Ethics Fraud and Internal Control
Ethics Fraud and Internal Control
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the CEO, CFO and controller. If a company does • Employee fraud is the performance fraud by
not have a code, it must explain why. non-management employee generally designed
to directly convert cash or other assets to the
Section 406—Code of Ethics for Senior Financial employee’s personal benefit.
Officers • Management fraud is the performance fraud
• CONFLICTS OF INTEREST - Procedures for that often uses deceptive practices to inflate
dealing with conflicts of interest (not necessarily earnings or to forestall the recognition of either
preventing, provide trainings) insolvency or a decline in earnings. It does not
• FULL AND FAIR DISCLOSURES - To ensure involve direct theft and is more harmful as it
candid, open, truthful disclosures (not complex usually involves material misstatements of
and misleading accounting techniques) financial data.
• LEGAL COMPLIANCE - Requiring employees to o Perpetrated at levels of management
follow applicable laws, rules and regulations. above internal control structures.
• INTERNAL REPORTING OF CODE o Frequently involves exaggerated financial
VIOLATIONS - A mechanism to permit prompt statement results.
internal reporting of ethical violations (whistle o Misappropriation of assets often
blowers) shrouded in complex transactions
• ACCOUNTABILITY - Taking appropriate actions involving related third parties.
when code violations occur (audit committee in-
charge). THE FRAUD TRIANGLE
• The fraud triangle is a triad of factors
Fraud and Accountants associated with management and employee
• The passage of SOX has had a tremendous fraud:
impact on the external auditor’s responsibilities o situational pressure(includes personal or
for fraud detection during a financial audit. job-related stresses that could coerce an
• The Statement on Auditing Standards (SAS) individual to act dishonestly);
No. 99 is the current authoritative document that o opportunity (involves direct access to
defines fraud as an intentional act that results in assets and/ or access to information that
a material misstatement in financial statements. controls assets); and
• The objective of SAS 99 is to seamlessly blend the o ethics(pertains to one’s character and
auditor’s consideration of fraud into all phases of degree of moral opposition to acts of
the audit process. dishonesty).
DEFINITIONS OF FRAUD
• Fraud is the false representation of a material
fact made by one party to another party, with the
intent to deceive and induce the other party to
justifiably rely on the material fact to his or her
detriment.
• Act must meet five conditions:
o False representation: false statement
or disclosure.
o Material fact: fact must be substantial
factor in inducing someone to act.
o Intent to deceive: must exist or
knowledge that statement is false.
o Justifiable reliance:
misrepresentation must have been a
substantial factor relied on.
o Injury or loss: must have been
sustained by the victim.
• Fraud in business has a more specialized FINANCIAL LOSSES FROM FRAUD
meaning: • A recent study suggests fraud losses equal 5% of
o Intentional deception, asset revenue.
misappropriation or financial data • The actual cost of fraud is, however, difficult to
manipulation to the advantage of the quantify for a number of reasons:
perpetrator. o Not all fraud is detected.
o White collar crime, defalcation, o Of that detected, not all is reported.
embezzlement and irregularities. o In many fraud cases, incomplete
information is gathered.
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• Statement on Auditing Standards (SAS) No. actions are taken to deal with the
109 is the current authoritative document for organization’s risks.
specifying internal control objectives and o IT CONTROLS: General controls are
techniques. It is based on the COSO framework. controls that pertain to entity-wide
• SOX and Internal Control: concerns such as controls over the data
o Public company management center, organization databases, systems
responsibilities are codified in Sections development, and program maintenance.
302 and 404 of SOX: Application controls are controls that
o Section 302 requires management to ensure the integrity of specific systems.
certify organization’s internal controls on o PHYSICAL CONTROLS relate to human
a quarterly and annual basis. activities.
o Section 404 requires management to o Transaction authorization is a
assess internal control effectiveness. procedure to ensure that employees
o Committee of Sponsoring process only valid transactions within the
Organizations of the Treadway scope of their authority.
Commission (COSO) is a joint initiative o Segregation of duties is the separation
of five private sector organizations and is of employee duties to minimize
dedicated to providing thought incompatible functions. These include
leadership through the development of separating: (1) transaction authorization
frameworks and guidance on enterprise and processing, (2) asset custody and
risk management, internal control, and record-keeping, (3) tasks so that
fraud deterrence. successful fraud must require collusion.
o Supervision is a control activity
COSO internal control framework five involving the critical oversight of
components: employees. It is a compensating control
• The Control Environment in organizations too small for sufficient
o The control environment is the segregation of duties.
foundation of internal control. o The accounting records of an
o It sets the tone for the organization and organization consist of documents,
influences control awareness. journals, or ledgers used in transaction
o SAS 109 requires auditors obtain cycles. These capture economic essence
sufficient knowledge to assess attitudes and provide an audit trail.
and awareness of the management, o Access controls are controls that
board and owners regarding internal ensure that only authorized personnel
controls. have access to the firm’s assets.
o As a minimum, board should adopt the
provisions of SOX. Segregation of Duties Objectives
• Risk Assessment
o Risk assessment is the identification,
analysis, and management of risks
relevant to financial reporting.
• Information and Communication
o The quality of information the AIS
generates impacts management’s ability
to take actions and make decisions.
o An effective accounting information
system records all valid transactions and
provides timely and accurate information.
• Monitoring
o Monitoring is the process by which the
quality of internal control design and o Verification procedures are
operation can be assessed. independent checks of the accounting
o This can be done thru separate system to identify errors and
procedures (e.g. internal audits) or misrepresentations.
ongoing activities (e.g. computer o These differ from supervision – these
modules, management reports) happen after the fact by an individual not
• Control Activities directly involved in the transaction or task
o Control activities are the policies and being verified. Supervision happens
procedures to ensure that appropriate
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during the activity by a superior directly • Hash total is a control technique that uses
responsible for the task. nonfinancial data to keep track of the records in
o Management can assess (1) individual a batch.
performance, (2) system integrity and (3)
data correctness. Batch Control Record
o Includes:
• Reconciling batch totals during
transaction processing.
• Comparing physical assets with
accounting records.
• Reconciling subsidiary accounts
with control accounts.
• Reviewing management reports
that summarize business Run-to-Run Controls
activities.
IT APPLICATION CONTROLS
• are associated with applications.
BACKUP PROCESS IN BATCH SYSTEM USING Output controls are procedures to ensure output is not
DIRECT ACCESS FILES lost, misdirected or corrupted and that privacy is not
• Each record in a direct access file is assigned a violated.
unique disk location or address that is determined • Can cause disruption, financial loss and litigation.
by its primary key value.
• The destructive update approach leaves no Controlling Hard-Copy Output
backup copy of the original master file. It requires • OUTPUT SPOOLING: Spooling is directing an
a special recovery program if data is destroyed or application’s output to a magnetic disk file rather
corrupted. than to the printer directly because output data
in output devices can become backlogged
Destructive Update Approach (bottleneck). Proper access and backup
procedures must be in place to protect these
output (spool) files.
• PRINT PROGRAM CONTROLS should be designed
to prevent unauthorized copies and employee
browsing of sensitive data.
• SENSITIVE COMPUTER WASTE should be
shredded for protection.
• REPORT DISTRIBUTION must be controlled.*
• END-USER should examine reports for
correctness, report errors and maintain report
security.
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