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    Corporate fraudTopic Gateway Series

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    Corporate fraudTopic Gateway Series No. 57

    Prepared by Helenne Doody and Technical Information Service May 2009

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    Corporate fraudTopic Gateway Series

    About Topic Gateways

    Topic Gateways are intended as a refresher or introduction to topics of interest

    to CIMA members. They include a basic definition, a brief overview and a fuller

    explanation of practical application, and finally signpost some further resources

    for detailed understanding and research.

    Topic Gateways are available electronically to CIMA Members only in the CPD

    Centre on the CIMA website, along with a number of electronic resources.

    About the Technical Information Service

    CIMA supports its members and students with its Technical Information Service

    (TIS) for their work and CPD needs.

    Our information specialists and accounting specialists work closely together to

    identify or create authoritative resources to help members resolve their work

    related information needs. Additionally, our accounting specialists can help CIMA

    members and students with the interpretation of guidance on financial reporting,

    financial management and performance management, as defined in the CIMA

    Official Terminology2005 edition.

    CIMA members and students should sign into My CIMA to access these services

    and resources.

    Chartered Institute

    of Management Accountants

    26 Chapter Street

    London SW1P 4NP

    United Kingdom

    2

    T. +44 (0)20 7663 5441

    F. +44 (0)20 7663 [email protected]

    mailto:[email protected]:[email protected]
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    Corporate fraud

    Definition

    Fraud essentially involves using deception to make a personal gain for oneself

    dishonestly and/or create a loss for another.Although definitions vary, most are

    based around these general themes.

    The term fraud commonly includes activities such as theft, corruption,

    conspiracy, embezzlement, money laundering, bribery and extortion.

    ContextIn the current CIMA syllabus, students will study and may be examined on fraud

    in Paper 3, Management accounting risk and control strategy.

    Related concepts

    Corporate governance; risk management; internal control; information systems

    control.

    Overview

    Surveys are regularly carried out to estimate the true scale and cost of fraud tobusiness and society. While findings vary and it is difficult to ascertain the full

    extent of fraud, all surveys indicate that fraud is prevalent within organisations

    and remains a serious and costly problem. Fraud may even be increasing due to

    greater globalisation, more competitive markets, rapid developments in

    technology and periods of economic difficulty.

    Despite the serious risk that fraud presents to business, many organisations still

    do not have formal systems and procedures in place to prevent, detect and

    respond to fraud. No system is completely fool proof, but business can take steps

    to deter fraud and make it much less attractive to commit. Managementaccountants, whose professional training includes information and systems

    analysis, have a significant role to play in developing and implementing anti-fraud

    measures within their organisations.

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    There are many types of corporate fraud, including the following common

    frauds:

    theft of cash, physical assets or confidential information misuse of accounts procurement fraud payroll fraud financial accounting mis-statements inappropriate journal vouchers suspense accounting fraud fraudulent expense claims false employment credentials bribery and corruption.This topic gateway focuses on fraud perpetrated by those internal to the

    organisation. Businesses are also susceptible to fraud committed by outsiders,

    such as corporate identity theft, intellectual property fraud or cyber crime.

    The topic gateway is based on CIMAs publication Fraud Risk Management: a

    guide to good practice, which explores fraud risk management in greater depth.

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    Application

    Internal fraud

    There are three main categories of internal fraud that affect organisations. These

    are summarised in the following diagram.

    Adapted from page 8 of Fraud Risk Management: a guide to good practice

    Further information on common types of internal fraud and methods of

    perpetration is included in CIMAs Fraud Risk Management: a guide to good

    practice.

    Which businesses are affected?

    Fraud is an issue that all organisations may face regardless of size, industry or

    country. If the organisation has valuable property, for example, cash, goods,

    information or services, then fraud is likely to be attempted.

    The scale of the problem

    There have been many attempts to measure the extent of fraud, but it is not easy

    to compile reliable statistics. One of the key aspects of fraud is deception, so

    fraud can be difficult to identify. Often survey results reflect only the instances of

    fraud that have actually been discovered. It is estimated that the majority of

    frauds go undetected. Some frauds may not be reported even when they are

    found. It is also often hard to distinguish fraud from carelessness and poor record

    keeping.

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    Although survey results and research may not give a complete picture, statistics

    indicate the extent of the problem. There is no doubt that fraud is prevalentwithin organisations and remains a serious issue. Some surveys put the

    proportion of companies suffering from fraud as high as 85%. Research shows

    that fraud is growing, with reported cases of fraud being much higher in 2008

    than in 2007. Fraud is likely to continue to grow during economic difficulties.

    Organisations may need to keep a particularly close eye on their budgets during a

    recession, but organisations should see a return on their investment in fighting

    fraud. Surveys show that UK companies suffered average fraud losses of

    1.75 million over a two year period. These figures exclude undetected lossesand indirect costs to the business such as management costs or damaged

    reputation. Other research estimates that organisations lose as much as 7% of

    their annual revenues to fraud.

    Given the prevalence of fraud and the negative consequences, there is a

    compelling argument that organisations should invest time and resources in

    tackling fraud.

    Fraud risk management

    In order to manage the risk of fraud, organisations should periodically identifythe risks of fraud within their organisation, using the process set out in the CIMA

    risk management cycle. The CIMA risk management cycle is an interactive

    process of identifying risks, assessing their impact, and prioritising actions to

    control and reduce risks.

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    Figure 2: The CIMA risk management cycle

    Adapted from page 19 of Fraud Risk Management: a guide to good practice

    Fraud risks should be identified for all areas and processes of the business and

    then be assessed in terms of impact and likelihood. As well as the monetary

    impact, the assessment should consider non-financial factors such as reputation.

    Once the scale of risk has been assessed and understood, an organisation should

    implement an effective anti-fraud strategy for responding to fraud risks.

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    An anti-fraud strategy

    An effective anti-fraud strategy has four main components:

    prevention detection deterrence response.The following diagram summarises these components and the context within

    which an anti-fraud strategy sits.

    Figure 3: An effective anti-fraud strategy

    Adapted from page 25 of Fraud Risk Management: a guide to good practice

    The training received by management accountants is a very good basis for

    implementing an anti-fraud strategy. Management accountants are expected to

    have a broad understanding of business processes. They also understand the

    systems and procedures that an efficient and effective organisation should have.

    A further asset is the ability to think and act logically, which is something the

    management accountant develops with experience.

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    The various components of an effective anti-fraud strategy are discussed in detail

    in CIMAs Fraud Risk Management: a guide to good practice. Some key pointsare summarised below. These anti-fraud approaches are generic and can be

    applied flexibly to different organisations and particular circumstances.

    Fraud prevention

    There are two main elements to fraud prevention:

    1. A sound ethical culture.2. Sound internal control systems.Developing a sound ethical culture

    In order to establish a sound ethical culture, CIMA recommends that

    organisations have:

    1. A mission statement that refers to quality or ethics and defines how theorganisation wants to be regarded externally.

    2. Clear policy statements on business ethics and anti-fraud, with explanationsabout acceptable behaviour in risk-prone circumstances.

    3. Management which is seen to be committed through its actions.4. Fraud risk training and awareness for all employees and key business partners.5. A process of reminders about ethical and fraud policies, for example, an

    annual letter and/or declarations.

    6. Periodic assessment of fraud risk.7. A route through which suspected fraud can be reported.8. An aggressive audit process which concentrates on fraud risk areas.Sound internal control systems

    An internal control system comprises all those policies and procedures that

    collectively support an organisations operation. Internal controls typically deal

    with approval and authorisation processes, access restrictions, transaction

    controls, account reconciliations and physical security. These procedures often

    include the division of responsibilities, and checks and balances to reduce risk.

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    The number and type of internal controls that an organisation can introduce

    depends on its nature and size. Although fraud is prevalent across organisationsof all sizes, sectors and locations, research shows that certain business models

    have greater levels of fraud risk than others. The control environment should be

    adjusted to fit with the degree of risk exposure. Where possible, internal controls

    should address warning signs and alerts to minimise fraud.

    Fraud detection

    It will never be possible to eliminate all fraud. No system is completely fraud

    proof because many fraudsters can by pass the control systems put in place to

    stop them. However, if an organisation pays greater attention to the mostcommon indicators, this can provide early warning that something is wrong and

    increase the likelihood of discovering the fraudster.

    Fraud indicators fall into two categories:

    1. Warning signs2. Fraud alertsWarning signs

    Warning signs have been described as organisational indicators of fraud risk.

    Some examples are given below, categorised under the headings of business risk,

    financial risk, environmental risk and IT and data risk.

    Business risk

    Business risk can be indicated by the absence of an anti-fraud policy and culture,

    together with lack of staff management supervision. Bonus schemes linked to

    ambitious targets or directly to financial results can point to risky behaviour.

    Unusual staff behaviour patterns, for example, employees who do not take their

    annual leave allocation or who are unwilling to share duties, can also indicatebusiness risk.

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    Other warning signs include:

    inadequate recruitment processes and no screening lack of job segregation no independent checking of key transactions inadequate access controls to physical assets and IT security systems poor internal control documentation large cash transactions.Financial risk

    Significant pressures on management to obtain additional finance can indicate a

    financial risk. Other signs include the extensive use of tax havens without clear

    business justification, along with complex transactions or financial products.

    Environmental risk

    This can occur when new accounting or other regulatory requirements are

    introduced. Highly competitive market conditions and decreasing profitability

    levels can also lead to environmental risk, as can significant changes in customer

    demand.

    IT and data risk

    Unauthorised access to systems gives rise to IT and data risk, as do rapid changes

    in information technology. Users sharing or displaying passwords is also highly

    risky.

    Fraud alerts

    Fraud alerts have been described as specific events, or red flags, which may

    indicate fraud. Some examples of fraud red flags are:

    discrepancy between earnings and lifestyle photocopied documents in place of originals missing approvals or authorisation signatures extensive use of suspense accounts inappropriate or unusual journal entries above average number of failed login attempts.

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    Fraud detection tools and techniques

    Available tools and techniques for identifying possible fraudulent activity include:

    ongoing risk assessment trend analysis data matching exception reporting internal audit

    reporting mechanisms.

    Fraud response

    An organisations approach to dealing with fraud should be clearly described in

    its fraud policy and fraud response plan. The plan is intended to provide

    procedures which allow for evidence gathering and collation. In summary, a

    fraud response plan should include information under the following headings:

    purpose of the fraud response plan

    corporate policy definition of fraud roles and responsibilities the response the investigation organisations objectives with respect to dealing with fraud follow up action.The fraud response plan should reiterate the organisations commitment to high

    legal, ethical and moral standards in all its activities, and its approach to dealing

    with those who fail to meet those standards. Organisations should be clear about

    how to enforce the rules or controls which are in place to counter fraud risks.

    They must also ensure that employees know how to report suspicious behaviour.

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    Reasonable steps for responding to detected or suspected instances of fraud

    include:

    clear reporting mechanisms a thorough investigation disciplining of the individuals responsible (internal, civil and/or criminal) recovery of stolen funds or property modification of the anti-fraud strategy to prevent similar behaviour in future.There are lessons to be learned from every identified fraud incident. The

    organisations willingness to learn from experience is as important as any other

    response. Organisations should examine the circumstances and conditions which

    allowed the fraud to occur, with a view to improving systems and procedures so

    that similar frauds do not occur in future.

    Fraud deterrence

    It is clear from the diagram in Figure 2 that the various elements of an effective

    anti-fraud strategy are closely interlinked. Each plays a significant role in

    combating fraud, with fraud deterrence at the centre. Fraud detection acts as a

    deterrent by sending a message to likely fraudsters that the organisation isactively fighting fraud and that procedures are in place to identify any illegal

    activity. The possibility of being caught will often persuade a potential

    perpetrator not to commit a fraud. There should also be complementary

    detection to counter the fact that the prevention controls may be insufficient in

    some cases.

    It is also important to have a consistent and comprehensive response to

    suspected and detected fraud incidents. This sends a message that fraud is taken

    seriously and that action will be taken against perpetrators. Each case that is

    detected and investigated should reinforce this deterrent and act as a form offraud prevention.

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    References

    Report to the Nation on Occupational Fraud and Abuse. (2008). Austin, TX: The

    Association of Certified Fraud Examiners (ACFE)

    Available from: www.acfe.org

    [Accessed 12 March 2009]

    Fraud risk management: a guide to good practice. (PDF 1,238Kb). CIMA

    Technical Guide, January 2009, London: CIMA

    Available from: www.cimaglobal.com/fraud

    [Accessed 12 March 2009]

    Kroll Global Fraud Report Annual Edition2008 /2009. Kroll and the Economist

    Intelligence Unit. (2008 /2009).

    Available from: www.kroll.com/about/library/fraud

    [Accessed 12 March 2009]

    Economic crime: people, culture and controls the 4th biennial global economic

    crime survey 2007. (2007). PricewaterhouseCoopers.

    Available from: www.pwc.com/crimesurvey

    [Accessed 12 March 2009]

    Further Information

    CIMA Publications

    Iyer, N. and Samociuk, M. Rotten to the Core in CIMAExcellence in Leadership,

    2007, Issue 2, pp 46-49

    Turner, C. (2007). Fraud risk management: a practical guide for accountants.

    London: CIMA

    Managing responsible business. (2008). A survey which explores how companiesare managing their ethical performance and how this will affect the finance

    function.(PDF 2MB). London: CIMA/Institute of Business Ethics.

    Available from: http://digbig.com/4ykrt

    [Accessed 12 March 2009]

    CIMA Fraud and Risk Working Group. (2002). Risk management: a guide to good

    practice. Oxford:Elsevier. (CIMA Research Series)

    http://www.acfe.org/http://www.cimaglobal.com/fraudhttp://www.kroll.com/about/library/fraudhttp://www.pwc.com/crimesurveyhttp://digbig.com/4ykrthttp://digbig.com/4ykrthttp://www.pwc.com/crimesurveyhttp://www.kroll.com/about/library/fraudhttp://www.cimaglobal.com/fraudhttp://www.acfe.org/
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    Articles

    CIMA members can obtain articles on this topic from the Business Source

    Corporate database, which can be found in the CIMA Professional Development

    section of the CIMA website. www.cimaglobal.com/mycima

    [Accessed 12 March 2009]

    Burrowes, A. and Sipple, S. Corporate accountability and continuing fraud.

    Chartered Accountants Journal, November 2007, Volume 86, Issue 10, pp 70-71

    Christie, J. Credit crunch sparks corporate fraud fear. Accountancy Age,

    02/07/2008, p. 2

    Dilger, K. Kroll: Corporate fraud is almost 100-per cent preventable.

    Manufacturing Business Technology, January 2008, Volume 26, Issue 1, p. 26

    Finn, J. and Cafferty, D. Defence mechanism. CIMA Financial Management,

    September 2002, pp 26-27

    Goldmann, P. Corporate fraud is here to stay. Internal Auditor, December 2006,

    Volume 63, Issue 6, p. 96

    Hawser, A. Corporate fraud on the rise despite SOX. Global Finance, July/August

    2007, Volume 21, Issue 7, p. 4

    Langnan, C. and Weibin, L. Corporate governance and fraud: evidence from

    China. Corporate Ownership and Control, Spring 2007, Volume 4, Issue 3,

    pp 139-145

    Books

    Coenen, T. (2008). Essentials of corporate fraud. Hoboken, NJ: Wiley; Chichester:

    John Wiley [distributor]. (Essentials Series)

    Iyer, N. and Samociuk, M. (2006). Fraud and corruption: prevention anddetection. Aldershot: Gower

    Luijerink, D. (2008). Corporate and financial fraud. Kingston upon Thames:

    Croner CCH

    Pickett, K.H. Spencer. (2007). Corporate fraud: a managers journey. Hoboken,

    NJ: Wiley; Chichester; John Wiley [distributor]

    Ramage, S. (2006). A comparative analysis of corporate fraud. New York:

    iUniverse

    Ramage, S. (2006). Fraud: the company law background. New York: iUniverse

    http://www.cimaglobal.com/mycimahttp://www.cimaglobal.com/mycima
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    Webley, S. (2003). Developing a code of business ethics: a guide to best practice

    including the IBE illustrative Code of Business Ethics. London: Institute of BusinessEthics

    Wells, J.T. (2007). Corporate fraud handbook: prevention and detection. 2nd ed.

    Chichester: Wiley

    Guides and Surveys

    Economic crime: people, culture and controls the 4th biennial global economic

    crime survey 2007. (2007). PricewaterhouseCoopers.

    Available from: www.pwc.com/crimesurvey

    [Accessed 12 March 2009]

    Fraud Advisory Panel. (2006-2007). Ninth annual review 2006-2007: ethical

    behaviour is the best defence against fraud.

    Available from: http://digbig.com/4ykrw

    [Accessed 12 March 2009]

    Education, Events & Training Working Group,Fraud Advisory Panel. (February2006). Fighting fraud: a guide for SMEs. (PDF 68Kb). 2nd ed.

    Available from: http://digbig.com/4ykrx

    [Accessed 12 March 2009]

    Education, Events & Training Working Group. Fraud Advisory Panel. (February

    2006). Sample Fraud Policy Statements. (PDF 552Kb).

    Available from: http://digbig.com/4ykry

    [Accessed 12 March 2009]

    Institute of Internal Auditors, Association of Certified Public Acountants,

    Association of Certified Fraud Examiners. (2008). Managing the business risk of

    fraud: a practical guide

    Profile of a fraudster survey 2007. (2007). London: KPMG

    Available from: http://digbig.com/4yksa

    [Accessed 12 March 2009]

    Managing the risk of fraud. May 2003. London: HM Treasury

    Professional Accountants in Business Committee. (2006). Defining and

    developing an effective code of conduct. New York: IFAC

    http://www.pwc.com/crimesurveyhttp://digbig.com/4ykrwhttp://digbig.com/4ykrxhttp://digbig.com/4ykryhttp://digbig.com/4yksahttp://digbig.com/4yksahttp://digbig.com/4ykryhttp://digbig.com/4ykrxhttp://digbig.com/4ykrwhttp://www.pwc.com/crimesurvey
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    Websites

    Fraud Advisory Panel

    Registered charity which raises awareness of the human, social and economic

    damage caused by fraud. Helps individuals and organisations to develop

    preventative strategies.

    Available from: www.fraudadvisorypanel.org

    [Accessed 12 March 2009]

    National Fraud Strategic Authority

    Part of the Office of the Attorney General formed to address the challenges of

    fraud. Available from: http://digbig.com/4yksb[Accessed 12 March 2009]

    Public Concern at Work (PCaW)

    Independent authority on public interest whistleblowing.

    Available from: www.pcaw.co.uk

    [Accessed 12 March 2009]

    Serious Fraud Office

    Government department and part of the UK criminal justice system. It exists to

    pursue and prosecute those who commit serious and complex fraud.

    Available from:www.sfo.gov.uk

    [Accessed 12 March 2009]

    Serious Organised Crime Agency (SOCA)

    SOCA is sponsored by, but operationally independent from, the Home Office. It

    exists to enforce the law and to reduce harm caused to people and communities

    by serious organised crime.

    Available from: www.soca.gov.uk

    [Accessed 12 March 2009]

    World Bank Anti-Corruption Resource Center

    Available from: http://digbig.com/4yksc

    [Accessed 12 March 2009]

    http://www.fraudadvisorypanel.org/http://digbig.com/4yksbhttp://www.pcaw.co.uk/http://www.sfo.gov.uk/http://www.soca.gov.uk/http://digbig.com/4ykschttp://digbig.com/4ykschttp://www.soca.gov.uk/http://www.sfo.gov.uk/http://www.pcaw.co.uk/http://digbig.com/4yksbhttp://www.fraudadvisorypanel.org/
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    No responsibility for loss occasioned to any person acting or refraining fromaction as a result of any material in this publication can be accepted by theauthors or the publishers.

    All rights reserved. No part of this publication may be reproduced, storedin a retrieval system, or transmitted, in any form or by any means methodor device, electronic (whether now or hereafter known or developed),mechanical, photocopying, recorded or otherwise, without the priorpermission of the publishers.

    Copyright CIMA 2009

    First published in 2009 by:

    The Chartered Institute ofManagement Accountants26 Chapter StreetLondon SW1P 4NPUnited Kingdom