Fraud Risk Program
Draft Copy
1
Mission Statement
• To formally document the risks of fraud and policy
abuse to demonstrate due diligence around fraud
prevention and to formalize mitigation strategies
with better alignment of proactive fraud
prevention and early detection efforts with
Internal Audit activities.
2
What is a Fraud Risk Assessment?
• Fraud and reputation risk assessments focus on fraud
schemes and scenarios.
• Purpose is to identify and document risks and controls for
various scenarios & schemes that can affect the company
and its shareholders by:
– Significantly impacting the organizations reputation
– Exposing the company to criminal or civil liability
– Creating a financial reporting irregularity
• Ensure compliance with corporate governance
requirements.
Information taken from PWC Article “Deeper & Broader: Performing Fraud & Reputation Risk Assessments”
3
Risk Assessment Benchmarking
Company
Kmart
Summary
Multidisciplinary steering team created to assess the fraud risk
across Kmart and to develop a program that would minimize the
risk of overlooking fraud during the audit planning stage. Outputs
were:
(1) Documentation of significant fraud related risks, mapped to
SOX controls.
(2) Creation of a Fraud Risk Map that provides graphical
representation of where fraud falls in significance and likelihood.
Positives
(1) Buy in and involvement of
multiple parts of the organization to
identify frauds that have occurred or
have yet to occur.
Negatives
(1) Does not take regional or international risks
into consideration. Kmart stores are only in US,
Puerto Rico & Virgin Islands.
(2) Appears to be solely an attempt to document
the types of frauds and identifying those that need
preventative controls.
(3) Involvement from different areas of the
company requires significant investments in time.
Microsoft learning's
(1) Documentation of past case history and
unknown frauds drives the formulation of a risk
assessment.
(Risk Assessment Phase)
(2) Mapping of documented risks to SOX controls.
(Control Documentation Phase)
(3) Creation of a Fraud Risk Map.
(Control Documentation Phase)
7-11
Risk Assessment that identified scenarios, assesses likelihood
and impact. Outputs were:
(1) Development of a matrix that identifies high level scenarios.
(2) Assessment of Likelihood and Impact using Low, Medium,
High and Very High
(3) Brief description of Antifraud elements for each scenario.
(4) Identified Gaps and remediation steps where necessary.
(1) Easy to read matrix that shows
schemes with easy to understand
Likelihood and Risk terminology.
(1) Very high level, schemes are summarized to a
high degree.
(2) Appears to be solely an attempt to document
the types of frauds and identifying those that need
preventative controls.
(3) Does not show any type of further integration
of risks.
(1) Documentation of past case history and
unknown frauds drives the formulation of a risk
assessment.
(Risk Assessment Phase)
Reynolds American
Internal Audit driven risk assessment project that leveraged
management expertise to ensure assessment was
comprehensive. Outputs were:
(1) Development of a fraud audit program to provide a structured
approach to fraud in every audit to ensure consideration of fraud
risks in each audit and to identify potential fraud schemes and
mitigating controls.
(2) Development of separate fraud control matrices from the
existing SOX matrices.
(3) Use of information developed to promote early fraud
detection.
(1) Engagement with Internal Audit
to discuss fraud risks for each audit.
(2) Detailed audit approach for each
identified risk.
(3) Integration of fraud testing into
SOX 404 testing.
(1) Significant time with management of
(1) Requirement for audits to use the fraud risk
processes needed for documentation, assessment assessment questionnaire when meeting with
and testing of fraud controls.
subsidiary management.
(2) Does not take regional or international risks
into consideration.
Fonterra
Global Assurance driven process that creates a fraud survey for
distribution to management to mitigate fraud risk. Involvement of
business unit management to assess the current operating
environment and gaps in antifraud control as part of their
responsibility to maintain strong controls and promote an
antifraud culture. Outputs were:
(1) Fraud Survey outputs were put into a Business Unit Risk
Map that rolls to a Enterprise wide Risk Map.
(2) Creation of an Annual Fraud Review - fraud susceptible areas
are integrated in the Annual Fraud Review paper after
management comment and feedback.
(3) Management Assessment and Remediation - management
identifies areas that are currently under remediation and
relocates on the fraud risk map.
(4) IA gets involved for further audit or engagement with those
non-compliant or high fraud risk entities.
(1) Fraud Survey gets input from the (1) Time consuming
team that is working in each
(2) Requires recurring buy-in and action from
business unit.
management team to view the survey as a priority.
(2) High Management participation
in fraud surveys.
(3) Integration with existing audit
risk assessments.
(4) Coordination of management and
Internal Audit.
(1) Creation of a Microsoft Fraud Survey that
develops an understanding of where Fraud Risk
lies and to develop a better understanding of the
regions/accounts that may need further attention.
(Survey Phase)
(2) Annual FIU fraud review meeting to discuss
trends in fraudulent activity, regions and schemes.
(Fraud Experience Benchmarking Phase)
4
IA/FIU Fraud Risk Program
• IA/FIU process takes the benefits of a standard
fraud risk assessment and raises it to a new level
with tight integration into a program of fraud
prevention and early detection.
• Documents the audit risk of how the company
determines risk and audit priority.
• Coordinates an assessment of the perceived risk
by the “people in the trenches.”
• Integrates perceived risk to the IA function within
an embedded process.
5
IA/FIU Phased Process
•
Risk Assessment Phase – Now into May FY05
–
–
–
–
•
Control Documentation Phase – Late Q1 FY06
–
–
•
FIU - Additional detailed benchmarking with other corporations to facilitate the sharing of best
practices in identifying and mitigating fraud risks.
Survey Phase – Q1 and Q3 FY06
–
•
Specialization leaders - Detail control alignment to the scenario types.
Specialization leaders - Mapping of each unit’s risks to a risk map, with each quadrant having
defined risk actions.
Fraud Experience Benchmarking Phase – H1 FY06
–
•
FIU - Develop an understanding of the external regulations/industry guidelines that exist on fraud
prevention and detection. (DONE)
FIU - Benchmark Fraud Risk Assessment procedures at other companies to the the company
process. (DONE)
FIU - Formal documentation and Identification of the types of risks that have been incurred and yet
to occur at the company. (DONE)
Specialization leaders - Assessment of the likelihood and significance of a fraud occurring in
their area. (To occur in May)
FIU - Assessment of the risk that is perceived by the Sr. Management team throughout the world.
This will give good benchmarking to our internal expectations and cases received.
Evaluation Phase – Q4 FY06
–
FIU & IA - Re-visit the initial assessment of risk and coordinate the perceived risk of Management
6
to IA risk and learned best practices to the IA function.
Risk Assessment Phase
A.
Organize the Assessment
–
B.
Determine Units & Locations to Assess
–
C.
Units determined by specialization lead, with regional breakdown for SMSG.
Identify Potential Fraud & Misconduct Schemes & Scenarios
–
–
–
–
D.
Separate Cycle performed by IA/FIU on assessing the Fraud Risk at the company.
FIU to prepare a “master fraud list” of known and potential fraud schemes involving company
and break down to the specialization areas as defined in step B.
FIU to compare Transparency International listing of Corruption Perceptions Index to the
company revenue and headcount.
FIU to compare recent well known corporate scandals to determine the viability of that specific
fraud occurring at the company.
Specialization leaders to focus on areas of fraud labelled as “A” or “B” risk. FIU preventative
presentations and targeted efforts for company-wide “C” risk mitigation.
Assess Likelihood of Fraud
–
Specialization leaders to assess the likelihood of the frauds on the “master fraud list” occurring
based on a sliding scale:
–
–
–
–
E.
Assess Significance of Risk
–
Specialization leaders to assess the likelihood of the frauds on the “master fraud list” occurring
based on a sliding scale (differs for each fraud type):
–
–
–
–
F.
*
1 - Remote (<5% chance of occurrence)
2 - Possible (5-50% chance of occurrence)
3 - Somewhat likely (51-75% chance of occurrence)
4 - Probable (>75% chance of occurrence)
1 - Negligible
2 - Serious
3 - Significant
4 - Material
Mapping of Identified Risks to a quadrant view to show the likelihood and
significance.
Derived from
PWC study on creating a Fraud Risk Assessment
7
Risk Assessment Phase – Schemes (Preliminary)
ACFE Fraud Categorization
Financial
Statements
Revenue
Recognition
A
Antitrust
Journal Entries
Liability
Reporting
Asset
Misappropriation
Corruption
Conflict of
Interest
B
Channel Stuffing
Reserves
Identity Theft
Treasury
Purchase Orders
C
Fictitious
Employee
Pre-payments
T&E
Gift Cards
Disclosures
Vendors
Insider Trading
FCPA/Bribery
Petty Cash
Income Taxes
Side Letters
Benefits
Kickbacks
Former
Employee
Time & 8
Attendance
Considerations in Assessing Fraud Risk
• Specialization leaders to focus on “A” and “B”
identified schemes.
• Risk to be assessed is the inherent risk:
– Think of the risk of this fraud occurring should minimal controls
be in place.
• Consider the account balances:
– Treasury risk is rated as an “A” level risk, due to the large amount
of cash on hand. Other misappropriation of assets are “C” level
risks due to smaller potential impact on the organization.
• Consider non-financial risks:
– In fraud, reputation risks may be as significant, or more
significant than financial loss. Please consider all risks that are
attributable to the area being assessed.
9
Risk Assessment Phase - Schemes
#
Category
Classification
Assessment
Level
Scenario Type
Scenario Example
Potential Warning Signs
Likelihood
Significance
Risk Quadrant
11 Corruption
Conflict of Interest B
Employee has an undisclosed interest Employee's spouse owns a consulting company and is
in another company that is being
used by the employee without proper disclosure or
employed for work at the company.
mitigation plan.
Consistent use of a vendor without a process for
analyzing bid and work quality. Vendor pricing
higher than others in similar fields.
Please Assign Likelihood
& Significance
12 Corruption
Kickbacks
B
Employee receives a kickback from a the company pays vendor for work at a premium price and
vendor for directing work to that vendor. the company employee/vendor receives portion of the
payment back in cash or other goods/services.
Consistent use of a vendor without a process for
analyzing bid and work quality. Vendor pricing
higher than others in similar fields. Resistance
to review other competing companies.
Please Assign Likelihood
& Significance
13 Corruption
Identity Theft
B
Employee has committed identity theft Employee falsifies resume or application using another
and is not the individual they represent individuals name and/or work/education history.
to be.
No SS# on file with corp, discrepancies between
resumes submitted to recruiting.
Please Assign Likelihood
& Significance
14 Corruption
Antitrust
A
the company not following antitrust
legislation requirements.
15 Corruption
FCPA/Bribery
A
Bribery performed by the company that the company Employee bribes an employee or
violates the Foreign Corrupt Practices representative of a government entity.
Act.
Please Assign Likelihood
& Significance
16 Financial
Statements
Insider Trading
A
Insider Trading
the company Employees utilizing insider information to
influence stock decisions.
Please Assign Likelihood
& Significance
17 Financial
Statements
Revenue
Recognition
A
Adjustment of revenue data in the
company Sales.
Unauthorized adjustment of data from 3rd party to change
the amount of reported revenue.
18 Financial
Statements
Journal Entries
A
Inappropriate journal entry is made to
manipulate accounting system.
Unauthorized journal entry moves expenses to the balance Unapproved JE's, lack of BS reconciliation
sheet.
process.
Please Assign Likelihood
& Significance
19 Financial
Statements
Liability Reporting A
Under-reporting of liabilities on the
financial statements.
Movement of liabilities to off-balance sheet affiliates.
Significant change in liabilites without
corresponding outflows on the cash flow
statement.
Please Assign Likelihood
& Significance
20 Financial
Statements
Revenue
Recognition
A
Timing of Revenue
Employee changes terms of contract to change the timing
of revenue being recognized.
Significant unexplained change in timings of
revenue recognition, contracts that appear to
have non-standard terms.
Please Assign Likelihood
& Significance
21 Financial
Statements
Channel Stuffing
A
the company stuffs channel with
product to inflate reported revenue.
Employee authorizes significant additional product to
market, stuffing channel.
Spikes in sell in vs. sell through reporting
Please Assign Likelihood
& Significance
22 Financial
Statements
Reserves
A
the company uses accounting estimates or reserves to
manage earnings.
Significant changes in reserves balances or
methodology.
Please Assign Likelihood
& Significance
23 Financial
Statements
24 Financial
Statements
FS Disclosures
A
Income Taxes
A
Estimates and reserves are used to
manage earnings or misstate financial
results.
Innaccurate or misleading financial
statement disclosures.
Income Tax evasion by under-reporting
earnings or making unlawful
deductions.
the company not providing full disclosure or misleading info
within the footnotes.
the company incorrectly classifies or under-reports income
for tax purposes, or takes unlawful tax deductions.
Please Assign Likelihood
& Significance
Please Assign Likelihood
& Significance
25 Financial
Statements
Side Letters
A
Unauthorized side letter offers
concessions that may affect revenue
recognition.
Employee sets agreement on non-standard contract terms
authorizing concessions or services that affect revenue
recognition.
Please Assign Likelihood
& Significance
26 Financial
Statements
Revenue
Recognition
A
Incorrect license volumes being
reported resulting in understated or
overstated revenue.
27 Asset
Misappropriation
Treasury
A
Theft or use of treasury funds in an
unauthorized manner.
the company not following antitrust legislation
requirements.
Preventative
Controls
IA Notes
FIU Notes
Please Assign Likelihood
& Significance
Increased retailer rebates, unexplainable
differences between other the company groups of
similar size or product.
Please Assign Likelihood
& Significance
Please Assign Likelihood
& Significance
Employee directs treasury funds to an unapproved
investment or directs funds to a personal account.
Please Assign Likelihood
& Significance
Definitions
A Significant Adverse Impact upon the Enterprise
B Prevent/Detect at Source
C Manage through company-wide FIU fraud prevention & detection program
Additional Considerations for FIU:
1 Is fraud being considered by M&A during acquisitions
2 Is there a double standard for high level vs. lower level employees, if so, why?
3 Current inconsistency in disciplinary actions for similar offenses, not always based on level of employee.
10
Risk Quadrants & Actions
4
Quadrant 3 –
Detect & Monitor
Quadrant 4 –
Prevent at Source
Significance
Focus Audit
Programs and
Control
documentation for
risks in these areas.
3
2
Quadrant 1 –
Low Control
Quadrant 2 –
Monitor
1
1
2
3
Likelihood
4
11
Risk Assessment Phase - Likelihood & Significance
Asset Misappropriation
Corruption
Financial Statements
Likelihood
Remote
Possible
Somewhat Likely
Probable
<5% Chance of Occurrence
6%-50% Chance of Occurrence
51%-74% Chance of Occurrence
>75% Chance of Occurrence
<5% Chance of Occurrence
6%-50% Chance of Occurrence
51%-74% Chance of Occurrence
>75% Chance of Occurrence
<5% Chance of Occurrence
6%-50% Chance of Occurrence
51%-74% Chance of Occurrence
>75% Chance of Occurrence
Significance
Negligible
Serious
Significant
Material
<$100M
$100M-$300M
$301M-$500M
>$500M
FIU to develop significance levels
12
Risk Assessment Phase – International
25 Least Corrupt Countries
Rank
1
2
3
3
5
6
7
8
9
10
11
12
13
13
15
16
17
17
17
20
21
22
22
24
25
+ No Office
Country
Finland
New Zealand
Denmark
Iceland
Singapore
Sweden
Switzerland
Norway
Australia
Netherlands
United Kingdom
Canada
Austria
Luxembourg
Germany
Hong Kong
Belgium
Ireland
USA
Chile*
Barbados+
France
Spain
Japan
Malta+
2004 CPI
FY05 Revenue FC
Score
(000's)
9.7
187,645
9.6
114,605
9.5
282,562
9.5
11,241
9.3
100,497
9.2
353,761
9.1
336,979
8.9
195,773
8.8
644,276
8.7
572,581
8.6
2,083,437
8.5
860,866
8.4
207,778
8.4
11,477
8.2
2,096,960
8.0
101,131
7.5
231,632
7.5
120,412
7.5
18,058,433
7.4
30,378
7.3
0
7.1
1,060,348
7.1
393,001
6.9
3,880,728
6.8
0
FY05 Approved
FTE HC
141
115
871
7
645
402
514
167
712
458
2,335
775
179
5
1,739
199
257
1,064
43,388
63
0
1,290
527
2,090
0
IA/FIU
Ranking
1
1
2
1
2
1
1
1
2
1
3
2
1
1
2
1
1
2
3
2
Comments
IA/FIU
Ranking
1
2
3
Definition
No known issues
Issues known, sporadic
Consistent issues, high risk
To change
2
2
3
Benefits:
•
Provide SMSG Specialization Leader with aggregate of Regional Risk
•
Worldwide analysis of how HC and $$ allocation compares to known corruption indexes
•
Provide visibility to countries or regions that may need education on fraud risks
13
* Information taken from 2004 Transparency International Corruption Index
Risk Assessment Phase – International
25 Most Corrupt Countries
Rank
122
122
122
122
122
122
122
129
129
129
129
133
133
133
133
133
133
133
140
140
142
142
144
145
145
+ No Office
Country
Bolivia*
Guatemala+
Kazakhstan
Kyrgyzstan+
Niger+
Sudan+
Ukraine
Cameroon+
Iraq+
Kenya
Pakistan
Angola+
Congo, Democratic Republic+
Cote d´Ivoire
Georgia+
Indonesia
Tajikistan+
Turkmenistan+
Azerbaijan+
Paraguay*
Chad+
Myanmar+
Nigeria
Bangladesh
Haiti+
2004 CPI
FY05 Revenue FC
Score
(000's)
2.2
3,375
2.2
0
2.2
12,478
2.2
0
2.2
0
2.2
0
2.2
42,550
2.1
0
2.1
0
2.1
15,434
2.1
11,331
2.0
0
2.0
0
2.0
12,334
2.0
0
2.0
42,374
2.0
0
2.0
0
1.9
0
1.9
482
1.7
0
1.7
0
1.6
17,324
1.5
1,300
1.5
0
FY05 Approved
FTE HC
7
12
13
0
0
0
21
0
0
11
7
0
0
10
0
74
0
0
0
1
0
0
13
3
0
IA/FIU
Ranking
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Comments
IA/FIU
Ranking
1
2
3
Definition
No known issues
Issues known, sporadic
Consistent issues, high risk
To change
14
* Information taken from 2004 Transparency International Corruption Index
Risk Assessment Phase - Corporate Fraud Scandals
Company
Adelphia
Enron
Fraud (or Alleged Fraud) Descriptions
How could this happen?
(1) Fraudulently excluded billions of dollars in liabilities Very tight familial ownership of
from its consolidated financial statements by hiding
the company with few outsiders
them on the books of off-balance sheet affiliates.
allowed into the inner circle.
(2) Falsified operations statistics and inflated earnings
to meet Wall Street's expectations.
(3) Concealed rampant self-dealing by the Rigas
Family, including the undisclosed use of corporate
funds for Rigas Family stock purchases and the
acquisition of luxury condominiums in New York and
elsewhere.
(1) Setup a system of shell companies to hide
liabilities, insure stock holdings and sell money losing
assets.
(2) Booked revenue from power swaps with other
energy traders.
(3) Booked loans as cash from operations.
(4) Booked revenue for long term contracts before
revenue was able to be recognized under GAAP.
(5) Manipulation of electricity markets and pricing.
Scenario assessed by
(1) 18-Journal Entries
(2) 19-Liability Reporting
(3) 23-Financial Statement
Disclosures
Amount of Fraud
Carried out by
$2.4B ($2.3B of
Founders family
liabilities hidden and and 2 Sr.
~$100M of self
Executives
dealing)
Explosive growth, extremely high (1) 19-Liability Reporting
pressure to exceed targets, non- (2) 20-Revenue Recognition
independent Board of Directors,
significant bonuses paid for
meeting targets to Sr.
Management.
CEO, CFO and top
level executives
Reasons Unlikely
1. Founders are involved in the day to day
business decisions and are near the top of the
worlds richest people, there would be no
f inancial need to carry out these levels of f raud.
2. Board of Directors is independent other than
2 individuals and is made up of skilled members
of the business community.
3. Accounting f irm is independent.
4. Strong emphasis on compliance through the
creation of the Of f ice of Legal Compliance.
5. Standards of Business Conduct.
Worldcom
Tyco
(1) Reduced liability reserve accounts and counted as
revenue.
(2) Classified operating costs as long term
investments in order to capitalize and reduce P&L
impacts.
High pressure to hit targets,
(1) 22-Reserves
significant loans to CEO making (2) 18-Journal Entries
stock price exceedingly important
to the CEO, CFO putting extreme
pressure on finance to please
Wall Street.
$11B
(1) CEO & CFO authorized themselves interest-free or
low interest loans for personal purchases of property,
jewelry, and other frivolities. According to the SEC,
these loans were never approved or repaid.
(2) CEO & CFO were accused of issuing bonuses to
themselves and other employees without approval of
Tyco’s board of directors. It was alleged that these
bonuses acted as loan forgiveness for employees who
had borrowed company money or were used to buy the
silence of those who suspected the former CEO and
CFO of fraud.
Company was tightly controlled
by the CEO and the Board of
Directors was not seen as a
group that could question his
authority.
$600M
(3) 23-Financial Statement
Disclosures
CEO, CFO and top
level executives
6. Strong Internal Audit f unction with integrated
FIU.
7. Strong and Independent Audit Committee.
CEO, CFO,
General Counsel
15
Control Documentation Phase
Financial Statements
#
Scenario Type
1 Employee has an undisclosed interest in another company that is
being employed for work at the company.
2 Employee receives a kickback from a vendor for directing work to that
vendor.
Significance
Q1 - Preventative and/or
Detective Controls
Quadrant
Please Assign
Likelihood &
Significance
Please Assign
Likelihood &
Significance
Please Assign
Likelihood &
Significance
4 the company not following antitrust legislation requirements.
Please Assign
Likelihood &
Significance
5 Bribery performed by the company that violates the Foreign Corrupt
Practices Act.
Please Assign
Likelihood &
Significance
6 Insider Trading
Please Assign
Likelihood &
Significance
7 Adjustment of revenue data in the company Sales.
Please Assign
Likelihood &
Significance
8 Inappropriate journal entry is made to manipulate accounting system.
Please Assign
Likelihood &
Significance
9 Under-reporting of liabilities on the financial statements.
Please Assign
Likelihood &
Significance
10 Timing of Revenue
11 the company stuffs channel with product to inflate reported revenue.
12 Estimates and reserves are used to manage earnings or misstate
financial results.
13 Innaccurate or misleading financial statement disclosures.
15 Unauthorized side letter offers concessions that may affect revenue
recognition.
16 Incorrect license volumes being reported resulting in understated or
overstated revenue.
Assets
Likelihood
3 Employee has committed identity theft and is not the individual they
represent to be.
14 Income Tax evasion by under-reporting earnings or making unlawful
deductions.
17 Theft or use of treasury funds/IP/other assets in an unauthorized
manner. (Think of the 10 areas in the FIU section below and how they
apply to your area.)
18 Purchase Order creation after commencement of work.
19 Vendor fraudulently over-charging or double charging for services or
goods.
20 the company pre-paying vendor for work to be completed.
21 Unauthorized use of gift cards for personal gain.
FIU
• Specialization
Leaders to take
scenarios matrix
for their areas
and map each
risk to specific
SOX controls.
• Late Q1
timeframe for
rollout – ensure
that it doesn’t
affect 404
deliverables.
Corruption
Category
22 Individual continues to use the company resources after leaving the
company.
23 Petty cash theft.
24 Travel & Entertainment or ProCard expenditues are falsified.
25 Employee's not reporting sick or leave time.
26 Employee's not reporting partner as eligible for benefits at their place of
employment.
27 Payment of payroll to ficticious or former employees.
IA Notes
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To be addressed via company-wide FIU fraud
awareness presentations and FIU preventative
efforts.
16
FIU Notes
Fraud Experience Benchmarking Phase
• Benchmark fraud prevention and detection within
the company against other companies to better
understand the trends in fraud and to build a
fraud resource network within the business
community.
• Use of the Corporate Executive Board to facilitate
a Fraud Summit that includes the other
companies that have been heavily involved in
fraud prevention and detection.
• FIU annual meeting for discussing fraud trends in
a formal setting.
17
Survey Phase
•
Creation of a fraud survey that would be circulated to large audience worldwide,
in order to better identify trends and to get a better idea of the frauds that are
not being reported to the FIU. Ideas for those to be included are:
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Vice Presidents (US)
General Managers (Regional)
Country Managers (In Country)
Controllers (all)
Compliance Managers
CFO’s (BG)
LCA (Subsidiary)
HR (Subsidiary)
FIU to aggregate the data to see what the perceived risk by those in the field is,
and where unknown risk may lie.
2 surveys – 1st would not be anonymous, 2nd would be 6 months later and be
anonymous. Comparison of results would provide validation of responses.
FIU to determine what vehicle is best for surveys – integrate with other surveys
and ensure consistency with 302?
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Evaluation Phase
• Taking knowledge learned from previous phases,
the FIU will work with IA to:
– Use survey feedback to identify regions or countries
that may have significant risk that has been unreported to the FIU.
– Create a documented benchmark of how the FIU
compares to similar investigative groups across the
industry.
– Develop a systematic plan for integrating fraud
detection into the audit plan.
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