| This is the final installment in a
four-part series on identifying false
invoices and their issuers. The July and
August columns focused on billing schemes
involving shell companies criminals set
up to facilitate fraud. Articles in this
issue and September explain how to detect
and prevent two scams that employ other,
completely different phony-bill
strategies. This months case
study shows CPAs the far-reaching
consequences of not setting up controls
in a business to detect and prevent
seemingly immaterial frauds.
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ost business owners enjoy their leadership role.
But wearing the bosss hat means shouldering
diverse responsibilities, and many entrepreneurs
dont have time to manage human resources
and other important administrative functions. So
they often hire someone to do these jobs for
them. If at first all goes
well, the boss may no longer check to see if his
or her managers follow proper supervisory
procedures. Thats when trouble brews.
| The following case study
isnt just for auditors, but rather
for the thousands of CPAs heading their
own businesses, occupying other
management positions or advising
business-owner clients. It demonstrates
how immaterial
fraudespecially in small
organizationscan have companywide
consequences. THE
PERFECT APPLICANT?
A
Midwestern CPA firm with about 50
full-time employees needed someone to run
office errands. Deidre, a member of its
bookkeeping staff, thought she knew the
ideal candidate: a young man named Mark,
who lived in her apartment complex. So
she recommended him for an employment
interview during which he appeared
bright, energetic and
sincereeverything the firm wanted.
Gladys, the partner in charge, hired him
on the spot.
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How Crooks
Help Themselves to Company Funds
Some employees
cant resist temptation and
use their employers money
to buy things for themselves.
They do it in one or more of four
ways. Fraudulently
authorizing invoices by an
appropriate party. In
many occupational fraud cases,
the culprits duties include
authorizing purchases, and his or
her conscience is the only
control in place.
Falsifying
documents to obtain
authorization. If
the fraudster is not the
authorizer of invoices, he or she
often will forge a
supervisors approval
signature on purchase
requisitions and other documents.
Altering
legitimate purchase orders. In
some cases, a crooked employee
alters a legitimate purchase
order, increasing the quantity of
merchandise requested. When the
goods arrive, the employee takes
the excess items or returns them
for a refund.
Misusing
company credit cards. If
a company has weak controls over
the use of credit cards, some
employees take advantage and buy
everything from fuel for their
automobiles to furniture for
their homes.
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The following Monday Mark
began work enthusiastically: He hand-delivered
urgent documents, used the company car to pick up
visitors arriving from out of town and shopped
for miscellaneous office supplies and groceries.
The weeks passed swiftly as Mark got better at
his job. Management even trusted him with making
bank deposits, and after six months of exemplary
performance, he received a positive evaluation
and a modest raise.
CLAY
FEET REVEALED
One day,
as Marks first anniversary neared,
his good start came to a bad end. On the
way back from picking up supplies at the
supermarket, he stowed some of them in
his car before bringing the rest to the
office. But unfortunately for Mark, the
firms receptionist saw what he had
done and promptly informed the office
manager, Harriett. Given the firms lax
purchase approval procedures, Mark had
had no trouble using company funds to buy
things for himself. Each time he made a
list of necessary supplies and prepared
to go shopping, Harriet issued Mark a
blank, signed check. When he returned,
Mark submitted the receipt for his
purchases.
Because the office
supplies and groceries werent
particularly expensive, Harriett rarely
examined the cash-register tapesa
fact that hadnt escaped Marks
attention. After the receptionists
visit, though, Harriett scanned several
of Marks receipts. She was shocked
to discover that in addition to items for
the office, Mark had been buying beer,
cigarettes and other personal items
without reimbursing the firm for them.
Taking a deep breath,
Harriet reported the embarrassing facts
to Gladys, who didnt take the news
well. Individually, Marks thefts
werent material, but they would
force Gladys to make a difficult
decision. Although she couldnt just
reprimand Mark, she hesitated to fire
him. And yet it was important to set an
example that would deter other employees
from committing fraud.
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Source: Occupational
Fraud and Abuse, by Joseph
T. Wells, Obsidian Publishing Co.
Inc., 1997.
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THE TRUTH HURTS
The choice turned
out to be clearer than Gladys expected, but it
still was painful. After glancing at Marks
personnel file, she summoned him to her office
and closed the door. When he was seated she said
she needed his help on a problem. Gladys paused
and looked Mark right in the eye. What
would you do if you were the boss and you learned
a valuable employee was stealing from the
firm? she asked.
Marks gaze wandered
around the room. He frowned and said in a low
voice, I guess Id call him in and ask
him about it. After five minutes of patient
questioning, Gladys got Mark to confess. When she
asked for a motive, he said the stolen items
werent expensive and the
company could easily afford them.
Hearing this casual admission,
Gladys resisted an urge to shout at Mark in
frustration. We all liked and trusted this
young man, Gladys thought. Hes
been a good employee in every other wayhe
has a near-perfect attendance record, gets along
well with everyone and makes a good impression on
clients.
But Gladys knew retaining Mark
would set a dangerous legal precedent. If she let
one thieving employee stay and in the future
fired another for similar misdeeds, the firm
would be vulnerable to a wrongful discharge suit.
It was clear Mark had to go.
| Gladyss eyes moved again
to Marks personnel file, open on
her desk, with his employment application
on top. She noticed Mark previously had
worked for a nearby computer
manufacturer. On a hunch, she asked,
What would your former employer say
if I called and asked why you left?
She was struck by Marks curious
reply: I didnt do it.
As she said
Im terminating you
immediately for stealing from the
company, Mark, she realized it
mattered more to her than it did to him.
Before leaving the
bosss office, Mark admitted the
computer maker also had fired him for
stealing. Gladys silently cursed herself
for not instructing the staff to put Mark
through a normal preemployment background
check. Instead, she had trusted
Deidres judgment and
recommendation. At the time it seemed
reasonable; Deidre had been with the
company for more than four years and was
an outstanding employee.
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How to
Prevent and Detect Personal
Purchases
Ensure
company policy clearly prohibits
all personal purchases with
company funds. Do not
permit the same employee to
originate purchases and approve
them.
Separate
the invoice approval function
from the payment and receiving
function.
Establish
maximum purchasing limits for
each employee.
Install
controls to detect multiple
purchases just below
employees approval limits.
Establish
procedures to routinely check for
deliveries of company-ordered
goods to external addresses. And
look for matches between invoice
delivery addresses and
employees home addresses.
Examine
shipment receiving reports for
merchandise ordered and paid for
but not delivered.
Check
invoices for vendors that are not
usually associated with the
companys business. For
example, it would be suspicious
for a manufacturer to order goods
from a department store.
Routinely
examine individual
employees buying habits,
looking for increases in the
amount or frequency of purchases.
Carefully
control access to, and purchases
that are made from, company
credit cards. Be especially alert
to purchases in round amounts,
which might indicate false or
inappropriate charges.
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Gladys knew that in
todays litigious environment, Marks
previous employer probably would not have
revealed the true reason for his departure, even
if her firm had asked. But the computer
manufacturers HR manager probably would
have admitted he would not rehire Mark, and that
would have been a red flag.
ONE
MISTAKE, MANY CONSEQUENCES
Minutes after
finishing with Mark, the boss called in Deidre,
who, having heard the rumor quickly spreading
through the office, was in tears and
revealedto Gladyss growing
anxietyshe and Mark had been dating for
months. When questioned, Deidre admitted she knew
Mark was pilfering groceries and said she had
encouraged him to stop. But Mark continued
stealing, and Deidre said she couldnt bring
herself to turn him in. Dazed, Gladys wondered if
shed checked her own brains at the door the
day the firm hired Mark without knowing more
about him. But she gritted her teeth and fired
Deidre, too, for her ethical lapse.
But what of Gladyss
managerial error? The price for the firms
slack cost controls and failure to follow
appropriate hiring procedures was significant:
Although Marks thefts were petty, two
workers lost their jobs. Deidre had been next in
line to head the bookkeeping department.
Furthermore, although
Deidres coworkers knew why she was leaving,
her popularity did not diminish and a blue mood
pervaded her team for weeks. Gladys learned the
hard way how a good employees departure
under bad circumstances can foster low morale
that, along with the cost of training
replacements, burdens a firm with avoidable
difficulties.
The moral? When it comes to
fraud, do sweat the small stuff. 
Checking References
Approximately
7% of employees who commit fraud did so
at previous jobs, according to the
Association of Certified Fraud
Examiners 2002 Report to the
Nation on Occupational Fraud and Abuse. To
avoid hiring these high-risk workers,
consider the following recommendations.
On the companys
employment application form, request
information on all jobs held in the last
seven years or longer.
Look for chronological gaps
on an employees application, which
may indicate he or she wants to avoid
disclosing information about a particular
position held or a criminal conviction.
Confirm all
employment-history information. If
possible, interview the applicants
immediate supervisor. Fearful of employee
litigation, most organizations will
provide only basic information. But often
they will reveal whether they would
rehire the employeea valuable
indication of the circumstances under
which he or she left the company.
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JOSEPH T. WELLS, CPA, CFE, is
founder and chairman of the Association of
Certified Fraud Examiners in Austin, Texas, and
professor of fraud examination at the University
of Texas. Mr. Wells article, So
Thats Why It's Called a Pyramid Scheme (JofA, Oct.00, page 91),
won the Lawler Award for the best article in the JofA
in 2000. His e-mail address is joe@cfenet.com.
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