1
Office of Internal Audit
ACUA 2013 Annual Conference
Presented by:
Lori Tesch – CPA, CFE, CFF, CGMADirector, Forensic Audits
Fraud Risk Assessment
1September 2013
• Understand what a Forensic/Fraud Risk Assessment is and it’s key elements
• Discuss the development and design of an effective assessment
• Examine tools for executing the assessment
• Report results
• Incorporate results into the Audit Plan and sustain the program
Objectives
2September 2013
Definitions
3
Fraud Risk
• Organization’s vulnerability to overcoming the three elements of fraud
• Internal and external sources
September 2013
2
Definitions
4
Fraud Risk Assessment
Process to identify where fraud may occur and who may be committing it
September 2013
Identifying Fraud
5September 2013
Identify the Fraudster
6September 2013
3
Key Elements
7
Identify inherent fraud risk
Assess likelihood and significance
Respond to reasonably likely and significant inherent and residual fraud risks
September 2013
What makes a good Fraud Risk Assessment?
8
Understand where it falls within an Effective Anti-Fraud Program
Code of Ethics
Fraud Prevention
Policies
Communication & Training
Controls Monitoring
Fraud Response
Plan
Fraud Risk Assessment
September 2013
9
What makes a good Fraud Risk Assessment?
Necessary Elements
CollaborationThe Right Sponsor
Independence & Objectivity
Working Knowledge of
BusinessTrust
Access to All People
Think the Unthinkable
Sustainability
September 2013
4
Development and Design
10
Package it right
One size does NOT fit all
Keep it simple
September 2013
Development and Design
11
Prepare the Organization
Team Technique Agreement Educate
September 2013
Team
12
Accounting & Finance
Internal Audit Nonfinancial/ Operations
Risk Management
External Consultants
General Counsel
Ethics or Compliance
Business Leaders
September 2013
5
Technique
13
Survey
Interview
Facilitated Session
September 2013
Agreement and Education
14
Obtain sponsor’s agreement
Educate the employees
Promote the process
September 2013
Assessing Possible Risks
15
Likelihood
Significance
People/department
September 2013
6
Online Resources
16
http://www.acfe.com/fraud-prevention-checkup.aspx
http://www.aicpa.org/InterestAreas/ForensicAndValuation/Resources/FraudPreventionDetectionResponse/Pages/Managing%20the%20Bu
siness%20Risk%20of%20Fraud.aspx
http://www.cgma.org/Resources/Reports/Pages/fraud-risk-management.aspx
Fraud Prevention Checkup - ACFE
Managing the Business Risk of Fraud
CGMA Fraud Risk Management
September 2013
Tools
17
Survey Software
Questionnaire
Self-Assessment
September 2013
Report Results
18
Report objective – not subjective - results
KISS
Focus on what really matters
Identify clear and measurable actions
September 2013
8
Reporting
22September 2013
Reporting
23September 2013
Incorporate with Audit Process
24
Combine results
Focus on high priority risks
Design test procedures
September 2013
9
Sustain the Program
25
Begin a dialogue across the organization
Continue to look for fraud in high risk areas
Hold responsible parties accountable
Monitor key controls
September 2013
Final Thoughts
26
1. There is no standard
2. Just like a fraud investigation, no two are alike
3. Ongoing, continuous process
September 2013
Final Thoughts
27September 2013
10
Final Thoughts
28September 2013
Final Thoughts
29September 2013
Auditor Humor
5 – In God we trust, everybody else gets audited
30
4 – What do you call an Auditor without an opinion?
3 – We’re not happy until you’re not happy
2 – If your mother tells you she loves you… check it out
1 – There were Thirteen Commandments… before the auditor questioned three of them
I don’t know, I’ve never heard of one
September 2013
Page 1 of 2
FRAUD RISK ASSESSMENT FORM
Identified Fraud risks and
Schemes1
Likelihood2 Significance
3
People
and/or
Department4
Existing Anti-
fraud
Controls5
Controls
Effectiveness
Assessment6
Residual
Risks7
Fraud Risk
Response8
FINANCIAL REPORTING:
MISAPPROPRIATION OF
ASSETS:
CORRUPTION:
Page 2 of 2
1. Identified Fraud Risks and Schemes: This column should include a full list of the potential fraud risks and schemes that may face the
organization. This list will be different for different organizations and should be formed by discussions with employees and management and
brainstorming sessions.
2. Likelihood of Occurrence: To design an efficient fraud risk management program, it is important to assess the likelihood of the identified fraud
risks so that the organization establishes proper anti-fraud controls for the risks that are deemed most likely. For purposes of the assessment, it
should be adequate to evaluate the likelihood of risks as remote, reasonably possible, and probable.
3. Significance to the Organization: Quantitative and qualitative factors should be considered when assessing the significance of fraud risks to an
organization. For example, certain fraud risks may only pose an immaterial direct financial risk to the organization, but could greatly impact its
reputation, and therefore, would be deemed to be a more significant risk to the organization. For purposes of the assessment, it should be
adequate to evaluate the significance of risks as immaterial, significant, and material.
4. People and/or Department Subject to the Risk: As fraud risks are identified and assessed, it is important to evaluate which people inside and
outside the organization are subject to the risk. This knowledge will assist the organization in tailoring its fraud risk response, including
establishing appropriate segregation of duties, proper review and approval chains of authority, and proactive fraud auditing procedures.
5. Existing Anti-fraud Internal Controls: Map pre-existing controls to the relevant fraud risks identified. Note that this occurs after fraud risks are
identified and assessed for likelihood and significance. By progressing in this order, this framework intends for the organization to assess
identified fraud risks on an inherent basis, without consideration of internal controls.
6. Assessment of Internal Controls Effectiveness: The organization should have a process in place to evaluate whether the identified controls are
operating effectively and mitigating fraud risks as intended. Organizations should consider and review what monitoring procedures would be
appropriate to implement to gain assurance that their internal control structure is operating as intended.
7. Residual Risks: After consideration of the internal control structure, it may be determined that certain fraud risks may not be mitigated
adequately due to several factors, including (a) properly designed controls are not in place to address certain fraud risks or (b) controls
identified are not operating effectively. These residual risks should be evaluated by the organization in the development of the fraud risk
response.
8. Fraud Risk Response: Residual risks should be evaluated by the organization and fraud risk responses should to address such remaining risk.
The fraud risk response could be implementing additional controls and/or designing proactive fraud auditing techniques.
ACFE Fraud Risk Assessment Instructions
The Fraud Risk Assessment consists of 15 modules, each containing a series of questions designed to help
organizations zoom in on areas of risk. The fraud professional and the client or employer should begin the
risk assessment process by working together to answer the questions in each module. It is important that
the client or employer select people within the organization who have extensive knowledge of company
operations, such as managers and internal auditors, to work with the fraud professional. Upon completion
of all of the questions, the fraud professional should review the results of the assessment with the client or
employer in order to:
Identify the potential inherent fraud risks.
Assess the likelihood and significance of occurrence of the identified fraud risks.
Evaluate which people and departments are most likely to commit fraud and identify the
methods they are likely to use.
Identify and map existing preventive and detective controls to the relevant fraud risks.
Evaluate whether the identified controls are operating effectively and efficiently.
Identify and evaluate residual fraud risks resulting from ineffective or nonexistent controls.
Respond to residual fraud risks.
The Fraud Risk Assessment may reveal certain residual fraud risks that have not been adequately
mitigated due to lack of, or non-compliance with, appropriate preventive and detective controls. The fraud
professional should work with the client to develop mitigation strategies for any residual risks with an
unacceptably high likelihood or significance of occurrence. Responses should be evaluated in terms of
their costs versus benefits and in light of the organization's level of risk tolerance.
Be aware, however, that this assessment only provides a snapshot of a particular point in time. The
dynamic nature of organizations requires routine monitoring and updating of their financial risk
assessment processes in order for them to remain effective.
These questions are provided as a guide only. The user is free to modify the questions as appropriate to
match the size and structure of the organization. Additional information on fraud risk assessment may be
obtained from:
ACFE's Fraud Resources
Fraud Examiners Manual
Corporate Fraud Handbook, Third Edition, by Joseph T. Wells
The ACFE would like to thank Larry Cook, CFE, for his invaluable contribution to the Fraud Risk
Assessment. The Fraud Risk Assessment was originally developed by Mr. Cook, and we thank him for
allowing us to build upon his foundation and share his assessment process with our members.
Copyright Notice: The modules and the questions are the property of the Association of Certified Fraud
Examiners. The ACFE grants its members the right to use these modules and questions for their own use,
or for the use of their clients or employers. Neither, these modules, nor any part thereof, may be sold in
whole or in part unless as part of consulting or fraud examination services to a client or employer.
Modules
1 - Employee Assessment
2 - Management/Key Employee Assessment
3 - Physical Controls
4 - Skimming Schemes
5 - Cash Larceny Scheme
6 - Check Tampering Schemes
7 - Cash Register Schemes
8 - Purchasing and Billing Schemes
9 - Payroll Schemes
10 - Expense Schemes
11 - Theft of Inventory and Equipment
12 - Theft of Proprietary Information
13 - Corruption
14 - Conflicts of Interest
15 - Fraudulent Financial Reports
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Page 1
Sample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk Assessment
In an effort to better assess the organization's fraud risks, we have developed this Fraud Risk Assessment. The survey should take no more than 20 minutes to complete. Please note that the survey must be fully completed once started. You cannot exit and restart the survey. Please complete all sections no later than Friday, August 3, 2013. Should you have any questions, please contact XXXXXXXXX. Thank you in advance for your cooperation. Name and title of support person
INTRODUCTION
Page 2
Sample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk Assessment
1. How would you rate the overall ethical behavior of the department in the following areas:
2. Are measures taken to reduce the risk of fraud in your area concerning:
3. Are there instances in your area where employees have close friends or immediate relatives reporting to them or they are working in the same S/C/D?
ETHICS
*Excellent Above Average Average Below Average Poor
Commitment to accurate financial reporting
nmlkj nmlkj nmlkj nmlkj nmlkj
Disclosing wrongdoing nmlkj nmlkj nmlkj nmlkj nmlkj
Proper review and approval nmlkj nmlkj nmlkj nmlkj nmlkj
Complying with policies and procedures
nmlkj nmlkj nmlkj nmlkj nmlkj
Doing what is right nmlkj nmlkj nmlkj nmlkj nmlkj
*Strongly Agree Agree Disagree Strongly Disagree
Reviews nmlkj nmlkj nmlkj nmlkj
Reconciliations nmlkj nmlkj nmlkj nmlkj
Segregation of duties nmlkj nmlkj nmlkj nmlkj
Safeguarding physical assets and sensitive data
nmlkj nmlkj nmlkj nmlkj
*
Additional Comments:
Additional Comments:
Yes
nmlkj No
nmlkj N/A
nmlkj
If yes, has management been made aware of the situation?
Page 3
Sample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk Assessment
4. Are employees aware of how to report occurrences of suspected fraud or suspicious activity?
5. Please identify the top five frauds that could occur in your area.
6. Of the following types of fraud, which ones could occur in your area (check all that apply).
7. Can you identify potential “red flags” which are indicators of possible fraud or fraudulent behavior?
FRAUD AWARENESS
*
*1.
2.
3.
4.
5.
*
*
Yes
nmlkj
No
nmlkj
Unsure
nmlkj
Additional Comments:
Conflict of interest
gfedc
Financial statement manipulation
gfedc
Theft of assets
gfedc
Falsification or alteration of documents
gfedc
Time theft
gfedc
Inappropriate Pcard transactions
gfedc
Inappropriate or unapproved travel
gfedc
Unauthorized use or abuse of signature authority
gfedc
Unauthorized use of University assets
gfedc
Manipulation of information on University systems
gfedc
Other
gfedc
Yes
nmlkj No
nmlkj
If yes, please list some examples below:
55
66
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Sample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk Assessment
8. Do you currently have employees in positions that, as the result of budget cuts and/or other cutbacks, may have an issue with segregation of duties?
9. How effective are current processes with ensuring segregation of duties in the following areas:
SEGREGATION OF DUTIES
*
*Excellent Above Average Average Below Average Poor N/A
Credit Card Processing nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Cash Activities nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Bank Deposits nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Account Reconciliations nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Bank Reconciliations nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Posting of Cash Receipts nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Cash Disbursements nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Petty Cash Accounts nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Frequency of Process Review
nmlkj nmlkj nmlkj nmlkj nmlkj nmlkj
Yes
nmlkj
No
nmlkj
Additional Comments:
Additional Comments:
Page 5
Sample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk AssessmentSample Fraud Risk Assessment
10. How effective is the process for reviewing and/or approving key documents for discrepancies, unusual activity or misuse in the areas of:
11. How effective is management with providing feedback related to:
12. A background check was done on all new employees within the past three years.
13. How important is it to monitor employee leave time to prevent time theft or ensure employees are reporting time accurately as it relates to:
PROCESS REVIEW
*Excellent Above Average Average Below Average Poor
Financial transactions nmlkj nmlkj nmlkj nmlkj nmlkj
Operational activities nmlkj nmlkj nmlkj nmlkj nmlkj
Academic activities nmlkj nmlkj nmlkj nmlkj nmlkj
Grant funds compliance nmlkj nmlkj nmlkj nmlkj nmlkj
*Excellent Above Average Average Below Average Poor
Employee performance nmlkj nmlkj nmlkj nmlkj nmlkj
Departmental performance nmlkj nmlkj nmlkj nmlkj nmlkj
General feedback nmlkj nmlkj nmlkj nmlkj nmlkj
*
*Critical Very Important Important Not Important
Sick Leave nmlkj nmlkj nmlkj nmlkj
Special Needs Time nmlkj nmlkj nmlkj nmlkj
Vacation nmlkj nmlkj nmlkj nmlkj
Holidays nmlkj nmlkj nmlkj nmlkj
Personal Business/Any Purpose
nmlkj nmlkj nmlkj nmlkj
Please list any issues with specific areas/transactions below:
55
66
Additional Comments:
Yes
nmlkj No
nmlkj N/A
nmlkj
Additional Comments:
Additional Comments:
Page 2
2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment
1. Are you aware of any weaknesses in internal controls that would provide an opportunity for someone to steal or commit fraud?
2. If someone in your department/area decided to steal or commit fraud, how could they do it and get away with it?
3. Are you aware of any behaviors that may expose your department/area or the University to regulatory violations, fines or penalties?
4. Do you have any knowledge of fraud in your department/area or the University?
FRAUD AWARENESS
*
*
55
66
*
*
Yes
nmlkj No
nmlkj Unsure
nmlkj
If yes, please list some examples below:
55
66
Yes
gfedc
No
gfedc
Unsure
gfedc
If yes, please list any concerns you may have:
Yes
nmlkj No
nmlkj
If yes, please explain.
Page 3
2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment
5. Are you aware of any employee that exhibits behavior that is unethical or inappropriate for the workplace?
6. Are you aware of any conficts of interest or nepotism in your department/area or the University?
7. Are you aware of anyone who does any of the following during work time (check all that apply):
ETHICS
*
*
*
Yes
gfedc
No
gfedc
Unsure
gfedc
If yes or unsure, please describe the behavior(s) and why you are concerned.
Yes
gfedc
No
gfedc
If yes, please explain.
Runs a personal business
gfedc
Spends a great deal of time surfing the internet
gfedc
Receives gifts from outside businesses or individuals
gfedc
Disappears for large blocks of time
gfedc
Additional comments:
Page 4
2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment
8. Do you know of anyone who exhibits any of the following behaviors (check all that apply):*
Easily annoyed at reasonable questions
gfedc
Viewing, transmitting or downloading inappropriate data
gfedc
Never, or rarely, takes vacation
gfedc
Sexual harrassment, sexual jokes and innuendo
gfedc
Excessive gambling
gfedc
Affairs, inside or outside the office
gfedc
Bullying
gfedc
Provides unreasonable responses to questions
gfedc
Intimidation
gfedc
Appears to be living beyond their means
gfedc
Retaliation
gfedc
Overprotective of data or information
gfedc
Vulgarity, profanity, and abusive language directed at people
gfedc
General harassment
gfedc
Additional Comments:
Page 5
2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment
9. If you had knowledge that an unethical/fraudulent activity was occurring within your department/area or the University, what would you do?
10. What are ways that an individual can report fraud or abuse to the University? (check all that apply).
11. The reporting of fraud or abuse to the University can truly be completely anonymous. Do you agree or disagree with this statement?
REPORTING
*
55
66
*
*
Supervisor or other upper level management
gfedc
Hotline
gfedc
Office of Internal Audit
gfedc
Human Resources
gfedc
Labor Relations
gfedc
Anonymous tips form
gfedc
Office of Equal Opportunity
gfedc
Public Safety
gfedc
Agree
nmlkj
Disagree
nmlkj
If you disagree, why?
Page 6
2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment
12. How effective is the process for reviewing and/or approving key documents for discrepancies, unusual activity or misuse in the areas of:
13. Do you have knowledge of anyone abusing their position to circumvent or bypass departmental processes or procedures?
PROCESS REVIEW
*Excellent Average Poor N/A Unsure
Financial transactions nmlkj nmlkj nmlkj nmlkj nmlkj
Operational activities nmlkj nmlkj nmlkj nmlkj nmlkj
Academic activities nmlkj nmlkj nmlkj nmlkj nmlkj
Grant fund compliance nmlkj nmlkj nmlkj nmlkj nmlkj
*
Please list any issues with specific areas/transactions below:
Yes
nmlkj
No
nmlkj
Unsure
nmlkj
If yes or unsure, please explain.
Page 7
2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment2014 Fraud Risk Assessment
14. Do you currently have employees in positions that, as the result of budget cuts and/or other cutbacks, may have an issue with segregation of duties?
15. Is there anything else you would like us to know?
SEGREGATION OF DUTIES
*
55
66
Yes
gfedc
No
gfedc
Additional comments: