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 month’s 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 boss’s hat means
shouldering diverse responsibilities, and many
entrepreneurs don’t 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. That’s when
trouble brews.
The following case study
isn’t 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”
fraud—especially in small
organizations—can 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
sincere—everything the firm wanted.
Gladys, the partner in charge, hired him
on the spot. |
How Crooks Help
Themselves to Company Funds
Some employees can’t
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
culprit’s 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 supervisor’s 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
Mark’s 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
firm’s receptionist saw what he had done
and promptly informed the office manager,
Harriett. Given the firm’s 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 weren’t
particularly expensive, Harriett rarely
examined the cash-register tapes—a fact
that hadn’t escaped Mark’s attention.
After the receptionist’s visit, though,
Harriett scanned several of Mark’s
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 didn’t take the news well.
Individually, Mark’s thefts weren’t
material, but they would force Gladys to
make a difficult decision. Although she
couldn’t 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. | 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 Mark’s 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.
Mark’s gaze wandered around the room. He
frowned and said in a low voice, “I guess I’d 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 “weren’t 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. “He’s been a good
employee in every other way—he 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.
Gladys’s eyes moved again to Mark’s
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 Mark’s curious reply: “I
didn’t do it.” As she said “I’m
terminating you immediately for stealing
from the company, Mark,” she realized it
mattered more to her than it did to him.
Before leaving the boss’s 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 Deidre’s 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. |
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
company’s 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 today’s litigious
environment, Mark’s previous employer probably
would not have revealed the true reason for his
departure, even if her firm had asked. But the
computer manufacturer’s 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 revealed—to
Gladys’s growing anxiety—she 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 couldn’t
bring herself to turn him in. Dazed, Gladys
wondered if she’d 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 Gladys’s managerial error? The
price for the firm’s slack cost controls and
failure to follow appropriate hiring procedures
was significant: Although Mark’s thefts were
petty, two workers lost their jobs. Deidre had
been next in line to head the bookkeeping
department. Furthermore, although Deidre’s
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
employee’s 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 company’s employment
application form, request information on
all jobs held in the last seven years or
longer.
Look for chronological gaps
on an employee’s 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 applicant’s
immediate supervisor. Fearful of
employee litigation, most organizations
will provide only basic information. But
often they will reveal whether they
would rehire the employee—a valuable
indication of the circumstances under
which he or she left the company.
| 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
That’s 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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