FLORIDA DEPARTMENT OF FINANCIAL
SERVICES
DIVISION OF ACCOUNTING AND AUDITING
Presented to Purchasing Card Administrators
February 17, 2012
MISSION STATEMENT
• The mission of the Office of Fiscal Integrity is to detect
and investigate the misappropriation or misuse of state
assets in a manner that safeguards the interests of the
State of Florida and its taxpayers.
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INVESTIGATIVE AUTHORITY
17.04 To settle accounts of those entrusted with property, funds or moneys
of this state; and those indebted to the state
• OFI may conduct investigations
• Shall refer violations for state or federal prosecution
17.0401 Confidentiality of information relating to financial investigations
• Information relative to investigations is confidential until the investigation is
completed
17.05
Subpoenas; sworn statements; enforcement proceedings
• OFI may issue subpoenas, administer oaths, and examine witnesses
20.121 Department Of Financial Services
• OFI shall function as a Criminal Justice Agency
• May conduct investigations within or outside this state
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ORIGIN OF CASES
• Internal Referrals From Within DFS
• Inspectors General
• FBI, FDLE, and Local Law Enforcement
• Other Governmental Agencies
• Consumer Complaints
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FOLLOWING THE MONEY
• Financial Data Will Prove If a Crime Has Been
Committed
• Subpoenaed Bank Statements (with Signature
Cards) Will Reveal Financial Transaction History:
o Other Bank Accounts/Credit Cards Being Used
o All Transactions
• Spreadsheets Are Created to Analyze:
o Timeline of Account Activity
o Who Spent the Funds, and When and Where
They Were Spent
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FOLLOWING THE MONEY
• Questionable Items Are Researched and Flagged
• Examples of Questionable Transactions:
o Checks Written Payable to Cash
o Payments to Subsidiaries or Possible Shell or
Ghost Companies
• Final Outcome – Financial Analysis Helps Explain
the Crime and is Matched With Analyst's Diagrams
and Charts for Ease of Understanding the Case
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TYPES OF FRAUDS INVESTIGATED
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Contract and Grant Fraud
Unclaimed Property Fraud
Electronic Fund Transfer (EFT) Fraud
State Travel / Purchasing Card and Payroll Fraud
Ghost Contractors / Ghost Employees
Theft of State Property
Fraud Through Counterfeit Warrants / Fraudulent
Debits to State Treasury Accounts
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TYPICAL CRIMINAL CHARGES IN OFI CASES
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Mail Fraud / Wire Fraud
Aggravated Identity Theft
Scheme to Defraud
Aggravated White-Collar Crime
Racketeering
Grand Theft
Money Laundering
Official Misconduct
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P-Card Investigations
• Suspected fraudulent transactions are referred by
the Statewide P-card Office directly to OFI
• OFI interviews witnesses and uses the CFO’s
subpoena authority to obtain necessary documents
and records from vendors and financial institutions
• Many cases involve receipts that are “lost”, followed
by a fraudulent replacement receipt being created
• Many P-card frauds occur because of a lack of
oversight
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P-Card Investigations
• Agencies need to do a thorough job of monitoring
• Approvers frequently fail to review the transaction
• Many times, approvers fail to require adequate
descriptions of the items being purchased
• Be wary of generic descriptions (like office supplies)
or no description for items being purchased
• Check a vendor’s website if there is a question about
legitimacy
• Ask yourself whether the vendor name and the
description make sense
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P-Card Investigations
• The administrator should be running queries and
looking for patterns of possible abuse/misuse
• The approvers need to be knowledgeable AND
monitor that the agency needs what is being
purchased & confirm agency is getting what was
ordered.
• If OFI or any other law enforcement agency
investigates, the administrator and approvers will be
interviewed to determine how the scheme was
perpetrated.
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CONTACT:
Steve Horn
steven.horn@myfloridacfo.com
850-413-5553
200 East Gaines Street
Tallahassee, FL 32399