'Look for red flags ...'
From special agent to investigative services provider: After college I took a job with a small CPA firm and got my first taste of financial crime when I found $5,000 missing during an audit for a small savings and loan institution. It turned out one of the tellers had taken the money. That piqued my interest in forensic accounting. Later, seeing advertisements suggesting I could be an investigator and use my accounting degree led me to apply to become a special agent with the Internal Revenue Service, Criminal Investigation. I left that role in 2015 and now serve as an associate director with Guidehouse's Global Investigations & Compliance practice. I provide investigative, forensic accounting, internal control review, anti-money laundering, monitorship, and cross-border tax investigative services to clients and their counsel. I also conduct training relating to anti-money laundering and fraud typologies.
The pandemic brings new financial crimes: It seems like there are new criminal complaints and indictments every day related to the pandemic, from price gouging, identity theft, tax and stimulus fraud to fraud around the CARES Act. A transaction that lacks any kind of business sense or investment strategy, and transactions that don't match the customer's stated line of business are just a couple examples of red flags. Bank transactions that are under the Bank Secrecy Act reporting thresholds, large round dollar transactions, rapid movement of funds, or extensive cash activity are other examples.
Conduct proper risk assessment to avoid trouble: One of the biggest compliance mistakes I see where companies perhaps don't mean to break the law but wind up in trouble is failing to conduct a proper risk assessment. It's important to assess the people and entities we're doing business with, both customers and vendors. We need to evaluate the company we work for and see what kinds of associated risks there are. Evaluate the delivery channel: Is it through the internet, face-to-face, or something else, and what are the risks there? That's probably where we get in trouble the most.
The challenges of the job: In my current role with Guidehouse, I encounter challenges that people may not understand. From an investigative standpoint, what you see on TV, where someone conducts an investigation by simply pressing one button and getting all the records they need — that does not exist. In internal investigations we'll sometimes need third-party information, but we don't have subpoena power. We generally only have internal documents and external research. Sometimes we work in tandem with attorneys, but people still have their constitutional rights. We go about our business while respecting those rights, and we're still able to put a case together.
— As told to Lea Hart, a freelance writer based in Virginia. To comment on this article or to suggest an idea for another article, contact Ken Tysiac, the JofA's editorial director, at Kenneth.Tysiac@aicpa-cima.com.
Robert Beranger, CPA/CFF, is an associate director with Guidehouse's Global Investigations & Compliance practice, based in New York City.
Favorite book or movie: The Untouchables
Favorite technology or app: I use Excel for performing gap analysis of controls, policies, and procedures. For personal matters, I use it to track vehicle repairs, home improvements, to-do lists, and budgets.
Favorite item to travel with or keep on your desk: All kidding aside, the Journal of Accountancy. Often, they just pile up and I take them on a train, plane, or vacation.