Profiling a Fraudster Here is a simple checklist that you can use to help identify fraud in your business. There are separate questions for different areas of your business depending on the department. Categories Include: • Employee • Management • Payroll • Accounts Receivable • Accounts Payable • Revenue • Procurement • Corporate • Other Employee Red Flags Unexplained employee lifestyle changes - living above their expected means Significant personal debt and credit problems Refusal to take annual or sick leave Behavioural changes - i.e. drugs, alcohol, gambling or fear of losing the job. High employee turnover, especially in those areas which are more vulnerable to fraud Lack of segregation of duties in the vulnerable area Complained about inadequate pay Unusually close association with vendor/customer Wheeler-dealer attitude Divorce/family problems Past employment-related problems o o o o o o o o o o o Management Red Flags Reluctance to provide information to auditors Managers engage in frequent disputes with auditors Management decisions are dominated by an individual or small group Managers display significant disrespect for regulatory bodies There is a weak internal control environment Accounting personnel are lax or inexperienced in their duties Decentralisation without adequate monitoring Excessive number of checking accounts Frequent changes in banking accounts Frequent changes in external auditors Company assets sold under market value Significant downsizing in a healthy market Continuous rollover of loans Excessive number of year end transactions High employee turnover rate Unexpected overdrafts or declines in cash balances Refusal by company or division to use serial numbered documents (receipts) Compensation program that is out of proportion Any financial transaction that doesn’t make sense - either common or business Service contracts result in no product Photocopied or missing documents Borrowing money from co-workers Creditors or collectors appearing at the workplace Gambling beyond the ability to stand the loss Easily annoyed at reasonable questioning & providing unreasonable responses to questions Refusing vacations or promotions for fear of detection Bragging about significant new purchases Carrying unusually large sums of money Rewriting records under the guise of neatness in presentation o o o o o o o o o o o o o o o o o o o o o o o o o o o o o Payroll Red Flags Inconsistent overtime hours for a cost center Overtime charged during a slack period Overtime charged for employees who normally would not have overtime wages Budget variations for payroll by cost center Employees with few or no payroll deductions A terminated employee who is still on the payroll list Employees on the payroll register before their start date or after their termination date o o o o o o o Note: Red flags that show up in payroll are generally worth a thorough investigation. Although payroll is usually an automated function, it is a vulnerable area, especially if collusion is involved. Accounts Receivable Red Flags Customer complaints Unexplained change in uncollectable accounts and aging Customer statements are not sent or are not sent timely Timing differences between collections and posting to accounts Staff not taking vacations Credits to a customer account followed by an identical debit Changes to customer accounts or new customers with unusual names/addresses Shipping to customers without proper credit approval Unusual “ship to” address is different from company address Inventory discrepancies Unusual collection agency activity (low recovery/high utilisation) Changes in sales (increase or decrease) not consistent with changes in cash receipts Unusual number of reverse transactions/voids Unusual number of pricing overrides Unusual number of credit overrides Credit level increases not consistent with sales volume Abnormal number of expense items, supplies, or reimbursement to the employee Large number of write-offs of accounts o o o o o o o o o o o o o o o o o o Accounts Payable Red Flags Actual costs over budget Original documents are not available for inspection Missing documentation Changes to vendor master file are not approved Payment not properly authorized or typical controls are overridden Vendor names appear to be unusual Vendors with multiple addresses or addresses that change frequently Common name, address, bank account number between vendor & employee master files Vendor address is a P. O. box Unexplained fluctuations in payments to vendors Changes in employee habits and lifestyle Lack of physical security protocol over check stock and signature stamps or plates Cancelled checks cannot be located Bank reconciliations with long-term outstanding checks Vendors not being paid timely or being paid sooner than other vendors Check sequences, anomalies, or gaps o o o o o o o o o o o o o o o o Revenue Red Flags Sales trends out of line with industry Sales exactly meet budget or analysts’ expectations Bonuses tied to sales Excessive returns after period end Side agreements identified in confirmations Recurring negative cash flows from operations Sales on tax return differs from sales reported in financial statements Missing documentation Commissions not paid to sales rep. when otherwise would be expected Unusual increase in the number of days sales in receivables Customer invoice shows extended payment terms or unusual return allowances Credit limits exceeded o o o o o o o o o o o o Procurement Red Flags Frequency of purchases and amount of vendor spend sharply increase (particularly with new vendors) Vendor used consistently in the past suddenly is no longer used Vague descriptions provided on invoices (e.g., materials purchased or services rendered) Unusual number of purchases below approval threshold level – purchases broken into smaller pieces One payment applies discount, another pays full invoice (invoices amounts with 2% difference, etc.) Volume of purchases not supported by a rational need Purchasing Cards - Unusually high spend activity at the end of the year Purchasing Cards - Weekend purchases and holiday purchases Purchasing Cards - Purchases from vendors not in the normal course of business (jewellery stores, casinos, furniture stores, gentlemen’s clubs, etc.) Excessive sole source justifications Unusual restrictions or time limits to exclude or reduce competition Prequalification procedures that restrict robust competition Vague bid specifications Specifications developed by a vendor who then submits a bid One party represents a number of potential bidders Unknown or unusual vendors Acceptance of late or incomplete bids Permitting changes after receipt of bids Bids submitted in editable electronic formats Selecting vendors with records of poor performance history. Qualified vendors stop submitting bids Vendor addresses matching employee addresses Purchases that bypass the normal procedures Vendors without physical addresses Charges without shipping documents Lack of physical security over assets/inventory High volume of purchases from new vendors o o o o o o o o o o o o o o o o o o o o o o o o o o o Corporate Corruption Red Flags Operating in countries or industries notorious for fraud or corruption Expenses over budget Excessive consulting fees Unauthorised payments for goods and services Complaints from suppliers regarding bidding or relationships Fluctuations in vendor volumes o o o o o o Other Common Types of Fraud Falsifying timesheets for a higher amount of pay Pilfering stamps Stealing of any kind (e.g., cash, petty cash, supplies, equipment, tools, data, records, etc.) Forgery (not just check forgery, e.g. forging management signatures on purchase orders) Lapping collections on customers’ accounts Check Kiting Pocketing payments on customers’ accounts, issuing receipts on self-designed receipt books Not depositing all cash receipts (deposits are not “intact”) Creating fictitious employees and collecting the paychecks (impersonation) Paying for personal expenses with business funds Increasing vendor invoices through collusion Billing for services not rendered and collecting the cash Seizing checks payable to vendors Recording fictitious transactions on the books to cover up theft Conflicts of Interest Nepotism Favoritism If you suspect fraudulent activity in your business; why not take the red flag test? It might help you determine if fraudulent activity is possibly occurring at your business. Alternatively, why not join us on the 3rd March 2016 for the ‘Prevention of Fraud’ e-workshop, which will discuss the next steps to take once you have identified fraudulent activity. However, if in the meantime you have any other questions or wish to discuss any concerns you have, please feel free to contact Bernard Whebell at bwhebell@ulton.net or by phoning (07) 4197 6300. Source: Red Flags of Fraud, DiNapoli TP, https://www.osc.state.ny.us/localgov/pubs/red_flags_fraud.pdf Red Flags of Fraud, Chianese J, Haimoff I, McSwain J, Wiseman M, Deloitte, 2012, http://www.afci.org/sites/default/files/ document-library/redflagsoffraud-final.pdf Disclaimer: This checklist is a general and indicative resource only. All material published on in this document is of a general nature only and is not intended to be a substitute for or relied upon as specific professional advice. Accordingly, the information in these materials is not intended to constitute accounting, tax, legal, investment, consulting, or other professional advice or services. The information is not intended to be relied upon as the sole basis for any decision which may affect you or your business. Before making any decision or taking any action that might affect your personal finances or business, you should consult a qualified professional adviser. No responsibility for loss or damage suffered by any person acting on or refraining from action as a result of any material within this document is accepted. Although Ulton have taken reasonable steps to ensure all material in this document is complete and accurate, no guarantees are given.