE ROLE OF AUDIT TO DETECT MONEY LAUNDERING

Q2. Does your SAI have its own “anti-money laundering strategy?

Rate

Yes team have been assigned to follow up FBSA activities

1 20%

Coordination with anti corruption joint council

3 60%

no 1 20%

Q1. Does your Constitution, law or regulation dealing with your SAI contain specific articles about its roles and responsibilities on the prevention and detection of money laundering?

4 respondent of 5 answers “yes” (Money laundering act NO. 93 of 2004, central bank of Iraq law number 56 and Iraqi bank law number 94).

Q3. Does detecting money laundering already embedded in the regular audit services?

Rate

Yes, it is an audit focus of the audit services being rendered by our SAI

3 60%

Yes, but merely incidental to the audit services being rendered and not an audit focus

1 20%

No, not a concern of our SAI but by the anti-corruption agencies

1 20%



Q4. Are there special departments, offices or units within your SAI

Rate

No, all departments, offices or units conducting audit are mandated to prevent, detect and investigate money laundering

2 20%

No, our SAI’s duties are merely confined in the evaluation of internal control system and providing recommendations for improvements

2 60%

No, our SAI’s duties are merely confined in the evaluation of internal control system and providing recommendations for improvements

1 20%

Q5. If there are special departments, offices or units within your SAI which are responsible for combating money laundering

Rate

5 answer was “none” 100%

Q6 How would you describe the approaches of your SAI Rate

Reactive approach based only on complaints and referrals received 1 20%

Both proactive and reactive 2 40%

Neither proactive nor reactive as our SAI’s role is limited only to rendering opinion on the fair presentation of financial statements of audited entities

2 40%



Q7. Upon discovery of red flags or symptoms of money laundering during a regular audit, what are the available courses of action for your SAI

Rate

The red flags will be referred by the SAI to the anti-money laundering agency

4 80%

The red flags will not be pursued but will be reported to management as internal control weaknesses

3 60%

Q8. Does your SAI have available facilities or mechanism to promote and intensify detection of money laundering?

Rate

Citizens help desk that caters money laundering complaints in whatever form

3 60%

Legal and financial assistance for auditors, witnesses and whistle blowers

1 20%

Anti-money laundering researches 2 40%

Promulgation of relevant accounting and auditing rules and regulations

3 60%

Declaration of assets and liabilities of public officials 1 20%

Governing Code of Ethics for Government Accountants and Auditors

5 100%

Updated publication of audit reports through the SAI’s website

1 20%



Q9. Dose your SAI have sufficient audit mandate, tools and techniques to detect money laundering which consists of three basic steps: Placement, Layering and Integration. With the current mandate, which of the three is most accessible to audit?

Rate

No answer 2 40%

None of the above 2 40%

Others (please specify) This mandate limited to central bank of Iraq with other banks and financial institutions

20%

Q10. Does your SAI have a specific manual or guideline on anti-money laundering

Rate

Yes / *Audit to prevent corruption in government institutions*Good governance in public assets*The role of control agencies in the fight against money laundering

2 40%

No 1 20%

No answer 2 40%



Q11. Does your SAI have adequate number of audit personnel that have specific skills……

Rate

Very few personnel have adequate training 4 80%

Audit personnel have no skills 1 20%

Q12. Does your SAI provide regular trainings to auditors about anti-money laundering in accordance with an annual training program……

Rate

Yes 5 100%

No /

Q13. How does your SAI report any encountered and/or detected money laundering incidents?

Rate

Our SAI issues a special audit report specifying the detected money laundering incidents, the pecuniary loss suffered by the government,…..

2 40%

Our SAI does not issue a special audit report but the money laundering incidents encountered and/or detected will be incorporated in the regular

3 60%

Other (Please specify) 1 20%



Q14. To which parties does your SAI submit the audit report containing findings…..

Rate

Entity’s management 3 60%

Executive body 1 20%

Law Enforcement Agency 3 60%

Others (please specify) 1/ Parliament/Inspector general

20%

Q15. What legal actions, if any, can your SAI initiate against the perpetrators…..

Rate

Criminal prosecution 1 20%

Civil suits for recovery of the government funds 2 40%

Administrative sanctions 1 20%

Our SAI’s role is purely recommendatory in nature 3 60%

Others (please specify) Inform inspector general office and commission of integrity

20%



Q16. In what field of the anti-money laundering efforts of your country does your SAI contributes best?

Rank

Preventive actions by providing recommendations 4 respondents chose only this option & only one rank this option as

“1”

Detective actions through the conduct of investigations and timely reporting of the audit results to the Prosecution Department

3

Punitive measures by implementing criminal, civil and administrative/disciplinary sanctions

2Q17. How would you rate the performance of your SAI in combating money laundering

Rate

Fair 1 20%

Good 4 80%

Q18. What methods, if any, do your SAI use to obtain objective information Rate

Third-party satisfaction surveys 2 20%

In-house research and studies 2 80%

Others (please specify) 2/ Peer reviewquestionnaire of money laundering and corruption and a number of assignments with INTOSAI and ARABOSAI.



Q19. Do the relevant laws, rules and regulations authorize your SAI to have full access to bank records of government officials………

Rate

Yes 5 100%

Q20. Which of the following factors do you think hampers your SAI’s role………

Rate

Corrupt people are not severely punished 4 80%

Collusion between law enforcers and corrupt people 2 40%

Authorized officials lack commitment 2 40%

Some superiors cover up for their subordinates 4 80%

Fear of retaliation and victimization 2 40%

Lack of competent and experienced staff to handle money laundering cases

2 40%

Q21What is necessary course of action to improve the role of your SAI in the fight against money laundering?

Rate

A change in the laws and regulations to ensure that tour SAI has the sufficient mandate

4 80%

Reorganization of the SAI to devote necessary resources 1 20%

Need for professional training to improve the skills and expertise of auditors……

5 100%

Need for professional training to awareness of auditors for anti-money laundering

4 80%



Q22. Does your SAI have exchange of information and experience with other SAIs

Rate

YesIf yes, please elaborate:

3 / Commission of integrity, inspector

general offices and anti corruption joint council

60%

No answer 2

Q23 Are there legal instruments in your country that provides for a joint undertaking among your SAI and anti-corruption agencies relative to the prevention, detection, reporting and prosecution of money laundering?

Rate

YesIf yes, please elaborate:

4/money laundering law, FBSA’S law, COI’s law and central bank law are joint instruments designated to fight

against corruption and money laundering

80%

No answer 1 20%

Q24. Does your SAI have any close cooperation and attachment of officers with other enforcement agencies to acquire investigative skill, knowledge and experience in the fight against money laundering?

Rate

Yes (please specify) 5 100%


Conclusions of money laundering questionnaireWe have reached a number of conclusions related to the money laundering questionnaire, we enlist it as following: 1. Our SAI’s law does not contain specific articles about its roles and responsibilities on the prevention and detection of money laundering, as well as no anti-money laundering strategy has been developed within our SAI and in case of emergence of indicators, our SAI will conduct fundamental tests in this regard.2. Our SAI approach in the detection and investigation of money laundering is proactive and reactive through its regular audit and referral of complaints received. Upon discovery of red flags or symptoms of money laundering during a regular audit, our SAI will conduct the following:• Red flags will be referred by the SAI to the inspector general concerned to conduct investigation and inform the Commission of Integrity with investigation’s results.• In case of inadequacy of the investigation conducted by Inspector General, our SAI will forward that case to Commission of Integrity to take actions and refer cases to affiliated courts in case of proving these accusations.


As well as there are a number of mechanisms to promote and intensify detection of money laundering, we include it as following:Citizens help deskPromulgation of relevant accounting and auditing rules and regulationsGoverning Code of Ethics for Government Accountants and AuditorsIn addition to that, few personnel have adequate training in the detection and investigation of money laundering. Furthermore, our SAI is keen to engage his employees in training programs and workshops, especially on the topics of anti-money laundering to ensure the knowledge and experience needed in this area.Our SAI issues a special audit report, specifying the detected money laundering incidents and the persons responsible/liable and the laws and rules violated to be submitted to Commission of Integrity, auditees and inspector general with recommendations to take legal actions against violators.


Our SAI efforts are Preventive actions by providing recommendations to improve entity’s anti-money laundering and internal control system and sharing best practices and benchmarking information to assist decision-makers.Factors that hamper our SAI’s role in the fight against money laundering are represented by corrupt people who not severely punished and the cover up subordinates by their superiors. There is close cooperation between our SAI and anti-corruption agencies reflected by his membership in the Anti-Corruption council and Central Bank of Iraq's Monetary Laundering Reporting Office.


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EVALUATION OF THE ROLE OF AUDIT TO DETECT CORRUPTION

Q1. How would you describe the legal status and existence of your (SAI)? Rate

Established by virtue of the Constitution and enjoys a permanent legal status

5 100%

Q2. organizational structure of your SAI? Rate

Westminster model, also known as the Anglo-Saxon or Parliamentary model where the Office of the Auditor General is an independent body that reports to the Parliament

5 100%

Q3. Audit Committee/Board or Head of your SAI enjoy a fixed term……….. Rate

Yes, they have a fixed term under the Constitution or law

5 100%

Q4. the independence or relationship of your SAI with the other branches of the government?

Rate

Independent of the executive, legislative and judicial departments of the state

5 100%


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Q5. Does your SAI enjoy fiscal autonomy or financial independence in its operation?

Rate

Yes, our SAI’s budget is subject to automatic release based on a fixed percentage of the annual state budget which cannot be diminished or reduced by the Parliament or Congress

1 100%

No, our SAI’s yearly budget undergoes the scrutiny and review process of the Budget Department and the Parliament/Congress and the proposed budget could be reduced or increased by them

3

Others (please specify) Our SAI budget relies on certain expenditures and revenues within the general budget of the state, and our Comptroller General has

the power of the minister of finance with regard to resources

allocations Q6. Over what entities does your SAI have legal mandate and authority to audit?

Rate

Central or national government agencies, bureaus, offices, instrumentalities and local government units at all levels

5 100%

State-owned and controlled corporations, universities, colleges and enterprises

4 80%

Private entities and non-governmental organizations receiving loans, subsidy or grants from the state

4 80%

Social undertakings that enjoys financial support from the state 3 60%




Q7. What types of audit services does your SAI render? Rate

Performance Audit 5 100%

Compliance Audit/Regularity Audit 4 80%

Financial Audit 5 100%

Environmental Audit 5 100%

Economic Accountability Audit 1 20%

Others (please specify) Legality audit

Q8. Does your Constitution, law contain specific articles about its roles and responsibilities on anti-corruption?

Rate

If yes, please summarize them briefly

2 answer/ According to article 16 of the FBSA’s law no. 31, The Board must report to the General

Prosecution, Commission of Integrity, or the relevant investigative authorities, each by its

jurisdiction, on every financial irregularity detected if it was recognized as an offence.

40%

No 2 40%

No answer 1




Q9. Does your SAI have its own “anti-corruption strategy” Rate

Yes (please summarize the goals and actions)

2 answers/ FBSA is a key partner in the fight against corruption and work within

the national strategy to combat corruption, furthermore he is also an active member in the anti-corruption

Joint Council, which has formed by the Council of Ministers

40%

No 1

No answer 2

Q10. Does the Strategic Plan of your SAI contain strategic goals and action concerning fight against corruption?

Rate

Yes (please summarize the goals and actions)

2 answers/ Helping, assisting and working with anti corruption agencies and joining activities and assignments

of the national strategy and UNCAC

40%

No 2 40%

No answer 1

Q11. Does detecting corruption already embedded in the regular audit services that your SAI has been performing?

Rate

Yes, it is an audit focus of the audit services being rendered by our SAI

5 100%




Q12. Are there special departments, offices or units within your SAI which have been assigned specific functions and/or powers in the prevention,

Rate

If yes, please specify the name of the departments, offices or units

4 answers/ (Cross-audit departmentLegal department has the mandate to investigate and refer cases to relevant departments or offices)

80%

No, all departments, offices or units conducting audit are mandated to prevent, detect and investigate corrupt activities and transactions

1 20%

Q13. how long such departments, offices or units have been in place? Rate

More than 20 years 1 20%

10-20 years 1 20%

None 2 40%

No answer 1 20%

Q14. Does your SAI have adequate number of audit personnel that have specific skills in the detection of corrupt activities

Rate

Yes (estimated number of personnel with special training/skills)

3 answers/ All departments and offices have sufficient number of skilled staff300 employees

60%

Very few personnel have adequate training in combating corruption

2 40%

No answers 1 20%




Q15. Does your SAI provide regular trainings to auditors Rate

Yes (please enumerate the special trainings)

5 100%

Q16. Does your SAI have a specific manual or guideline Rate

If yes, please specify the title of the manual 2 (Financial audit guide) 40%

No 1 20%

No answer 2 40%

Q17. How would you describe the approaches of your SAI Rate

Proactive through a risk based audit approach

4 80%

Reactive approach based only on complaints and referrals received

1 20%

Both proactive and reactive 2 40%

Limited only to detecting red flags or symptoms of corruption which will be referred

3 60%




Q18. Upon discovery of red flags, what are the available courses of action for your SAI?

Rate

will conduct a full blown investigation 1 20%

will be referred to the special department, office or unit of the SAI for the conduct of a full blown investigation

2 40%

will be referred by the SAI to the anti-corruption agency

4 80%

Q19. Dose your SAI have available facilities or mechanism to promote and intensify prevention and detection of corrupt activities

Rate

Hotline 1 20%

Corruption alert section in the SAI website 1 20%

Citizens help desk 2 40%

Anti-corruption researches 3 60%

Promulgation of accounting and auditing rules and regulations 3 60%

Declaration of assets of public officials 1 20%

Governing Code of Ethics 4 80%

Public Information Office 3 60%

Updated publication of audit reports through the SAI’s website 4 80%




Q20. Does your SAI have sufficient audit mandate to detect relevant cases of the following types of corruption?

Rate

Fraud 1 20%

Criminal breach of trust 2 40%

Illegal gratuities 1 20%

Asset misappropriation 2 40%

Embezzlement 2 40%

Forgery 1 20%

Kickback 1 20%

All types of Illegal activities in public procurement procedures

1 20%

Others All the mentioned cases we address it and refer it

to relevant agencies

Q21. which of the audit services are most instrumental in the detection and prevention of corruption in your country based on SAI’s experience?

Rate

Compliance Audit/Regularity Audit 4 80%

Performance Audit 4 80%

Risk-based audit 1 20%

Economic Accountability Audit 2 40%

Contractors audit 1 20%

Environmental audit 1 20%

Specialized audit 1 20%




Q22. What audit tools and techniques does your SAI perform to detect corrupt activities

Rate

Financial statements audit 4 80%

Risk analysis 3 60%

Cross-audit 1 20%

Evaluation of the internal audit system 1 20%Q23. please discuss briefly the most high profile corruption case that it uncovered……

Rate

subcontractors 2 40%

Money laundering 1 20%

Nepotism 1 20%

Bribery 1 20%

Abuse of position 1 20%

Q24. How does your SAI report any encountered and/or detected corrupt activities

Rate

Our SAI issues a special audit report specifying the audited corrupt activities and transactions, the pecuniary loss suffered by the government, the persons responsible/liable and the laws and rules violated.

5 80%




Q25. To which parties does your SAI submit the audit report Rate

Entity’s management 4 80%

Legislative body 4 80%

Executive body 3 60%

Law Enforcement Agency 2 40%

Others (please specify) 2/ Inspector’s general offices, commission of integrity

40%

Q26. What legal actions, if any, can your SAI initiate against the perpetrators of corrupt activities

Rate

Criminal prosecution 1 80%

Civil suits for recovery of the government funds 2 80%

Administrative sanctions 3 60%

Our SAI’s role is purely recommendatory in nature

1 40%

Q27. What mechanism does your SAI adopt to ensure that the audit findings and recommendations contained in your audit reports are properly acted

Rate

according audit goals and depending on cases referred to audit

1 20%

refer some cases to Commission of Integrity 1 20%

Follow-up office 1 20%




Q28. In what field of the anti-corruption efforts of your country does your SAI contribute best?

Rate

Preventive actions 5 100%

Detective actions 4 80%

Q29 How would you rate the performance of your SAI in combating corruption?

Rate

Good 4 80%

Very Good 1 20%

Q30. What methods do your SAI use to obtain objective information Rate

In-house research and studies 4 80%

Others (please specify) 1 20%

None 1 20%

Q31. Has your SAI implemented a self-integrity assessment such as the “IntoSAINT Methodology”

Rate

Yes 2 40%

No 1 20%

No answer 2 40%




Q32. Which types of controls do not have a sufficient level of maturity to ensure the integrity and competence of your SAI in the field of anti-corruption?

Rate

Response to integrity violations 1 20%

Recruitment and selection 1 20%

Administrative organization and internal control 2 40%

Integrity awareness 3 60%

SAI legal framework 1 20%

None 1 20%Q33. Do you think that there must be changes in the legal framework and organizational structure of your SAI to better address growing demand for anti-corruption activities?

Rate

Yes (please elaborate) 1/ The SAI should have a special department devoted to combat corruption

20%

None 4 80%

Q34. Which of the following factors do you think hampers your SAI’s role Rate

Corrupt people are not severely punished 4 80%

Collusion between law enforcers and corrupt people 1 20%

Authorized officials lack commitment 2 40%

Some superiors cover up for their subordinates 3 60%

Fear of retaliation and victimization 2 40%

People’s and media’s participation not mobilized well 1 20%

Lack of competent and experienced staff to handle corruption cases

1 20%




Q35. Do the relevant laws, rules and regulations guarantee those conducting fraud/forensic audits the rights to the following?

Rate

Immunity from harassment cases 2 40%

Legal and financial assistance to auditors acting as witnesses 2 40%

Power to issue compulsory processes 3 60%

Access to government offices’ accounting records, financial statements, contracts and other legal instruments

4 80%

Q36. Good governance is the best antidote to fraud and corruption.

• Holding training programs• Holding conferences• audit plans• good coordination and cooperation between the three control agencies (FBSA, COI, IGO’s)

Q37. Has your SAI ever cooperated with foreign counterparts Rate

Yes 3 60%

No 1 20%

No answer 1 20%

Q38. Are there legal instruments in your country that provides for a joint undertaking

Rate

Yes 2 40%

No 2 40%

No answer 1 20%


Conclusions of Corruption questionnaire1. Our SAI legal status and existence established by virtue of the Constitution and enjoys a permanent legal status; the head of our SAI enjoy a fixed term under the Constitution or law and Independent of the executive, legislative and judicial departments of the state.Our SAI’s yearly budget undergoes the scrutiny and review process of the Budget Department and the Parliament and the proposed budget could be reduced or increased by them.All state departments concerned with financing and collecting resources subject to be audited by our SAI.Types of audit services our SAI render is performance audit, financial audit, compliance audit, environment audit and legality audit.


2. FBSA is one of the main pillars in the fight against corruption and his work in accordance with goals of the anti-corruption strategy and detecting corruption already embedded in the regular audit services that our SAI has been performing.

Our SAI has adequate number of audit personnel that have specific skills in the detection of corrupt activities, but that number is considered moderate as compared with the total staff number. Therefore, we try to involve more personnel into training program to improve and raise this ratio.The methods of our SAI in detecting corrupt activities are a proactive approach with the possibility of using reactive approach based only on referral complaints received.

FBSA have its mechanism to promote and intensify prevention and detection of corrupt activities through:• Promulgation of accounting and auditing rules and regulations• Governing Code of Ethics for Government Accountants and Auditors• Updated publication of audit reports through the SAI’s website All forms of corruption are subject of scrutiny by FBSA which has authority in such cases.


Our SAI will submit audit report containing findings and recommendations on corrupt activities to Entity’s management, Legislative body, Commission of integrity and Inspector’s general offices to conduct the required investigation.

3. Our SAI efforts are Preventive actions and we can rate its performance as good in the field of combating corruption.

4. Corrupt people are not severely punished and some superiors cover up for their subordinates is the main obstacles that our SAI facing

5. Good governance is the best antidote to fraud and corruption that’s through holding conferences and programs to help identify this phenomenon and its negative impact on society, also to find appropriate ways to reduce its effect by developing mechanisms of cooperation between state agencies and citizens.


Thank you for your attention

bestpowerpointtemplates.com. preface this phase of the project aims to develop ideas about the role...

Documents

role of audit

detection of money laundering

money laundering questionnaire

money laundering act

money launderingrate

money laundering220

money launderingq2

money launderingq4