The ACFE’s 5 Big Fraud Tips You Should Act on Now

By Lowers & Associates,

The ACFE’s 5 Big Fraud Tips You Should Act on Now

As part of the 2019 International Fraud Awareness Week, the Association of Certified Fraud Examiners (ACFE) distributes information and training to help anti-fraud professionals reduce the incidence of fraud and white-collar crime. A recent ACFE publication, 5 Fraud Tips Every Business Leader Should Act On, spells out five ways organizations can work to prevent and minimize fraud in the workplace. We’ve paired their recommendations with the research-based actions you can take to achieve these aims.

1. Be Proactive

A code of ethics for management and employees sets the tone that your organization is committed to conducting business honestly and fairly. Fortify your commitment with internal controls around areas of the business that are vulnerable to fraud.

In its 2018 Report to the Nations, the ACFE studied nearly 3,000 incidents of fraud across 125 nations. Here are the top 10 most common anti-fraud controls they found among the organizations in the study:

  1. Code of conduct: 80%
  2. External audit of financial statements: 80%
  3. Internal audit department: 73%
  4. Management certification of financial statements: 72%
  5. External audit of internal controls over financial reporting: 67%
  6. Management review: 66%
  7. Hotline: 63%
  8. Independent audit committee: 61%
  9. Employee support programs: 54%
  10. Anti-fraud policy: 54%

The study found that weaknesses in internal controls were responsible for nearly 50 percent of all fraud cases.

2. Establish Hiring Procedures

Background checks will continue to be one of the best practices any workplace can implement, yet surprisingly, a full 96 percent of fraud perpetrators had no prior fraud conviction, according to the AFCE’s 2018 report. Therefore, understanding the behavioral red flags displayed by fraud perpetrators can help organizations detect fraud and mitigate losses. The AFCE found that 85 percent of fraudsters displayed at least one of the six red flags listed below and 50 percent of them exhibited multiple red flags.

Six Red Flags of Fraud:

  1. Living beyond means
  2. Financial difficulties
  3. An unusually close relationship with vendor/customer
  4. Control issues, unwillingness to share duties
  5. Divorce/family problems
  6. “Wheeler-dealer” attitude

3. Train Employees in Fraud Prevention

Looking for signs of fraud isn’t top of mind for most employees, but having a code of ethics and internal controls create a strong workplace culture that’s attuned to the possibility of fraudulent activity. Employers can take this awareness a step further by educating employees on how to recognize fraud in their day-to-day lives.

Here are the top eight concealment strategies used by fraudsters:

  1. Created fraudulent documents: 55%
  2. Altered physical documents: 48%
  3. Created fraudulent transactions in the accounting system: 42%
  4. Altered transactions in the accounting system: 34%
  5. Altered electronic documents or files: 31%
  6. Destroyed physical documents: 30%
  7. Created fraudulent electronic documents or files: 29%
  8. Created fraudulent journal entries: 27%

4. Implement a Fraud Hotline

Now that employees know some of the signs to look for, employers should also provide a clear means for reporting suspected fraud. The top three ways that fraud is detected are through tips (40%), internal audits (15%), and management review (13%).

Employees are responsible for reporting 53 percent of occupational fraud cases with the remaining coming from outside parties, such as customers, vendors, or shareholders.

Having a fraud hotline has proved to be instrumental in detecting fraud. In fact, 46 percent of cases detected by tips in the AFCE’s study had hotlines versus 30 percent coming from tips where no hotline existed.

5. Increase the Perception of Detection

Keeping the risk of fraud both top of mind and at the forefront of your organizational policies and practices is key to preventing, recognizing, and mitigating its impacts. In addition to having employees sign a code of conduct, make sure you’re regularly communicating to staff about anti-fraud policies. Remind them of the methods available to report suspicions of misconduct and the potential consequences (including termination and prosecution) of fraudulent behavior.

Though 42 percent of the organizations in the 2018 Report to the Nation offered hotlines to report fraud tips, other mechanisms are also readily available. They include:

  • Email: 26%
  • Webform/online: 23%
  • Mailed letter: 16%
  • Other: 9%
  • Fax: 1%

To learn more about helping your organization combat fraud, stay tuned here for the rest of our our 2019 Fraud Week Series. If you need help formulating your fraud prevention program, request a meeting with a risk management expert at Lowers & Associates.

The College Admissions Fraud Triangle [Infographic]

By Lowers & Associates,

Can the Fraud Triangle Help Us Understand How the Higher Ed Admissions Bribery Scandal Happened?

 

High-profile stories of fraud in corporate America are commonplace, but the details surrounding Operation Varsity Blues – the biggest college admissions bribery scandal of its kind to be prosecuted by the US Justice Department – reveal how fraud is an equal opportunity threat.

Pressures, opportunities, and rationalizations of all sorts combined to create a situation for coaches, parents, admissions personnel, and test administrators to deceive the admissions system. In total, $25 million was reportedly paid in bribes and 50 defendants were named in the case.

Criminologist Donald Cressey’s Fraud Triangle offers a framework for understanding the factors that lead people to commit fraud. In the infographic below, we use the fraud triangle as a model for understanding how the college admissions scandal happened.

Colleges and universities are not immune to fraud, and it’s imperative that administrators have protections in place to safeguard their reputations and resources. The infographic outlines a few key prevention measures.

Check out the full infographic here:

college admissions bribery scandal fraud

  Category: Fraud Awareness
  Comments: Comments Off on The College Admissions Fraud Triangle [Infographic]

College Admissions Scandal: Are We too Quick to Blame the Institutions?

By Lowers & Associates,

College Admissions Scandal

The college admissions scandal has caused quite a stir in the media over the last few weeks. The stories have varied, the fraudsters are unique to each situation, but in the end it’s the same old tale; the rich use money and power to influence the morally weak and advance those closest to them to undeserved positions of grandeur. The key in this case is that schools across the US are being brought down to the same level as the criminals and fraudsters that perpetrated the crime in the first place.

Yale University, founded in 1701, has graduated five U.S. Presidents, and prides itself on its motto, ‘Lux et veritas’ or in English “Light and Truth.” However, a Yale soccer coach was able to pull off a scholarship-based fraud in which a student was accepted without merit. Is this Yale’s fault? Perhaps in part, but I would like to blame it on a much larger, systematic fraud scheme that can easily be discovered and rectified with appropriate planning and execution.

Other schools were involved in Title IX fraud, SAT proctoring schemes, and direct fraud from payoffs or bribes. Each school left a back door open for a fraudster to come barging through and in the end, will be sued for millions of dollars. These lawsuits, some frivolous and others merited, will need to be tried and tested. What can your institution do to avoid situations such as this?

In our experience, fraud is perpetrated in larger educational institutions and corporations when the controls breakdown or are antiquated. There are simple ways to enhance controls and become a much more aware organization.

Some important tips that we feel will mature your organizational fraud prevention controls are below.

Enhance Internal Controls

When looking at sophisticated organizations such as a university, one might think that internal controls are deployed across the enterprise. However, this was not the case in athletics, where some of the fraud was perpetrated. Entities should implement enterprise wide systems of internal “dual control” whereby a minimum of two people are involved in the decision-making process/function. The purpose of dual control is to deter fraud, provide a properly documented audit trail, maintain quality assurance, and prevent extortion. This dual control process creates a system of “checks and balances” in which a single person (authorized person(s) within a department) does not have the sole authority to decide without the verification and approval conducted by a secondary and separate department (authorized person(s) within that department). This helps to mitigate the potential for collusion. These obvious changes can deter fraudulent actions and lead to much more effective fraud deterrence. Internal control is vital when trying to ensure that protocols and regulations are carried out according to policy.

Make your organizations aware, and force reporting

Create a fraud risk policy with demonstrative cases that establish consequences for perpetrators. It sounds simple, but this is a critical step in setting up the consequential deterrence that is sometimes needed to stop amateur fraudsters. If individuals in the organization are aware that management is looking for certain types of fraud, they might think twice before acting.

An additional aspect of organizational awareness is to implement reporting. In any instance where there is a violation of policies or an employee feels there is a violation by someone else, encourage reporting. Anonymous reporting/tip lines have historically been the number one means by which occupational fraud is discovered. These reports and tips need to be vetted and followed up to ensure there are consequences. As the fraud risk policy matures, there should be a noticeable difference that will help secure organizations from becoming victims of fraud.

Know Your People

Fraudsters tend to demonstrate behavioral traits that can indicate they have committed or are candidates to commit fraud. Comprehensive background screening can be the first step in ensuring that there are no concerns prior to offering employment. However, initial background checks are not enough.

Employers and leaders need to listen to what employees are saying. If there are divisional leaders, or in this case coaches and deans, that are deeply respected or far too entrenched in the internal control environment, they can create circumstances that could lead to fraud. For instance, USC, who saw their senior athletic director implicated, was victim to the college admissions scandal when the water polo coach recruited a student who didn’t even play water polo! Had USC screened each scholarship athlete and ensured there were controls and reporting in place, this could have been avoided. Now, USC is at the mercy of the judicial system.

In conclusion, it is amazing that these events transpired in today’s digital environment, but it clearly demonstrates a lack of understanding when it comes to the willingness of fraudsters to attain what they want. Legacies are now tarnished over the acts of bad actors and their accomplices.

Lowers Risk Group prides itself in delivering solutions to our clients that rectify these types of situations.

Contact us to learn more.

  Category: Risk Management
  Comments: Comments Off on College Admissions Scandal: Are We too Quick to Blame the Institutions?

The Red Flags of Fraud You May Not Know

By Lowers & Associates,

Fraud Red Flags

It would be really good to know who in your organization is most at risk of perpetrating a fraud. You could then take steps—counseling, reviewing controls, rotating jobs—to protect against that risk.

Theoretically, the Fraud Triangle does a good job of stipulating who might be a fraud risk. It says people are more likely to commit an occupational fraud when they have motivation, opportunity, and a rationale to excuse their crime. The rationale is an individual factor which organizations cannot address in advance, but there can be indicators based on motivation and opportunity.

The 2018 Report to the Nations on Occupational Fraud and Abuse contains some concrete information that is consistent with this theory. In research for the Report, the Association of Certified Fraud Examiners (ACFE) identified 17 behavioral “red flag” traits that might be associated with a perpetrator of fraud. These are primarily indicators of motivation or pressure that may cause a potential fraudster to flip into active fraud.

85% of the fraudsters in the 2,690 cases ACFE reviewed had at least one of the red flags, and 50% had more than one. They are at least somewhat predictive.

The most common red flags have to do with financial difficulties (motivation, pressure). Since 2008 when the first edition of the Report was published, the six top red flags, in order, have consistently included:

  • Living beyond one’s means
  • Financial difficulties
  • Unusually close association with a vendor or customer
  • Control issues, unwilling to share duties
  • Divorce/family issues
  • “Wheeler-dealer” attitude

Much is written about these common behavioral red flags of fraud, but there are other red flags organizations should be aware of when it comes to predicting and preventing fraud. So-called human resources-related red flags and non-fraud-related misconduct can offer valuable insight to those responsible for anti-fraud programs.

Human Resources-Related Red Flags

According to the ACFE’s 2018 report, 39% of fraudsters had experienced some form of HR-related red flags prior to or during the time of their frauds. The most common of these red flags were negative performance evaluations, and fear of job loss.

Non-Fraud-Related Misconduct by Perpetrators

According to the ACFE report, 45% of fraud offenders had committed some form of non-fraud workplace violation, which could potentially indicate a link between occupational fraud and other forms of workplace misconduct. The most common non-fraud violation was bullying or intimidation, which was observed in 21% of all cases.

To anticipate occupational fraud, the organization has to be well acquainted with its members at all levels of authority. Regular or routine evaluations (background checks, interviews, work reviews) would help to identify individuals at risk, and help them avoid failure. A fraud prevented saves the organization from damage to people, brands, and profits.

  Category: Fraud Awareness
  Comments: Comments Off on The Red Flags of Fraud You May Not Know

Who’s Putting Your Organization at Risk of Fraud?

By Lowers & Associates,

who's the fraudster?

Many times, occupational fraud is committed by an employee or third-party partner who is experienced and trusted. Which of your employees—or leaders—is likely to flip over to the dark side? And why?

The 2018 Report to the Nations on Occupational Fraud and Abuse provides valuable information on these questions. This tenth edition of the Report, published by the Association of Certified Fraud Examiners (ACFE), is based on data from almost 2,700 cases of occupational fraud submitted by Certified Fraud Examiners (CFEs) worldwide. While not a random sample, the selected cases aggregate a huge amount of descriptive information that managers can use to evaluate their own organizations.

Here are a couple of key takeaways about the question of “Who?” in the fraud equation:

  • Anyone and everyone is a potential fraudster, but organizations must be aware that those in long-tenured, high authority positions can present a greater risk. Fraud prevention programs have to recognize this fact and plan extensive monitoring and controls to mitigate the risk.
  • Identifying a potential fraudster can be difficult. Background checks can help, but some previous fraudsters may not have bad information in the public record. The fraud triangle of “red flag” factors on issues of motivation and opportunity may help to identify risks.

Longer-tenured, higher-authority = greater risk.

One hard lesson from the Report—which is consistent over all 10 editions—is that owners and executives are a big risk in terms of fraud. They commit only one-fifth of the total frauds, but the median loss when they do go off the rails is $850,000, more than 5 times greater than managers ($150,000 median loss) and 17 times greater than regular employees ($50,000 median loss). One reason people with greater authority cause more damaging frauds is that they are able to evade detection longer: owner/executives hide for 24 months; ordinary employees only 12.

Owners and executives have the most access to the organization’s assets, and also have authority over some of the controls and processes established to deter fraud. They are also more likely to collude with others, and their frauds are more likely to be discovered by an external auditor or law enforcement. This argues for putting a risk management plan in place before fraud occurs, and to make sure the plan includes provisions for monitoring executive behavior as well as extensive controls on regular operations.

47% of occupational frauds reported were perpetrated by people with six or more years tenure with the organization. These long-term employees also stole far more money. In aggregate, the long-term employees caused much higher total losses than those who were with the organization less than six years. The length of tenure increases loss in all types of jobs, but the higher the authority the greater the loss. Both authority and tenure operate to increase the losses.

Follow the money.

By department, the data tends to say, ‘follow the money’. The two biggest threats come from upper management and accounting (with the high authority individuals by far the bigger threat). The single most common type of fraud is corruption, which strikes hardest in executive/upper management, and purchasing. Both of these departments are likely to be linked to both internal and external networks, which may foster systematic (often collusive) corruption.

Occupational fraud is estimated to have cost over $7 billion dollars in 2017. The warning to organizations is clear. There is no absolute certainty about the likelihood of any given employee committing a fraud. The organization’s best response is systematic fraud prevention aimed at all levels and functions of the organization.

  Category: Occupational Fraud
  Comments: Comments Off on Who’s Putting Your Organization at Risk of Fraud?