Fraud Risks and Controls
Role of InTERNAL AUDIT
Chapter 8
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Fraud Risks and Controls
Chapter 8
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Chapter 8: Fraud Risks and Controls
Learning objectives
Understand the prevalence of illegal acts and fraud in today’s world.
Compare and contrast various illegal acts/fraud definitions.
Describe the fraud triangle and its three elements, and “dark triad” personalities.
Define the types of fraud and fraud risk factors.
Define governance, risk management, and control in the context of fraud.
Describe fraud prevention, deterrence, and detection techniques.
Understand the behavioral aspects of fraudsters.
Describe internal auditors’ compliance and fraud-related responsibilities related to protecting the organization from regulatory violations.
Understand evolving responsibilities of the internal audit function, including the involvement of forensic accountants and fraud examination specialists.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Chapter 8: Fraud Risks and Controls
Standards related to Fraud
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Current environment: The perfect Storm for fraud
Internal
Controls
Layoffs unemployment and unease continue
Personal retirement plans and market levels remain low
Opportunity to
Commit Fraud
Anti-bribery regulatory focus increased globally
Budgets are decreasing. Companies and organizations are doing more with less.
Companies are decentralized which has an immediate effect on internal controls
Stressed and disaffected employees may have greater ability to rationalize improper actions
Pressure
Opportunity
Rationalization
Large government contracts
Employees are working in countries with perception of bribery
Lack of infrastructure and controls in many foreign countries
Internal and External
Pressure
(slide reproduced with permission from EY—Fraud Investigation and Dispute Services practice)
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Why discuss fraud?
Increasing Incidence of Fraud
Indicative of Corporate Governance Failure
Destruction of Economic Value
Legal Liability (Class-Actions)
Reputational Damage
Adverse Impact on Employee Morale and Attrition
Suggestive of Non-Compliance with Laws & Regulations
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Types of fraud
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Fraud Types
Corruption
Assets Misappropriation
Fraudulent Statement
Conflict of Interest
Bribery
Illegal Gratuities
Economic Extortion
Cash
Inventory and other
Larceny
Skimming
Financial
Non-Financial
Chapter 8: Fraud Risks and Controls
Fraud types:
frequency vs impact
High
FREQUENCY
Low
Low
IMPACT
($)
Financial
Reporting
Fraud
IP
Infringement
Data Security Breaches:
ID Theft
Bribery and
Kickbacks
(FCPA)
Asset
Misappropriation
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Why and how fraud happens
Behavioral and Integrity Risks
Collusion, including with Third Parties
Conflicts of Interest
Unethical Conduct
Insider Trading and Self-Dealing
Operational/Financial Risks
Pressure to meet Earnings Targets
Poor Internal Controls
Lax Data/Information Security Structure
Compensation Tied to Earnings/Performance
Economic Downturn Creates Pressure
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Fraud indicia
Subtle and nondescript clues include:
Numbers do not add up
Revenues outside core business
Important documents missing
Journal entries without support
Aggressive accounting techniques
Management obsessed with revenue and profits
Domineering management, executives
Control overrides
Collusion is usually involved
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Fraud definition
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Additional Fraud
definitions
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Fraud requirements
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Risk of fraud – responsible parties
Board and Management
(SOX 301 requires Audit Committees to set up appropriate whistleblower policy/mechanisms)
Internal and external auditors
All employees
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Fraud classification
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
The fraud triangle
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Root causes of fraud
Supply of motivated offenders
Availability of suitable targets
Absence of capable guardians
Means, motivation and opportunity
Excuses/Rationalization
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Dark triad personality factors
Three types of dark triad personalities:
Narcissists
Psychopaths
Machiavellians
Common personality traits:
Little or no conscience
Low empathy
Anti-social personality disorder (DSM-5, APA, 2013)
Disagreeableness
Can be charming, but manipulative and scheming
Source: Paulhus & Williams, 2002
Epstein & Ramamoorti (2016) in their article in THE CPA JOURNAL
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Warning signs
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
COSO Internal control integrated framework principle #8
In the COSO internal control integrated framework (2013), principle #8 is one of the risk assessment component principles.
Principle #8 states:
“The organization considers the potential for fraud in Assessing risks to the achievement of objectives.”
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
The value proposition
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Fraudulent financial reporting
Financial Statement Fraud:
Misrepresentation
Omission of information
Intentional misapplication of accounting principles
Misclassifications
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
corruption
Extortion
Bribes/Kickbacks
Conflicts of interest
Illegal gratuities
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Fraud and internal audit
What fraud risks are being monitored?
Can management override controls?
Risk of management override (recent events)
Do the internal auditors have the required expertise to address risk of fraud?
Internal audit’s definition of the fraud detection process
Organization status of the audit function
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Use of data analysis to detect fraud
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Fraud related standards
1220.A1 - Internal auditors must exercise due professional care by considering the:
Extent of work needed to achieve the engagement's objectives.
Relative complexity, materiality, or significance of matters to which assurance procedures are applied.
Adequacy and effectiveness of governance, risk management, and control processes.
Probability of significant errors, fraud, or noncompliance.
Cost of assurance in relation to potential benefits.
2210.A2 - Internal auditors must consider the probability of significant errors, fraud, noncompliance, and other exposures when developing the engagement objectives.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Role of internal auditors
Raise fraud awareness, fraud deterence
Whistleblower procedures
Standard 2130: Nature of Work: Control
Promote ethics and values
Performance management and accountability
Communications about risk and controls
Coordination responsibilities – internal auditors need help to detect and prevent fraud from occurring
Shadowing forensic investigations
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Fraud detection
Professional skepticism, professional judgment, and industry experience
Looking at fraud indicia and evidence
Incomplete information
Forensic data analytics, use of monitoring and visualization tools
Determining whether it is an internal control breakdown or management override of controls
No controls can provide absolute assurance
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Questions for
internal auditors
What fraud risks are being monitored?
Can management override controls?
What is the risk of management override (recent events)?
Do the internal auditors have the required expertise to address risk of fraud?
What is the internal audit function’s definition of the fraud detection process?
What is the organizational status of the audit function?
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Chapter 8: Fraud Risks and Controls
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
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Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.
Internal Auditing: Assurance & Advisory Services, 4th Edition © 2017 by the Internal Audit Foundation.