In our work in high risk industries, we routinely uncover fraud and asset misappropriations. While it may seem counterintuitive, with the US and global economy currently at a standstill due to COVID-19 shelter at home directives, organizations should be on high alert for occupational fraud during this time. The Fraud Triangle provides a framework for explaining why this is.

Formulated in 1953 by criminologist Donald Cressey, the Fraud Triangle theorizes that fraud occurs when the fraudster feels financial pressure, they are presented an opportunity, and/or the person can rationalize the theft.

With record numbers of Americans filing for unemployment and organizations operating with skeleton crews, the circumstances are ripe for fraud to take place.

A “Perfect Storm” of Conditions

Today, with organizations shut down to outside visitors (including, in some cases, outside auditors) as well as many employees, we are seeing a virtual petri dish for fraud. Two corners of the Fraud Triangle – opportunity and rationalization – are getting bent pretty hard. The third corner, incentive, in the form of extreme pressure, is bent even further. People have less supervision, more opportunity, and way more financial pressure.

So while you’re dealing with this pandemic and the resulting disruption, now more than ever is the time to be vigilant.

Opportunity

The coronavirus pandemic has driven unprecedented change in the workplace. Many employees are either laid off, have taken a pay cut, and/or are working remotely. Those who remain, whether at the workplace or from home, may be working with less supervision than before. In fact, we are seeing many instances where key risk management procedures like dual controls have been weakened or suspended entirely. For example, instead of having two or more employees independently evaluate and compare financial records, now only one employee may be responsible. Or, that supervisory signature normally required on certain transactions? It’s no longer practical given our remote locations, so we’ll just “do it this way” in the interim.

Sound familiar? The problem in these scenarios is that one small transgression that goes unnoticed has a way of snowballing into full-blown fraud.

Rationalization

When opportunity and incentive exist, people are better able to rationalize their fraudulent behavior. That couldn’t be more true than during this pandemic.  “I have to do this to provide for my family. I’ll pay it back later. My employer deserves it for laying me off.” These are some of the underlying rationalizations that turn a fraudster’s underlying thoughts into an actionable theft.

Incentive/Pressure

Financial difficulties are at the top of the list in terms of the pressures that can motivate people to commit acts of fraud. At no other time in modern history have so many people been under such financial strain as they are today.

At the highest of levels of unemployment following the 2008 financial crisis, there were 15.3 million jobless Americans. By the third week of April 2020, 26.5 million workers had filed jobless claims as a result of the coronavirus. An estimated 33 million people are currently unemployed, representing nearly 21 percent of the workforce and the highest unemployment level since 1934. Many who remain employed have agreed to accept pay cuts, work reduced hours, or take unpaid furloughs.

While the $2 trillion stimulus bill, Coronavirus Aid, Relief, and Economic Security Act (CARES), provided some short-term relief, it is likely not enough to stem the extreme financial worry being felt by many who don’t know how they’ll pay next month’s mortgage or cover their car insurance premium.

The pressure is extreme.

The Takeaway? Stay Vigilant

It may be tempting for organizations to be complacent when the world seems at a standstill, but the time to be diligent is now. Businesses should be on “high alert” and taking measures to ensure they’re keeping their operations secure. That includes double checking that access to IT systems and software has been blocked for furloughed employees or that virtual private networks (VPNs) have been created for remote workers. Internal controls should also remain in place, even if they have to be modified temporarily. For example, regularly scheduled phone calls or video conferences send the message that you’re still monitoring employees’ activities. Finally, if you haven’t already done so, it’s a good time to do an updated risk assessment for the entire organization. Asking your team where new vulnerabilities might exist, whether internal controls are still functioning as intended, and what gaps have been created are all part of mitigating the risk potential associated with the Fraud Triangle.

If you’d like help conducting any of these assessments, please reach out to us.

As the ACFE’s 2019 Fraud Awareness Week comes to a close, it’s a good time to create your plan for fraud prevention in the year ahead. These seven fraud prevention strategies, drawn from the 2018 Report to the Nations by the Association of Certified Fraud Examiners (ACFE), will go a long way in fortifying your organization against the conditions that can facilitate occupational fraud at the workplace.

1. Tone from the Top

A robust anti-fraud program that is embraced from the top of the organization to the bottom creates a culture of honesty and fairness. A solid program starts with a code of ethics, signed by all employees, and continues with anti-fraud policies, training, internal controls, and periodic employee surveys which help gauge the extent to which employees believe management acts with honesty and integrity. Many organizations also include fraud prevention objectives as a part of their employee performance goals.

2. Anti-fraud Training

Practical, hands-on training that educates employees on how to detect fraud, what to look for, how internal controls work, and how to report fraud are instrumental to any anti-fraud program. For instance, make employees aware of the research that demonstrates how fraudsters attempt to conceal their activities, such as through the creation of fraudulent documents, altered accounting transactions, or fraudulent journal entries.

3. Clear Reporting Methods

Fifty-three percent of fraud cases in the ACFE’s 2018 Report to the Nations were reported by employees, and the research also revealed that hotlines were effective in encouraging such reporting. So, whether you create a dedicated fraud hotline, or rely on emails, web forms or in-person reporting, do be sure that all employees know their options for reporting suspected fraud.

4. Proactive Detection

Commit to having anti-fraud efforts remain at the forefront of your organization. This means sending out regular messages to the team, conducting surprise audits, performing regular account reconciliation, and implementing continuous monitoring software to detect anomalies. Organizations with proactive detection methods like these caught fraudulent activities months earlier than those with passive detection. For example, frauds detected actively by IT controls tended to last five months and cause a median loss of $39,000, compared to schemes detected passively (e.g., through notification from law enforcement), which tended to last two years and cause a median loss of almost $1,000,000. If you’re not sure where to start, begin with a fraud risk assessment to identify and mitigate any vulnerabilities you find.

5. A Strong Auditing Team & Internal Controls

The one-two punch of a strong auditing team and solid internal controls will mean the difference between sleeping well at night or potentially having massive losses. Your auditing team should have adequate resources and authority to operate effectively and without undue influence from senior management. In addition, the ACFE’s 2018 study found that weaknesses in internal controls were responsible for nearly 50 percent of all fraud cases! Anti-fraud controls are paramount to preventing or detecting fraud. Here are a few of the most important controls:

• External audits of financial statements
• Internal audit department
• Management certification of financial statements
• External audit of internal controls over financial reporting
• Management review
• Reporting hotline
• Code of ethics and anti-fraud policy
• Proper separation of duties
• Job rotations

6. Diligent Hiring Practices

Background checks should always be a part of any hiring practice, and attention to criminal history, credit reports, and reference checks are particularly important in the context of preventing fraud. However, since 96 percent of fraud perpetrators in the AFCE study had no prior fraud conviction, the next step is understanding the behavioral red flags associated with fraudsters. Eighty-five percent of perpetrators displayed at least one of these red flags: living beyond means; financial difficulties; unusually close relationship with vendor/customer; control issues, unwillingness to share duties; divorce/family problems; and a “wheeler-dealer” attitude.

7. Employee Support Programs

Employee support programs are valuable for a variety of reasons, but in the context of occupational fraud, they can help address some of the underlying issues that present themselves as “red flag behaviors.” An open-door policy that welcomes employees to speak freely about financial, family or addiction pressures can help alleviate them before they become acute or lead to destructive behaviors.

The most cost-effective way to limit fraud losses is, of course, to prevent fraud from occurring. With these strategies in-hand, your organization will be off to a strong start. If you’d like an experienced team to help create an anti-fraud program or investigate suspected fraud, please reach out at any time.

As part of the annual fraud awareness week, we wanted to bring you a quick summary of the principles of fraud risk management. These points are based on an extensive review titled Managing the Business Risk of Fraud: A Practical Guide.

As the Practical Guide emphasizes, “An organization should strive for a structured as opposed to a haphazard approach.” The Guide is a good place to start developing a fraud prevention and detection program as part of your overall risk management efforts (or structuring a review of an existing program). But as always, diving into the details of organizing and implementing a program like this requires significant effort. Skipping steps or making assumptions about risks and mitigation practices without systematic assessment will often lead to gaps or weaknesses in the plan. … Continue reading