Last week, we mentioned the importance of internal controls when trying to prevent and detect fraud. Now, let’s spend a few minutes talking about some specific internal control concepts. Many of you have probably heard the term, “internal controls”, and it may have a variety meanings to you. Very basically, an internal control is an activity or process to make sure that what you want to get accomplished, gets done. For example: as a manager you probably have a goal to make sure that each of your employees is paid for the time they work – and ONLY for the time worked. Can you think of some activities that make sure you accomplish that goal? First, you might use manual time-cards. With manual time cards, each employee can record when they arrive at work, and when they leave. This may work for your organization. But if your employees are not trustworthy, they might write down that they got to work earlier then they actually did, or write down a late departure time, and leave early. Another activity, with ELECTRONIC data collection, would be for the employees to “swipe” their ID when arriving and leaving. The computer would record the actual times. This is more likely to capture accurate times. A third activity you might consider is to use a camera to record all activities at the workplace. This might be “OVERCONTROLING” for most organizations, but it is a way to determine who is at work, and if they are working! It may also be expensive for the person preparing payroll to have to review every tape every day and record everyone at work. From these examples,I want you to understand that for most goals, there are a wide range of activities, with varying degrees of costs and appeal. You have to find the one that BEST fits your goal. In addition to general business goals, we also need to think about some goals that are important from the fraud perspective. One of these is the goal to reduce the risk that the organization will be exposed to a harm, danger or loss – this includes loss caused by fraud and other intentional and unintentional acts. Additionally we need to make sure the organization is in compliance with laws and regulations. Frequently, we have “GOAL OVERLAP”, for example, where the potential loss is monetary AND it breaks a tax law. Next, let’s talk about categories of internal controls. First, we have preventative controls – they PREVENT problems from occurring. To do this, we need to anticipate a problem and put a procedure in place to prevent the problem from happening. For example, an employee is entering the hours he works into an automated timesheet program. He works 30 hours, but by mistake, he enters, 300 hours. Knowing that errors in data entry may happen, we have a “PROGRAM EDIT CHECK” control that does not allow any entries greater than 168 hours for a week (24 hours X 7 days). The edit check PREVENTS the error from being introduced into the system. The second category of is DETECTIVE CONTROLS. These controls do not PREVENT a problem, but rather identify problems that have occurred. Our control example here is to compare the sales information from a cash register program to the cash in the register’s cash drawer. This will help to determine if cash is missing. Obviously this did not prevent the loss, but it helped identify that a loss occurred. The final category is CORRECTIVE controls. These resolve a problem that occurred. Corrective controls do not PREVENT or DETECT a problem. One example of a corrective control is a fidelity bond, which could be described as employee embezzlement insurance. It does not prevent, nor detect theft by an employee, but it does reimburse for the loss after the fraud. There are many, many opportunities to incorporate internal controls into an organization. Let’s spend a few minutes looking at some that you may have been exposed to. First consider some controls that may be used to prevent and detect fraud. Cameras at cashier stations in retail stores are there to DETECT problems. BUT, just knowing that someone is viewing the area may PREVENT a fraud by the cashier. Passwords on computer programs keep people from accessing certain routines. This can prevent frauds such as inappropriate adjustments to accounts. Approval processes, such as for cash payments, may prevent an accounts payable clerk from making fraudulent payments to relatives. It should be noted that not all controls are fraud related. There are also many controls to make sure that company operations work smoothly. Examples of these include having preset, automatic inventory reorder points. This control prevents stock-outs, and customer dissatisfaction because the item they want is not available. Another operations control is the automatic calculation of employee payroll. Automatic calculations typically reduce errors in every process where they are used. This control may also PREVENT intentional calculation errors by a fraudster. No matter what organizational objective you are considering, if possible, PREVENTATIVE controls are preferred. It is much better to PREVENT a fraud than to deal with the issues of detecting or correcting the problem. Fraud prevention and detection is directly related to internal control from a business perspective. To meet the requirements of being a good steward of the resources of an organization, management is expected to prevent fraud when possible, and disclose it when prevention efforts did not succeed. Internal controls are a major part of the framework to support this responsibility of management. In additional to the business perspective, in the USA and many other countries, management has a legal responsibility related to fraud and internal controls. The USA’s Foreign Corrupt Practices Act of 1977makes management legally responsible for an organization’s internal control system. The Sarbanes Oxley Act’s impact on corporate financial reporting not only addresses corporate fraud, but also includes penalties should it occur. The importance of preventative controls cannot be over-emphasized when studying fraud. Control failures can result in not only business failure, but also personal financial penalties, and criminal prosecution for individuals. The primary preventative control in any financial system is separation or segregation of duties. There are four functions that we are concerned about when processing of a business event: authorizing, executing, recording, and safeguarding. Separation of duties is the assignment of these four functions related to events to different people. When duties are properly separated, no individual job or role includes the capability to commit fraud without collusion. To help understand the concept, let’s look at the following example. An employee in the marketing department needs a new lamp. Consider the activity of purchasing the lamp. The authorization of the lamp purchase would likely be the responsibility of the supervisor of the department where the lamp is needed. The execution of the purchase, buying the lamp, is performed by a purchasing agent in the company’s purchasing department. The transaction will be recorded by an accounting clerk. And finally, the lamp will be safeguarded by the original requesting employee in the marketing department. When the controls are not segregated, fraud may result, The worst-case example would be all functions performed by a single individual. In that instance, the individual could approve and execute the purchase, record the transaction, and possess the item. For example, if funds were available, the individual could approve, purchase and take possession of a personal automobile, while recording it as business equipment -- and the fraud might go undiscovered. With duties segregated, it is unlikely such a fraud could be performed, and less likely it would go undiscovered. As we have discussed, while ALL controls are important, but separation of duties is likely the most important of controls. In this section, we learned that there are certain individuals that are actively seeking opportunities to commit fraud. These individuals don’t steal because they need money, they steal because they are greedy. When we are designing anti-fraud programs and controls, we must be careful to keep these predators in mind. The Triangle of Fraud Action is a valuable tool in understanding how certain conditions can lead opportunities to commit fraud. We also learned how important internal controls are to fraud prevention. One of the most effective controls is segregation of duties. Protecting an organization’s assets through good internal controls protects against both the accidental fraudster and the predator. You can find more information on this week’s topics on the West Virginia University and Association of Certified Fraud Examiner websites. Thank you for your participation today. We hope this segment has helped you with your understanding of Fraud Accounting and Forensic Examination.