RED FLAGS OF OCCUPATIONAL FRAUD Caroline Burnell, CFE, CGFM CAROLINE BURNELL Fraud Investigator 25 years experience in auditing and fraud investigations SOURCES: State of New York, Office of State Comptroller, Red Flags for Fraud http://www.osc.state.ny.us/localgov/pu bs/red_flags_fraud.pdf Accessed January 8, 2014. Wells, Joseph T; Corporate Fraud Handbook Prevention and Detection, 3rd Edition. 2011 cmburnell@comcast.net RED FLAGS Defined cmburnell@comcast.net RED FLAGS A set of circumstances that are unusual in nature or vary from the normal activity. cmburnell@comcast.net RED FLAGS Do not ignore a red flag! Studies of fraud cases consistently show that red flags were present, but either weren’t recognized or were recognized but not acted upon by anyone. cmburnell@comcast.net RED FLAGS The investigation should be done by a responsible person who is unlikely to be committing the fraud if one is occurring. Sometimes an error is just an error. cmburnell@comcast.net FRAUD And Its Perpetrators cmburnell@comcast.net Required Conditions: KEY POINTS cmburnell@comcast.net ANYONE within the organization can commit fraud. cmburnell@comcast.net Highly trusted employees are NOT always honest. cmburnell@comcast.net PERPETRATORS Past Employment-Related Problems Unusually Close Association with Vendor/Customer Wheeler-Dealer Attitude Irritability, Suspiciousness or Defensiveness Control Issues, Unwillingness to Share Duties Refusal to Take Vacations Complained About Inadequate Pay Complained About Lack of Authority PERPETRATORS Excessive Pressure from Within Organization Excessive Family/Peer Pressure for Success Financial Difficulties Addiction Problems Divorce/Family Problems Past Legal Problems Source: ACFE 2012 Report to the Nations cmburnell@comcast.net WAR STORY cmburnell@comcast.net WAR STORY RED FLAGS cmburnell@comcast.net Legal Pressure Past Theft Financial Pressure Similar looking invoices Sequentially numbered invoices Same address / telephone number Executive Directive submitted an invoice from one of his companies for payment of an item that was never delivered. Checks payable to companies endorsed by Executive Director and/or his family No email or web address cmburnell@comcast.net cmburnell@comcast.net SHELL COMPANIES Shell companies are fictitious entities created for the sole purpose of committing fraud by shielding identities of the perpetrator and/or hiding money. cmburnell@comcast.net SHELL COMPANIES No phone number No e-mail or web address No physical address No company logo No contact information No federal identification number cmburnell@comcast.net FALSE INVOICES Running unsanctioned invoices through the accounts payable system. May be done with vendor collusion. cmburnell@comcast.net FALSE INVOICES Invoices cannot be traced to shipments. Multiple payments to single vendor on the same date. Pattern of purchases just below review level. Unusually quick turnaround of invoices. Payment to multiple vendors for same product. cmburnell@comcast.net FALSE INVOICES Expenses increase dramatically. Unexplained rise in cost of goods sold. Unexplained decrease in gross/net profits. Excessive materials orders. Goods not purchased at optimal point. High level approval of a low level transaction cmburnell@comcast.net cmburnell@comcast.net CHECK TAMPERING Preparing a check for one’s own benefit Intercepting a check intended for a third party and converting the check for one’s own benefit. Check Tampering: • Forged Maker Schemes • Authorized Maker Schemes • Concealed Check Schemes • Intercepted Check Schemes Payee Maker Endorsemen t CHECK TAMPERING Missing checks. Voided checks Bank accounts that are not reconciled on a timely basis. Sudden activity in dormant bank accounts cmburnell@comcast.net CHECK TAMPERING Significant increase in payments to one vendor Duplicate payments Payments without supporting documentation Accounting records that disagree with the supporting documentation cmburnell@comcast.net CHECK TAMPERING Checks to employees, in excess of the # and $ amount of normal payroll checks. Vendor & customer complaints regarding nonpayment. cmburnell@comcast.ne t QUESTIONS cmburnell@comcast.net