Article at Are Your Employees Committing Fraud?

There’s a good chance fraud may be occurring under your nose. How to get better at preventing it from happening on your watch.

Tracy L. Coenen – CFO Magazine

Internal fraud is a huge risk to companies. Experts estimate that on average it costs companies 3% to 5% of revenue each year. Especially when profit margins are thin, internal fraud can literally put some companies out of business.

But executives are prone to underestimating the amount of fraud that exists within their company. They want to believe that their internal controls are better, their employees are more honest, and their ability to stop fraud is more effective than that of executives at other companies.

Identifying Red Flags of Fraud

Would you recognize the clues that your client has been ripped off by one of its employees? Or would management conduct business as usual, blindly trusting their employees?

Companies make the mistake of not actively searching for fraud. They tend to trust their employees and trust the procedures in place to safeguard company assets.

It may be good business to trust employees and empower them to make real contributions to the growth of the company. However, it is not wise to turn a blind eye to signs that a trusted employee may be stealing.

Bribery and Corruption: Difficult Frauds to Find

When fraud happens within an organization’s accounting system, there is often a paper (or digital) trail left behind. It’s unavoidable, as there is a record of something related to the fraud, whether it is a legitimate invoice that was later adjusted, an account balance that was changed, or a fake employee who was added to the payroll system.

Frauds involving bribery and corruption are different. They happen almost completely outside the accounting system, so they often don’t leave a paper trail. Management instead must rely on tips or other vague clues to the existence of such a fraud scheme.

Common Sense in Internal Investigations

Last week Mike Volkov had a great post on his blog about using common sense in your internal investigations. Mike is an FCPA expert, and the guy you want to go to if your company is the target of a government investigation or inquiry.

What makes Mike the better choice than the other attorneys who sell their services for internal investigations and compliance issues (and there are a lot of them!) is his level of experience. He was a federal prosecutor for a long time, and has deep experience with government prosecutions. You don’t want someone who just knows how to push paper. You need someone who knows the government process and how parts of the investigation are going to happen, what chance there may be for settlement, and how the government investigators are going to react to certain pieces of information (beyond the laws, and into the reality).

Article at Taking on Fraud Probes Without Interfering

 How CFOs can assist independent investigators and not mess up the integrity of the results.

By Tracy Coenen, Contributing Editor at

With the government’s increased focus on ferreting out corporate fraud, companies face a higher risk of gigantic defense costs, negative media reports, and substantial civil or criminal penalties. Cases involving bribery and corruption under the Foreign Corrupt Practices Act, for example, are costing companies their reputations and their profits.

It takes only one credible whistleblower with access to enough documentation to make a compelling case to a government agency to get the ball rolling. The saving grace, however, can be an aggressive compliance program, complete with thorough internal investigations of tips and red flags, plus swift and certain remediation.

How to Stop Employees From Stealing

It might be hard to believe, but each and every day companies are losing money because they not only give employees opportunities to steal, they encourage it.

How? By not providing adequate oversight. A clerk, for example, sees that an error in an account wasn’t caught by anyone. A purchasing manager notices that no one is watching over his vendor relationships, and won’t know it if he establishes a fake account. Employees are not stupid. They know when they are being monitored and when their work is being checked. They know when they are working in an environment ripe for fraud.

Steal and Conceal: MATC Procurement Director Fraud

Today the Journal Sentinel ran a story about the fraud perpetrated on Milwaukee Area Technical College (and taxpayers) by Kristin Semits, the procurement director. Seimits is accused of stealing more than $259,000j over a 7 year period using her P-card (purchasing card – like a company credit card).

The report produced by Titus, the company that investigated the fraud, can be seen here. A graph on page 2 shows how the theft started out small (a few thousand dollars each year) and built up to $86,000 in 2011 alone. MATC’s budget is $260 million, so it’s easy to see how a theft of $50,000 or $80,000 in one year might have flown under the radar.

Ways to Help Prevent Corporate Fraud

Executives have the means to commit and cover up the largest frauds.

They have access to the information and computer systems, they have power over all employees and they have access to the money. The finance function is riddled with fraud risks and the company’s executives are in the best position to take advantage of those risks.

Because of the risk of losing large sums of money to fraud by executives, companies must ensure owners and boards of directors are actively involved in creating and maintaining an environment that is not conducive to fraud. This involves active oversight of daily operations, continuous monitoring of potential red flags of fraud and swift action when fraud is discovered.

Article at Investigating a Compliance Failure

How to determine the right mix of expertise for a fraud investigation.

By Tracy Coenen, Contributor to

It’s every CFO’s worst nightmare: despite your best efforts, your company’s compliance program has failed. There are credible reports of fraud and corruption inside the company, and an initial analysis of the situation confirms a problem. An internal investigation is necessary to determine the magnitude of the fraud, the parties involved, and the company’s financial and reputational exposure under government regulations.

How should you proceed? These investigations are often high stakes, so it is important to do things the right way from the start. In-house counsel should be involved in any situation involving allegations or evidence of fraud. Once executives have sufficient reason to believe the allegations are credible, they should involve outside counsel as well.

Got Fraud? Don’t Try a Do-It-Yourself Investigation

When a business owner or executive encounters proof of a fraud-in-progress, a natural reaction is often to immediately begin investigating. After all, someone has to get to the bottom of the situation. Yet that’s not usually the best way to go.

Just like on television, we need to give owners and executives a warning that they should not try this at home. It’s tempting to dig right into a potential fraud and start to unravel what’s happened. While the immediate gathering of information is helpful to a fraud investigator, when an inexperienced person tries to go further and actually investigate, bad things can happen.

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