A number of our certified Chapter members, currently practicing both independently and as corporate staff, report being asked to proactively assist in the establishment of first time internal fraud prevention programs by clients and employers. That this development is something new is borne out by recent articles in the trade press but, on a moment’s reflection, shouldn’t be surprising since CFEs are so uniquely qualified for the particular task.
At a time when an increasingly volatile stock environment, increased cases of cyber fraud, the pressure of globalization and a multitude of increased regulatory requirements are of major concern to all managements, risk assessment and fraud prevention really have to play an important role in ensuring that corporations are not exposed to unexpected and poorly controlled risks. Internal fraud prevention related activities need to be revisited with a focus not just on all these new business paradigms but also on stakeholders’ expectations, transparency, and accountability.
It just makes sense then that today’s environment also calls for greater collaboration and strong relationships between all types of assurance professionals with their clients at all levels to ensure an internal anti-fraud structure is in place (if one doesn’t presently exist) that facilitates a healthy, secure and transparent operating environment.
To facilitate the establishment of a risk-centric approach, today’s fraud prevention functions (new or presently existing) must continually revisit their methodologies, processes, and practices. CFEs can provide experienced insight and real-time value to their client organization by expanding their consulting efforts to facilitate a risk-centric approach, helping to establish the foundation for a more sophisticated and nimble tone at the top, and by focusing on increased collaboration and strategic engagement.
Fraud prevention efforts have been dominated for some time now by a control focused approach that is often reactive and regressive in actual practice in the face of today’s swiftly changing realities. Anti-fraud professionals today need to widen their proactive scope to address the growing governance threats and risk management needs of increasingly global organizations. This requires them to adopt a revised risk-centric approach that involves:
–Taking fraud prevention and business ethics from a compliance perspective to a cultural mind-set. Accurately assessing these risks requires more than just checking to see whether rules are being followed; practitioners must also try to ensure that the spirit of these rules is incorporated into activities at every level.
–Determining key business and fraud risks rather than casting a wide net over numerous risks, many of which may be remote or obscure; the concept of critical business process identification drawn from disaster recovery and continuous operations planning is especially relevant here.
–Identifying emerging risk issues and trends, such as changes in the regulatory environment (which are often wholly reactive), and bringing them to the attention of key stakeholders.
–Estimating the significance of each fraud risk and assessing its probability of occurrence based on a deeper understanding of the present sense conveyed by constantly shifting data and as sometimes pinpointed by sophisticated statistical analysis.
–Identifying programs and controls designed to more sensitively detect and address risk and by concurrent testing of their effectiveness in real-time.
–Coordinating with the other critical risk and control related business processes, such as compliance, risk management, fiscal control, and legal, to ensure that fraud risks are identified, controlled and managed appropriately.
To provide real strategic value to the organization, new and existing fraud prevention practitioners need to help develop risk-based action plans that respond to their present state of risk assessment awareness and which focus on stakeholder expectations. Internal anti-fraud plans should incorporate risk identification and prioritization, as well as analysis and quantification of risk factors particularly in the new business ventures and strategies so characteristic of today’s volatile environment. Such planning should also reflect an understanding of shared risks among various projects and initiatives, and feature continuous monitoring of business activities and key performance indicators.
In the present cyber-threat laden environment the internal fraud prevention business process has to move from being just another routine and disconnected function to being a fulcrum of organizational governance and risk, working in concert with management, the board, and external auditors. Top management can establish the fraud prevention function’s role by:
–Allowing senior fraud examiners and investigators exposure to security information presently associated with key management and governance committees;
–Championing the importance of ethical conduct, fraud identification and fraud prevention consistently.
–Taking immediate and proactive action on fraud examination and investigative findings regardless of whatever level of the organization suspected perpetrators are identified.
–Holding senior executives accountable for identified instances of fraud, waste and abuse in business processes over which they exercise management oversight.
–Supporting the management of the fraud prevention function when its findings and recommendations to improve security prove politically unpopular.
–Defining fraud prevention’s role and management’s expectations.
–Providing appropriate funding, talent and authority to the function.
The ACFE has long indicated that a strong tone at the top from senior management about the importance of a internal fraud prevention function goes a long way toward promoting the engagement of managers throughout the client organization.
For staff assigned to an internal fraud prevention plan to proactively review important business strategies successfully for fraud vulnerability, examiners need to collaborate with management. In addition to providing assurance on compliance initiatives, examiners should develop a forward-looking approach to their assessment planning in which they cooperate and coordinate with related risk and control functions, focus on critical business risks and exposures, and determine the relevance and effectiveness of gathered executive responses to help an organization manage fraud risk proactively. To be forward-looking, fraud prevention professionals need to be fully integrated into the strategic planning process so that they can clearly identify which fraud related risks the organization will be undertaking. They also must be involved with the business in evaluating problems that come to light to determine whether they are the result of control weaknesses that could also emerge in other parts of the organization.
To identify and analyze rapidly emerging risks, direct resources toward areas of greatest risk, and conduct targeted, real-time investigations in response to specific, predicated risks, examiners must leverage technology, learn new skills, and work with management to understand and clarify their evolving expanded role.
To assess the new emerging risks effectively, fraud prevention professionals must develop a deeper understanding of the client business and of the processes that make competitors in the client’s industry successful. An effective fraud prevention activity that can deal with contemporary business risks and meet the ever-increasing demands of management and stakeholders requires a solid staffing strategy. As CFEs we must help spread the word that our client organizations need to invest in skilled resources, methods, training, career paths, and technical infrastructure to deal with increasing cyber-related business risks related to fraud, their internal controls, and government imposed regulations. When staffing a fraud prevention function, top management should:
–Establish a program for selecting and developing the fraud prevention team.
–Identify the skills and expertise required for an effective anti-fraud business process; the ACFE’s guidance and training programs are an invaluable resource to any organization contemplating a new fraud prevention function or looking to strengthen an existing one.
–Assess existing resources to identify staffing gaps.
–Identify and create key performance indicators for deploying fraud prevention and investigatory resources.
–Co-source or outsource internal fraud prevention activities, based on an assessment of current resources, budget, and strategic and tactical requirements.
Acquiring new skills through ACFE training can enable internally focused examiners to direct resources to those techniques that are the most effective in identifying risks to the organization. Especially important is the need to develop deep expertise in specialties such as credit, IT, finance, compliance, and cyber. In addition, investigators and examiners will have to be trained to approach their work strategically, beginning with a detailed understanding of where its owners and stakeholders view where the client business has been and where it is going.
In summary, progressive internal fraud prevention and investigation functions need to partner with their client organization’s risk management function to gain comprehensive visibility into enterprise-wide risks and to support performance of automation supported follow-on risk assessments that can help prevent fraud vulnerability issues from turning into fraud events. Such insight into the organization’s risk profile allows internal investigative professionals to deliver more strategic value by focusing their proactive fraud risk evaluation efforts on areas that represent the greatest risk to the organization as well as proactively anticipating where emerging fraud risk issues are most likely to cause problems. In addition, leveraging the activities performed by the client’s risk management function can lower fraud prevention’s overall cost of operation.