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Step #1 – Create a Fraud Policy
Simply having a fraud policy in place raises fraud awareness among
managers and establishes a hierarchy of responsibilities for the
detection and investigation of wrongdoing. There are several important
provisions that fraud policies must include:
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A statement
making managers responsible for knowledge of the exposures and the
symptoms of fraud in their department;
-
Guidelines
for properly handling suspected theft to avoid charges of malicious
prosecution, slander, libel and false imprisonment;
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Assignment
of responsibility for investigation, internal notification and
communication, insurance claims, and coordination with law
enforcement;
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A written
reporting procedure so that employees can confidentially report
suspicious conduct to those responsible for investigations.
Step #2 – Establish Internal Controls
Internal controls are necessary to monitor the objectives of any
organization. Internal controls cover such diverse areas as human
resources, manufacturing goals, accounting records, and compliance with
government regulations. In the opinion of many auditors, sound internal
controls can prevent most occupational offenses.
But internal controls can provide only reasonable – not absolute –
assurance that their company’s goals are being met. Most internal
control mechanisms can be defeated by one or more employees sufficiently
motivated. To maximize the effectiveness of internal controls three
conditions are absolutely necessary:
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Oversight
and supervision of employees and their activities;
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Careful
division of employee responsibilities so that no one employee can
handle a financial transaction from “cradle to grave.”;
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Require
countersignatures on all checks, as well as a separation of duties
for sensitive transactions, such as purchasing inventory, writing
checks and balancing accounts.
Step #3 – Obtain Periodic, Independent
Audits
To assure objectivity, an outside CPA should perform both internal and
external audits. Some organizations will even audit the auditor to
ensure he or she is not committing fraud. Many organizations employ
outside security consulting firms to test procedural controls and offer
suggestions for their improvement.
Step #4 – Don’t Forget About Your
Computer System Controls
It is critical to restrict access to sensitive transactions and
information to only employees with legitimate need for such access.
This can be accomplished by:
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Tracking who
requests access to the network or sensitive transactions;
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Ensuring
that passwords are difficult to guess and changed frequently;
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Install a
“firewall” between the private corporate network and the internet or
outside network;
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Encrypting
confidential information;
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Using
software that detects suspicious or threatening activity.
Step #5 – Take Appropriate Loss
Prevention & Detection Measures
Because internal controls are not completely foolproof, especially when
there is collusion, it is impossible to prevent employee dishonesty
entirely. But by taking these few simple steps, organizations can make
it difficult and time-consuming for employees and others to defraud the
organization.
1.
Establish standardized internal controls that provide both
the consistency and uniformity throughout the organization;
2.
Conduct pre-employment checks;
3.
Educate employees on how strong ethics benefit the
individual worker (i.e., avoid the financial impact on company profits,
raises and promotions);
4.
Management should set an example of ethical behavior;
5.
Set a decisive policy to investigate and, where warranted,
prosecute wrongdoing.
Step #6 – Completely Evaluate and
Monitor the Adequacy of Your Employee Dishonesty Coverage
Even with all the above steps taken, occasionally any employee, or group
of employees, can successfully defraud your company. The last line of
defense to prevent the financial impact of such events is a properly
designed employee dishonesty policy. Take a close look at coverage
adequacy. Not all employee dishonesty policies are alike, and there are
many gaps that can exist if not properly designed. For that reason we
strongly recommend an annual review of these coverages in light of
existing company exposures and make adjustments where necessary.
NAPLIA
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