AN EVALUATION OF THE EFFECTIVENESS OF ANTI-FRAUD MEASURES
WITHIN AN ORGANIZATION
By
Helen Ann Doerr
BS in Information Security and Intelligence
Ferris State University, 2010
BS
Murray State University, 1984
Advisor:
Dr. James H. Jones, Jr.
Assistant Professor
Accounting, Finance, and Information Systems Department
Fall Semester 2010
Ferris State University
Big Rapids, MI
1
DEDICATION
This is dedicated to my husband, Bret Doerr.
2
ACKNOWLEDGEMENTS
I would like to acknowledge Dr. Douglas Blakemore who was my instructor for the class
Fraud Examination. This class initiated my interest in the Information Security and
Intelligence program at Ferris State University.
3
TABLE OF CONTENTS
Page
List of Tables……………………………………………………………………………5
List of Figures…………………………………………………………………………...6
Abstract................................................................................................................……….7
Chapter 1 .......................................................................................................................…9
Chapter 2 .........................................................................................................................18
Chapter 3 .........................................................................................................................22
Chapter 4 ........................................................................................................................24
Chapter 5 .........................................................................................................................30
Appendices …………….………………………………………………………………32
List of References.……………………………………………………………………..36
4
LIST OF TABLES
Table
Page
Table 1: Asset Misappropriation Sub-Categories ............................................................ 14
Table 2: Percentage of Fraud Reports .............................................................................. 26
Table 3: How Hotlines are Communicated to Employees ................................................ 27
5
LIST OF FIGURES
Figure
Page
Figure 1: Types of Fraud by Occurrence .......................................................................... 12
Figure 2: Types of Fraud by Median Loss ........................................................................ 12
Figure 3: Percentage of Fraud Cases by Position ............................................................. 15
Figure 4: Median Loss by Position ................................................................................... 15
Figure 5: Reasons for Declining Legal Action ................................................................. 19
Figure 6: How Fraud is Detected ..................................................................................... 21
6
ABSTRACT
AN EVALUATION OF THE EFFECTIVENESS OF ANTI-FRAUD MEASURES
WITHIN AN ORGANIZATION
Helen Ann Doerr: BS
Ferris State University, 2010
Advisor: Dr. James H. Jones, Jr.
The main objective of this paper is to determine whether certain aspects of the SarbanesOxley Act (SOX) have been effective in preventing and detecting fraud. Prior to the
enactment of this Act, the business world within the United States had witnessed several
instances of fraud that would have catastrophic results. The purpose of SOX was, in part,
to address these issues through external auditing. Also included in SOX was the
implementation of hotlines, where “whistle blowers” could notify their company of
fraudulent activities. The methodology used to evaluate this topic was through online
research of various websites and articles and interviews with two experts in the area of
Accounting. Additional research was done by reviewing textbooks and notes from past
classes taken at Ferris State University. These classes included: Auditing, Accounting
Information Systems, Data Mining and Fraud Examination. From this research it was
determined while SOX did have an impact on the prevention and detection of fraud, there
7
were other measures that companies have chosen to implement. The use of technology is
now becoming a dominant factor in the prevention and detection of fraud. Hotlines
continue to be the number one source of fraud detection. However, companies must also
develop their own fraud control policies in order to protect their assets.
8
CHAPTER 1 - INTRODUCTION
During the last part of the 20th century and into the early years of the 21st century,
the business world was plagued with accounting scandals. Companies like Enron and
WorldCom that are publicly traded on the stock exchange, eventually were forced into
bankruptcy, while a leading accounting firm, Arthur Anderson LLP collapsed due to its
involvement with some of these companies. As a direct result of these scandals, congress
stepped in and in 2002 enacted the Sarbanes-Oxley Act (SOX). This Act was designed to
combat fraud and reform accounting, and financial report. However, since the enactment
a key question remains, was the Sarbanes-Oxley overkill or has it made an impact on
fraud control? This paper will focus on what companies are doing to protect themselves
from fraud. Two key aspects are key components found in SOX: Auditing and Hotlines,
while other technologies, such as the implementation of a Fraud Control Policy is not
mentioned in SOX.
SOX is a complex act containing 11 titles and each title containing multiple
sections. It is beyond the scope of this paper to fully analyze the efficacy of each title
and section. However, Title II Auditor Independence changed the way audits were
performed. The auditor was to remain independent from the company being audited by
9
reporting to an audit committee. The audit committee had to approve all audit and nonaudit services. Furthermore, the auditor must rotate off assignment every 5 years.
Auditors must complete detailed audits, and issue an audit report stating the findings.
But how effective are these audits in combating fraud? What about other types of audits,
ones conducted by the organization? Are they better in detecting fraud?
Also within SOX is another important area called Title III: Corporate
Responsibility. Section 301 of this Title states that “whistleblowing” mechanism must
be established where fraud and misconduct can be reported.
But since the implementation of SOX in 2002, how effective has it been in
reducing fraud? How do companies address the requirement for a “whistleblowing”
mechanism. If these titles are implemented, what has been the impact on fraud?
Finally, if SOX has not been effective in combating fraud, what are some
alternative measures that an organization can implement to combat and prevent fraud.
However, before we can fully evaluate the impact of these two titles, we must first
understand what fraud is and how serious it is in today’s work environment.
WHAT IS FRAUD
Fraud is still a serious problem in today’s work.
According to the 2010 Report
to the Nations on Occupational Fraud and Abuse published by the Association of
Certified Fraud Examiners (ACFE), it is estimated that an organization will lose
approximately 5% of its revenue to some type of fraud or abuse. But what does this in
terms of actual dollars? If we were to take this estimate and multiply it by the US Gross
World Product, we would project the cost of fraud to organization would exceed $2.9
10
trillion dollars. (Association of Certified Fraud Examiners, 2010). In comparison, the
2010 national defense budget was set at $ 663 billion dollars. Unfortunately, it is
unlikely, or even impossible to know what is the total cost of fraud might actually be
since it can go undetected for years within an organization.
But exactly what constitutes fraud? The definition for fraud is as follows:
The use of one’s occupation for personal enrichment through the
deliberate misuse or misapplication of the employing organization’s resources or
assets.
The definition of fraud is very broad, therefore a more detailed
explanation is necessary to understand what is fraud.
Fraud can be broken up into three categories



Corruption
Asset Misappropriations
Fraudulent Statements
A diagram illustrating the various examples of each category may be found in
Appendix B.
According to the ACFE 2010 Report to the Nations on Occupational Fraud and
Abuse, Asset Misappropriation account for more than 80% of all cases, however in terms
of losses, it is the lowest median loss as illustrated in Figure 1 and Figure 2.
11
Figure 1: Types of Fraud by Occurrence
Figure 2: Types of Fraud by Median Loss
12
Additionally, it is clear from Figure 1, that asset misappropriation is the most
common occurrence of fraud being committed. To understand how employees are
committing fraud it is also necessary to understand the different manners in which they
are doing so. Table 1 further provides the sub-categories, description and examples
associated with different types of asset misappropriation.
13
Table 1: Asset Misappropriation Sub-Categories
Asset Misappropriation Sub-Categories
Category
Description
Examples
Skimming
Cash is stolen before recorded on the
organization’s books
Employee accepts payment
from a customer but doesn’t
record the sale
Cash Larceny
Cash is stolen from an organization
after it is recorded on the books
Employee steals the cash
but before it is deposited in
the bank
Billing
A person causes his employer to issue
a payment by submitting invoices for
fictitious goods or services, inflated
invoices or invoices for personal
purchases.
Employee creates a shell
company and bills employer
for non-existent services
Expense
Reimbursement
A person makes a claim for
reimbursements of fictitious or
inflated business expenses
Employee files fraudulent
expense report
Check Tampering
A person steals employer’s funds by
intercepting, forging or altering a
check draw on the organization’s
bank account
Employee steals blank
checks and makes them out
to himself
Payroll
A person causes his employer to issue
a payment by making false claims for
compensation
Employee claims overtime
not worked
Cash Register
Disbursements
A person makes false entries on a
cash register to conceal the fraudulent
removal of cash
Employee fraudulent voids
a sale and steals the cash
Cash on Hand
A person misappropriates cash kept
Misappropriations on hand the organization’s premise
Employee steals cash from
the vault
Non-Cash
A person steals or misuses non-cash
Misappropriations assets of the organization
Employee steals or misuses
confidential customer
14
information
WHO COMMITS FRAUD
We also need to determine who is committing the fraud. Fraud is not limited to
offenses carried out by employees, but also it also may include managers, executives and
even the owners. While Figure 1 shows that the Owner/Executives account for only
19.3% of the number of cases of fraud, Figure 2 indicates the amount of fraud in dollars
is often larger when compared to the dollar amount committed by managers and
employees.
Figure 3: Percentage of Fraud Cases by Position
2006 National Fraud Survey: Percentage of Cases by Position
Figure 4: Median Loss by Position
2006 National Fraud Survey: Median Loss by Position
15
Based on the information provided, one might conclude that a large number of
asset misappropriations are being carried out by employees and managers. However, a
smaller amount of cases involve fraudulent misstatements which are typically carried out
by the owner executive and result in a much higher median loss.
Based on the background information on fraud, it is now time to ask some
questions.

How effective are aspects of the Sarbanes Oxley Act?

Are companies taking a more aggressive stand against fraud?

What kinds of technologies are available to companies to reduce the threat
of fraud?
16
GLOSSARY
Audit, External - Audits that are conducted by professional who evaluates the financial
statements of an organization. These professionals are independent of the organization
being audited.
Audit, Internal – Audits conducted by individuals employed by the organization to help
the organization achieve their state goals.
Data Mining - A profiling technique where artificial intelligence is used to analye large
volumes of data by considering the relationships between individual data items.
Internal Control – Are the set of procedures and policies adopted within an organization
to safeguard its assets, check the accuracy and reliability of its data, promote operation
efficiency and encourage adherence to prescribed managerial practices.
17
CHAPTER 2 – LITERATURE RESERACH
CORPORATE RESPONSIBLIY
Often without even knowing it, companies are actually encouraging fraud to happen
within their organization. But how can this be? Companies often do not have any policy
on what is expected of their employees in respect to responsibility and accountability.
Goals may not be established or monitored. There may not be written policies or
procedures for the establishment of internal controls such a segregation of duties. And
even if there is a company policy, it will be no good if it isn’t enforced consistently and
systematically.
Many times, if fraud does occur, management will often take the do nothing
attitude or not pursue any type of legal action. But why would a company do nothing?
According to the 2006 National Fraud Survey they may not want the negative publicity.
18
Figure 5: Reasons for Declining Legal Action
2006 National Fraud Surve: Reasons for Declining to Take Legal Action
But the tide may be turning, the schemes that fraudsters are now becoming more
elaborate and sophisticated. Additionally, the fraudsters are making sure they are
undetected so that the fraud scheme is active for a long as possible. Based on this fact as
well pressure from an organization’s board of directors, pressure from insurance
companies, new regulatory requirements for public companies and an increase in media
coverage, more organizations are now taking pro-active approach to the prevention and
detection of fraud. One way this can be achieved is the implementation of a Fraud
Control Policy
To assist in this change, Barack Ferrazzano Kirschbau and Negelberg LLP, a legal
firm located in Chicago has published a model Fraud Control Policy. The actual policy
19
may vary according to industry standards, type of organization, regulatory requirements
and geographic location. However, they should address some level the following: Fraud
Detection, Fraud Awareness, Fraud Reporting, Internal Controls, Procedures for
Reporting Potential Fraud, pre-employment and procedures for conducting internal and
external investigations. (Barack Ferrazzano Kirsch & Nagelberg LLP, 2008). The
outline of the policy can be found in Appendix with a link to the entire document.
As part of any Fraud Control policy, organizations also need to make assessment
on how fraud is actually detected. According to Figure 5, tips remain the most effective
measure of detecting fraud. Additionally, within the same report is states ,”
organizations could improve their detection efforts by establishing formal structures to
receive reports about fraudulent conduct”. By implementing a hotline, an organization
may be able to identify individual committing fraud and gather information to be used in
future investigations.
20
Figure 6: How Fraud is Detected
COMPANY HOTLINES
For a hotline to be effective, it must be accessible, ideally 24 hours a day and 7
days a week. According to an article written by David Slovin in Internal Auditor, “nearly
50% of all hotline calls are made at night or on weekends. It must also afford
confidentiality. Another benefit of using a third party hotline is that it will be staffed
with individuals who are trained interviewers. By using a standardized interviewing
process, the interviewer may cover the concern in a thorough and systematic manner.
(Sanzone, 2009)
21
CHAPTER 3 - METHODOLOGY
Research for the paper was based primarily from various online papers and
websites. Two separate studies provided much of the statistics found within the paper.
The first was The 2010 Report to the Nations on Occupational Fraud and Abuse
conducted by the Association of Certified Fraud examiners. The second study was the
2009 Corporate Governance and Compliance Hotline Benchmarking Report conducted
by BDO Consulting.
Additionally, interviews were conducted with two Ferris State University
professors: The first interview was conducted with Dr. Charles Wolgamott on September
21, 2010. Dr. Wolgamott teaches several Accounting classes at Ferris State University
including Forensic Accounting. He is also a Certified Fraud Examiner. During the
interview, there was a lengthy discussion fraud in general, much of what was also
identified in other resources. Key questions that were asked during the interview:



How do auditors proceed once fraud is suspected?
What happens after the primary investigation?
What types of documents are examined?
The second interview was with Robert Thompson on September 23, 2010. Mr.
Thompson teaches Governmental Accounting and Auditing classes at the University
22
Center in Traverse City, MI. In addition to his teaching duties, Mr. Thompson has been a
CPA at the accounting firm of Dennis, Gartland and Niergarth located in Traverse City,
MI since 1985. He has been a partner in the firm since 1994, specializing in audit and
accounting. Key questions that were asked during the interview include:




Has auditing reduced the occurrence of fraud?
What is the most effective detection of fraud?
What is the most effective prevention of fraud?
What are some “red flags” identified during an audit?
Additional resources also came from various classes such as: Fraud Examination,
Data Mining, Auditing and Accounting Information Systems.
23
CHAPTER 4 - FINDINGS
Deloitte
In 2007, the Deloitte Forensic Center, a think tank sponsored by Deloitte
Financial Advisor Services LLP, conducted a professional survey to evaluate how an
organizations practices compare to other organizations and successful are these practices.
The Deloitte Forensic Center received responses from 277 executives and how each rated
key areas of fraud control. The companies covered a broad range of sectors including
financial services, healthcare, retail, public sector, transportation and other services.
Sixty-four percent said their companies were subject to SOX, while 36% were
not.
Companies were categorized into more effective and less effective at fraud
control. The more effective companies gave their companies an average of 3.5 on a 5point scale in four areas: preventing internal fraud, detective internal fraud, preventing
external fraud, and detecting external fraud.
When asked of if the company has a formal Fraud Control Policy, 50% indicated
they did, with another 32% planning on implementing such a policy.
Another question that was asked was about the existence of a whistle-blower
hotline. 81% of respondents indicated there was a hotline in place, with another 9%
24
indicating there were plans to install one. Since tips are the primary way that fraud is
detected, whistle blower hotlines are an important way to address management override
of internal controls, improving their effectiveness creates an opportunity for fraud
control.
Companies that are more effective were more likely to have a better training
program for its employees than less effective companies. 54% of effective companies
felt their employees had a clear understanding of their responsibilities as compared to
only 20% of less effective companies.
Finally, based on the survey, it appears that the 35% of the more effective
companies utilized technology substantially in ongoing fraud monitoring while only 12%
of the less effective companies utilized technology. However, all companies indicated
the increased use of technology was extremely or very likely. (Deloitte Forensic Center,
2007)
2009 Corporate Governance and Compliance Hotline Benchmarking Report
In 2009 BDO Consulting, a division of BDO Seidman, LLP issued the 2009
Corporate Governance and Compliance Hotline Benchmarking Report. This report
covered a 5 year span starting in 2004 and ending in 2008. Over 1,300 organizations
were included covering a variety of industries such as retail trade, service industries;
transportation, communication as well as other industries.
The number of fraud related incidents has increased over time.
25
Table 2: Percentage of Fraud Reports
Quarter
Percent of Reports
Q1 2006
10.0
Q1 2007
14.3
Q1 2008
16.5
Q1 2009
21.0
By implementing an anonymous hotline, the organization can gather critical,
organizational feedback. Although it is required by publicly traded companies as
specified in SOX, other companies are now starting to realize positive benefits from
implementing a hotline.
When an organization benchmarks data obtained from a hotline, the company can
determine of organizational changes are needed. By continually monitoring the data, the
organization can assess new programs. This can easily be done by the use of data mining
software. Additionally, an organization can begin to assess the data and look for
relationships between data that has been collected. Another type of software that can be
used i2 which can graphically display large amounts of data and their relationships.
But the hotline is only useful, if employees are aware of it. Companies can
instruct employees on its use by a company handbook, brochure, or manager. However,
the most effective use of communication to the employees was through posters.
Although according to the study the trend of the poster is declining over the 5 year
26
period, the use of a company intranet is increasing even though it remains much lower
than the poster.
Table 3: How Hotlines are Communicated to Employees
Means
2004
2005
2006
2007
2008
Brochure
4%
3%
3%
2%
3%
Employee
14%
14%
15%
16%
14%
HR
4%
4%
4%
4%
4%
Handbook
9%
9%
10%
9%
10%
Intranet
4%
5%
5%
7%
9%
Manager
5%
6%
5%
6%
5%
Other
13%
13%
13%
13%
15%
Poster
39%
38%
37%
35%
31%
Sign
1%
1%
2%
2%
2%
Unknown
1%
1%
1%
2%
2%
Video
0%
0%
0%
0%
0%
Wallet Card
6%
6%
5%
4%
5%
(BDO Consulting, 2009)
Dr. Wolgamott Interview
One question asked during the interview with Dr. Wolgamott, was “What happens
once an auditor suspects an employee of fraud? The answer would depend a lot on the
27
type of fraud suspected as well as the position of the fraudster. However, in general
terms, the auditor would start asking questions of a general nature and then zero in on
more specific areas based on the responses. Dr. Wolgamott indicated that effective
interviewing skills played a critical part in investigating fraud. Questions would be asked
of the suspected fraudster as well as co-workers, supervisors, ex-spouses etc.
Another investigative technique was the examination of public records and
documents of the suspected fraudster. With more information made available due to
public records on the internet, it is easier to search for clues. By looking at real estate
transactions, an investigator might be able to see if a fraudster is living beyond what is
pay scale would allow.
After the fraudster is confronted by the auditor, it may be necessary for law
enforcement to get involved. A subpoena would be necessary for searches of any
computer device or other relative records
Robert Charles Thompson Interview
During the course of the interview with Mr. Thompson, I asked how effective was
auditing in the preventing and detecting fraud. The answer somewhat surprised me.
Based on the class in Auditing that I had previously taken with him, I understood how
detailed and complex it was, however, it actually based on his response, I learned that it
did not have the effect that I expected. This is due to the fact that once fraud in
uncovered during an audit, the damage has already been done.
28
A more effective way to address fraud was in the segregation of duties. By
segrating duties, this makes it more difficult for a fraud from occurring. An example of
segregation of duties would be that the individual who processes checks is not in charge
of bank reconciliation.
Another question that was discussed was whether companies were willing to
prosecute once a fraud was uncovered. Based on early research that I had conducted, I
believed that companies were reluctant to proceed with legal proceedings. While that
may have been true in the past, it appears that in recent years, more companies are willing
to prosecute. This may be driven by the insurance companies as a way to make
restitution.
Finally, there was a discussion on what might be some “red flags” for an auditor
to suspect fraud. One red flag might occur when examining two different shifts or two
different locations. If there are significant differences in how the two shifts or locations
operate, then more investigation might be warranted.
Mr. Thompson also stressed the importance of internal controls to prevent fraud.
While it may be more difficult for smaller businesses to have adequate internal controls
such as segregation of duties, the appearance of having internal controls, can be just as
effective. For example, a supervisor may not always review every invoice that has to be
paid, but if employees have to submit invoices for signature, then this may in fact prevent
faulty invoices being submitted for payment.
29
CHAPTER 5 - CONCLUSION
In conclusion, fraud has always and still is a serious threat in today’s business
world. However, in 2002, with the enactment of the Sarbanes-Oxley Act (SOX), the tide
began to turn. Even with that said, SOX is not the panacea for the detection or
prevention of fraud. It did place more responsibility on the corporate governance. No
longer can CEO use denial as a reason for fraud occurring in the workplace.
Auditing, which was also a key component of SOX has limited value in the
prevention of fraud. The main reason, is that by the time fraud has been detected during
the course of audit, the fraud usually has been going on for a while, and the damage is
already done.
Companies are now starting to realize that they must take a more hands on
approach in the detection and prevention of fraud. With the advances in technology,
companies now have more options than were available even 10 years ago. By using a
better method of screening potential employees, they may in fact avert fraud from ever
occurring. By using the hotline and data mining techniques, they may start to assimilate
a better picture of what is occurring in a larger situation. For example, trends and
patterns that normally aren’t identifiable, may now have significance in detecting fraud.
30
The future for different methods of the prevention and detection of fraud is
limited only to the existence of the technology. Employers may use video surveillance,
monitor an employee’s computer with key logging devices, search emails via packet
sniffers, or use smart card ID’s which are embedded with a computer chip that monitors
the movement of the employee while on the company property.
It is unlikely that fraud, will ever be eliminated entirely, but it is clear that it can
be reduced and brought into a controllable manner with the use of technology.
31
APPENDIX
FRAUD PREVENTION CHECKLIST
The most cost-effective way to limit fraud loses is to prevent fraud from occurring. This
checklist is designed to help organizations test the effectiveness of their fraud prevention
measures.
1
Is ongoing anti-fraud training provided to all employees of the organization
 Do employees understand what constitute fraud?
 Have the costs of fraud to the company and everyone in is – including
lost profits, adverse publicity, job loss and decreased morale and
productivity – been made clear to the employees?
 Do employees know where to seek advice when faced with uncertain
ethical decisions, and do they believe they can speak freely?
 Has a policy of zero-tolerance for fraud been communicated to
employees through words and actions?
2
Is an effective fraud reporting mechanism in place?
 Have employees been taught how to communicate concerns about
known or potential wrongdoing?
 Is there an anonymous reporting channel available to employees, such
as a third-party hotline?
 Do employees trust that they can report suspicious activity
anonymously and/or confidentially and without fear of reprisal?
 Has is been made clear to employees that reports of suspicious activity
will be promptly and thoroughly evaluated?
3
To increase employees’ perception of detection, are the following proactive
measures taken and publicized to employees?
 Is possible fraudulent conduct aggressively sought out, rather than
dealt with passively?
 Does the organization send the message that it actively seeks our
fraudulent conduct through fraud assessment questioning by auditors?
 Are surprise audits performed in addition to regularly scheduled fraud
audits?
32
 Is continuous auditing software used to detect fraud, and if so, has the
use of such software been made known through the organization?
4
Is the management climate/tone at the top one of honesty and integrity?
 Are employees surveyed to determine the extent to which they believe
management acts with honesty and integrity?
 Are performance goals realistic?
 Have fraud prevention goals been incorporated into the performance
measures against which managers are evaluated and which are used to
determine performance-related compensation?
 Has the organization established, implemented and tested a process for
oversight of fraud risks by the board of directors or others charged
with governance (e.g., the audit committee)?
5
Are fraud risk assessments performed to proactively identify and mitigate the
company’s vulnerability?
6
Are strong anti-fraud controls in place and operating effectively, including the
following?





Proper segregation of duties
Use of authorizations
Physical safeguards
Job rotations
Mandatory vacations
7
Does the internal audit department, if one exists, have adequate resources and
authority to operate effectively and without undue influence from senior
management?
8
Does the hiring policy include the following (where permitted by law)?






9
Past employment verification
Criminal and civil background checks
Credit checks
Drug screening
Education verification
Reference check
Are employee support programs in place to assist employees struggling with
addictions, mental/emotional health, family or financial problems?
33
10 Is an open-door policy in place that allows employees to speak freely about
pressures, providing management the opportunity to alleviate such pressures
before they become acute?
11 Are anonymous surveys conducted to assess employee morale? (Association of
Certified Fraud Examiners, 2010)
34
Model Fraud Control Policy Outline
I. Summary of Policy
A. Overview
B. Definition of Fraud
C. Company’s Zero Tolerance of Fraud
II. Summary of Fraud Control Strategies
A. Appointment of a Fraud Control Officer
B. Fraud Detection
C. Fraud Risk Management
D. Fraud Awareness
E. Fraud Reporting
F. Internal Control Review Following Discovery of Fraud
III. Fraud Risk Management
A. Regular Fraud Risk Assessment
B. Fraud Risk Assessment
C. Implementation of Proposed Actions
IV. Pre-employment Screening
V. Conflict of Interest
VI. Procedures for Reporting Potential Fraud
A. Internal Reporting
B. Protection of Employees Reporting Suspected Fraud
C. Evaluation of Reports Received
D. Recovery of Losses by Fraud
VII.
Procedures for Fraud Investigation and Prosecution
A. Internal Investigation
B. External Investigative Resources
C. Disciplinary Proceedings (Barack Ferrazzano Kirsch & Nagelberg LLP,
2008)
The document may be viewed at in its entirety at:
http://www.boardmember.com/uploadedFiles/Home/Conferences/Conferences/Ten_Thin
gs_About_Fraud_Control/ModelFraudControlPolicy.pdf?n=4700
35
REFERENCES
Association of Certified Fraud Examiners. (2010). Report to the Nations on Occupational
Fraud and Abuse.
Barack Ferrazzano Kirsch & Nagelberg LLP. (2008). Model Control Policy. Retrieved
September 27, 2010, from Boardmember web site:
http://www.boardmember.com/uploadedFiles/Home/Conferences/Conferences/Ten_Thin
gs_About_Fraud_Control/ModelFraudControlPolicy.pdf?n=4700
BDO Consulting. (2009). 2009 Corporate Governance and Compliance Hotline
Benchmarking Report. Retrieved October 30, 2010, from BDO Consulting:
http://www.bdo.com/download/1084
Deloitte Forensic Center. (2007). Ten Things About Fraud Control. Retrieved October
30, 2010, from Deloitte Forensic Center: www.deloitte.com/us/forensiccenter
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http://www.lawyershop.com/practice-areas/criminal-law/white-collarcrimes/embezzlement/
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http://ethicsline.com/about-ethicsline/
Hopwood, W. S., Leiner, J. J., & Young, G. R. (2008). Forensic Accounting. New York,
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Sheet Sheet 16: Employment Background Checks: http://www.privacyrights.org/fs/fs16bck.htm
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Sanzone, K. (2009, February).
Combating Fraud - Whistleblower Hotlines. Retrieved September 24, 2010, from
Anguillare, Ruocco, Traiester and Company Website:
http://www.artcpas.com/Press/Whistleblower%20Hotlines.htm
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Turner, L., & Weickgenannt, A. (2009). Accounting Information Systems. Hoboken, NJ:
John Wiley and Sons.
Wells, J. T. (2007). Corporate Fraud Handbook. Hoboken, NJ: John Wiley and Sons.
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CURRICULUM VITAE
Ann Doerr
4066 Garden Court
Traverse City, MI 49684
Cell:231(702)3372
abenningfield@chartermi.net
EDUCATIONAL BACKGROUND
Ferris State University – University Center, Traverse City, MI
BS in Information Security and Intelligence, December 2010
Minor in Accounting
Northwestern Michigan College – Traverse City, MI
Various classes
AWARDS and HONORS:
Dean’s List at Ferris State University
Award for Academic Excellence (2009-2010)
Member of Phi Theta Gamma at NMC
ACTIVITIES
Student member of Association of Certified Fraud Examiners
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