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DISCUSSIONS > FRAUD [ REFRESH ]
Thread Title: Understanding Fraud
Created On Sunday December 19, 2010 3:58 PM
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Dilbert


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Sunday December 19, 2010 3:58 PM

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Comrades: As most of you know, I have strongly advocated for the IIA discipline to take responsibility for preventing institutional fraud. My reasons for this stand, certain to be criticized as IIA heresy. include:

1 - Recent studies of the extent of the fraud matter place the prevalence of fraud as 12% of the population per annum. Gasp! How significant an issue in the auditing world do you want?

2 - No other discipline that I know of is better situated, educated and competent to deal with "fraud" at any level. When I have broached the issue with other accounting specialties, most of them default on the basis of remoteness to daily proceedings. Many point to IIA as the logical champion of busting fraud. I agree.

In working on edition two of my recent book "Design for Prevention," I investigated the sociologists latest work on "Crimes of Obedience." This is a tricky issue, like fraud, and it shares the ubiquity of fraud as well. Perhaps the biggest example of dealing with the conflict of personal morals and orders from the chain of command is BigKell. Wow! Has he suffered for living by his principles of conduct! I would fight along side of him anytime.

Crimes of obedience are routine in the accounting disciplines. Most auditors can smell fraud in the air at great distances. The collision comes when the related knowledge-building actions go against the grain of corporate ideology. You're supposed to defend the infallibility of the chain of command, not challenge it. Intelligence and infallibility are in a joint restriction. If you need one, you have to give up the other.

The law is quite able to cite law and legal precedent that labels auditors as accomplices to the crime of fraud. You will see this connection fleshed out in the Madoff Ponzi. It seems to me that if the law can prosecute an auditor for complicity in fraud, fraud avoidance is, by definition, part of the obligation of auditing to society.

The key question is: "Will citing the IIA redbook and IIA tradition defend the auditor against charges of complicity?" Will "I was only following orders" work in litigation? Don't bet on it.

"Were you or should you have been aware that fraud was going on? What did you do to stop it?"




Edited: Thursday January 20, 2011 at 11:31 AM by Dilbert

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bigkell


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Wednesday December 22, 2010 10:44 AM

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Is everyone asleep?

Any time those in-charge control the compensation of those doing the auditing -- there will ALWAYS be a bit of lost independence.

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planoisdaudit


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Tuesday December 28, 2010 3:43 PM

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Dil,

Again, you point to our profession to accomplish something that it is not designed to do. Your posit would suppose that we would be able to be the "fraud police" and still retain sufficient independence and objectivity to perform our other internal audit duties.

I've spent over 20 years in the profession, and yes we are trained to spot fraud. Most of us can audit the heck out of a suspicious situation and determine if fraud has taken place. I've lost CAE jobs twice because I've refused to bend my ethics to those of the C-staff or board. I've also been the cause of 14 people jailed and over 30 people terminated due to discovery of various occupational frauds. So, I've seen the worst and the best of reactions organizations can make.

Your post also forgets the fact that many organizations do not employ internal auditors. Madoff was a prime example, I've seen no evidence that there was an IA staff at his firm and according to press the external auditor was there in name only. So how would having IA become the "fraud police" have prevented Bernie Madoff's fraud? It would not!

Fraud is a crime that needs financial pressure, opportunity, and a rationalization. Take any of those elements away and the likelihood that fraud will occur has been greatly diminished. We can do that best through a good tone at the top, good policies, and good internal controls. All of those things are the purview of Senior Management and the Board.

It will never work for IA to become the "fraud police". As strenuously as you argue for this, it still won't work. It's like imploring a blind, crippled man to climb a ladder and change a light bulb. No matter how hard you may implore them, it just won't happen.



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Dan
Integrity can be defined as your moral soundness. A test for integrity - Do your actions match your words?

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CarlaDee


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Wednesday January 26, 2011 11:55 AM

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WoW! I'm glad I do not have to choose sides in this debate! It is a bit like our nation's health care issue: Yes, reform could be beneficial to many, but well planned and thought out reform with input from all areas. Even then I doubt it would be beneficial for all involved, just many.

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Mark R. Simmons


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Wednesday January 26, 2011 5:38 PM

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Dilbert wrote: As most of you know, I have strongly advocated for the IIA discipline to take responsibility for preventing institutional fraud...The key question is: "Will citing the IIA redbook and IIA tradition defend the auditor against charges of complicity?" Will "I was only following orders" work in litigation? Don't bet on it.


Dilbert, to put your question in a different context:
If I have observed the guy down the street dealing drugs from his home, is it necessary for me to stake out the drug house, gather evidence, raid the drug house, make a citizen's arrest of the drug dealer, restrain and detain the drug dealer, and then deliver him to the pokey? I think not.

Title 18, Part 1, Chapter 1, Section 4 of the United States Code
§ 4. Misprision of felony
Whoever, having knowledge of the actual commission of a felony cognizable by a court of the United States, conceals and does not as soon as possible make known the same to some judge or other person in civil or military authority under the United States, shall be fined under this title or imprisoned not more than three years, or both.


18USC4 requires that if I come into direct knowledge of the commission of a crime, I report my knowledge to appropriate authorities and let the authorities handle it. It doesn't require me to become a vigilante and go out hunting for drug dealers. Likewise for fraud (IMHO, of course).



Edited: Wednesday February 09, 2011 at 6:07 PM by Mark R. Simmons

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Busha


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Tuesday February 08, 2011 11:27 AM

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AMEN!! Bigkell, no question about that!


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Busha


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Tuesday February 08, 2011 11:50 AM

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Planoisdaudit, your comment regarding losing two CAE positions because of C-Staff or board leads me to believe you did not have true independence. And assuming you reported to the board, it seems it was controlled by by the C-Staff and therefore yours or anyone else in a similar position, the length of their tenure will be dubious. Independence from managment begins at the board level and then is vigorously delegated to the CAE, without this, the work product of the IA department may be suspect. Note AS5 which states that and external auditor MUST rely on the work of 3rd parties if that third party is deemed to competent and objective. How can IA be objective without independence in fact and appearance?



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T3gals


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Tuesday February 08, 2011 2:44 PM

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Busha,
I agree as internal auditors independence is of paramount importance to our effectiveness as well as our credibility. However, out in the real world there are boards that don't wish to hear what we have to say. Often management is very protective of its turf and doesn't want to hear how processes could be made more efficient and effective. They may think, "How could this person possibly know the business as well as me? They don't have the right to tell me anything!" Or there could be something scarier going on which they're hoping will never see the light of day.
Just my thoughts.

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bigkell


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Wednesday February 09, 2011 12:47 AM

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Compensation for EA's and IA's should be outside of the corporation of which they audit. Somewhat akin to a government agency set up. No answering to the CEO, CFO or BOD. Audits performed independent of corporate managments' whims.

I must be drinkin too much cool aid.

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Dilbert


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Wednesday February 09, 2011 6:19 PM

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The responses to the proposition have been most helpful. This responsibility for outcomes matter is neither simple nor clear cut. Only by discussion by the principals at the work face can these conflicts be reconciled. One might think that by now, considering the amounts at stake, these contradictions would have been worked out by the Establishment. Curious that such fundamental perspectives are left floating about by blind drift. The only thing certain here is that the resolution of the fraud epidemic will require change. Business as usual is creaming the stakeholders and Bigkell to boot.

Fraud has had plenty of scientific study and documentation, of course. My great unaswered question is, knowing the technology of fraud, what discipline is better suited than IA to nip it in the bud? Forget the past, the laws, the red book, precedent. Who's better situated to get the job done? Be sure to examine this question in the reverse. If free rein was given to a team to address the fraud obscenity, what would be better than to immediately start doing the job IA does? You want it both ways? Think it's possible without autonomy?

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planoisdaudit


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Thursday February 10, 2011 5:21 PM

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Busha,

In my experience, there is no relationship that allows one to achieve perfect independence. If you are an internal employee, you are still subject to being downsized, let go, or whatever your favorite pet phrase is. It doesn't matter if you do report to the AC or CAE, at some point you will run across a situation where you make someone with much more political clout than you most uncomfortable. Life isn't much more secure as a consultant. They don't like your answer, they can shop around for another consultant. I've even been an Inspector General, which is regulatory. Even regulators routinely have to run the political maze between powerful lobbies and performing their jobs correctly.

I've learned that the first thing you have to learn to deal with is people and politics. If you are unwilling or unable to take those on, you will eventually be moving on.


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Dan
Integrity can be defined as your moral soundness. A test for integrity - Do your actions match your words?

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planoisdaudit


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Thursday February 10, 2011 5:48 PM

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Dil,

You always seem to bring out a lively discussion thread. Consider the following:

A tall person is best suited to pick fruits from trees. Should we postulate that all NBA basketball players would be put to better use as field hands harvesting fruit?

A thief is best situated to detect and prevent crime. Should we postulate that only theives may apply to be policemen?

Obviously, I'm pulling your leg a bit. Solving fraud is obviously a complex issue. It has always seemed to me that you are looking for something that is a mix of an internal auditor, regulator, and perhaps security or enforcer. That is not a role that I would want to see created in my organization, period. I'll keep the current system of having management and the board squarely responsible for their actions (or lack thereof).

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Dan
Integrity can be defined as your moral soundness. A test for integrity - Do your actions match your words?

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bigkell


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Saturday February 12, 2011 1:16 AM

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"I'll keep the current system of having management and the board squarely responsible for their actions (or lack thereof). " Plano

In some cases, when the "poop hits the fan;" management, the board, and YOU are squarely responsible, in the eyes of some - rightly or wrongly.

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Dilbert


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Saturday February 12, 2011 10:44 AM

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BigKell has it right. Say what you will, when big fraud hits, people lose respect for their watchdogs. "How could the auditors be doing their job and then claim ignorance about what was going on - and for so long." Watch the Madoff episode play out in the courts. Think all the accountants will escape complicity? As Bigkell states, there is the law and there is the law of public opinion. IA is in a no-win situation here. If it clings to its traditional excuses, it's going to lose trust. You all know how hard it is to restore trust.

I really don't know why I never blamed management for stealing from the corporate treasury or ever held management responsible for the frauds they allowed. The track record of modern management speaks for itself. But what I do know is that IA BigKell is the model template for fraud prevention. If you set him autonomous with whatever resources he wanted and told him his goal was to prevent fraud, does anyone on this forum seriously think he would fail?

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bigkell


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Saturday February 12, 2011 5:16 PM

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I would never dispute the appropriateness of our mission. It will ALWAYS be appropriate. However, the world does not concern itself with the appropriateness of our mission. I honestly try not to suppress the zeal of those gaining experience in this profession, and its honorable goals, but they should know what will be presented to them in the course of their careers that can be very philosophically challenging.

The unfortunate thing is that our goals and their attainment on an individual basis (and collectively I suppose) are NOT sufficient to challenge the pervasiveness of the "dirty deeds" that exist in business today. We are "out-gunned."

Do I sound like a "quitter." I hope not. I've tried real hard over these many years being the best auditor I could be. My demise has been brought about by "innocent parties," who chose to find me culpable for business practices I had no control over practices that ultimately had very serious consequences for those innocent parties. They said "clean house." That included the "bad guys" and the "good guys." Guess who I feel I was.

If you stay in "auditing," you (at least I think most of you will) question if it is really worth it. Now, many in many professions go throught same "soul searching." The difference with auditors is not so much a desire to "self actualize," but to turn your back on the lack of appreciation for and ineffectiveness of your efforts.

Usually, the only ones appreciative of your efforts are your compadres on the job, and your counterparts in the "profession." That's why I say to the "newbies," give it five years, and then give real strong consideration towards doing something else.

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planoisdaudit


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Monday February 14, 2011 7:07 PM

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I'm not arguing a bit with what BK has said. Been there, done that, got the t-shirt. Twice I've picked myself up, dusted myself off, and went a job hunting after incidents similar to what BK has experienced. The first time, I went back to the profession, but in a completely different industry. The last time, I became a CFO instead. This is just the way of the world and something you learn to deal with in the financial profession.

Dil, this is a nice little theoretical conversation. But at the end of the day, as a CFO it doesn't do diddley squat for me. They say everything is bigger in Texas. Well the government budget crises darn sure is. The state has a $28.7 billion shortfall in revenue for the next bienium. They are passing $10 billion of that onto the backs of the schools. So, now I have to figure out how to make things work with 24% less money next year. I have to provide the same amount of students, the same level of services. The very last thing I'm worried about right now is fraud. I have a $3.4 million budget and now face an $850K revenue shortfall. What I really care about is getting revenues up and costs down. I want to close that gap and maintain the financial health of my organization.

This is the real effect of the recession two years ago. It's now showing up in your state and local governments. It will take about another 12-18 months to cycle the rest of the way out. Does that mean I'm going to commit some big fraud to pull this off? NOT ON YOUR LIFE. Integrity has always been and always will be a guiding post of my actions. I've actually got the tools I need to close the gap and then some. I've also got a board who is watching the right metrics to keep me and my fellow C-Staff honest.

That, for me, has always been the bottom line take away. When business gets so corrupt that you need an army of watchers, our nation will go bankrupt.

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Dan
Integrity can be defined as your moral soundness. A test for integrity - Do your actions match your words?

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LionelGA


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Thursday March 24, 2011 7:18 PM

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Sorry if I'm a bit late entering the debate opened by Dilbert...

Personally, I would argue against having 1 team and 1 manager, whether IA or others, tasked with fraud risk management. Reasons are that that manager would be ideally placed to defraud the company, extort fraudsters (instead of stopping their activities), be taken on board or threaten by them. We recently had the District Controller sacked under the charges of taking bribes down here in Bogota a few weeks ago. Hadn’t it been for the recession that made one of the bribe-offering company crash and burn (followed by intense finger-pointing, chest-beating and politic-manoeuvring), we probably still wouldn’t know. Besides, if 1 functional area is given authority over fraud risk management, then everyone else will feel all too happy to stop being concerned, if they ever were…

There was an interesting article in the January / February issue of Fraud Magazine, arguing in favour of multidisciplinary teams (Legal, HR, Security, IA, etc.) with strong upper management backing. Then, the structure and functioning depends on the company (1 work-group or several theme-related workgroups, a fixed number of members or a number of core members and ad hoc reinforcements, direct supervision of management or relative autonomy, etc.).

Regarding responsibility, I would argue that it is shared between those who supervise the individual(s) that committed the fraud, those who manage the functional area that was the target of the fraud and/or those who are in charge of designing / implementing / maintaining / evaluating internal controls in that functional area. That covers a lot more people than IA.

Also I would argue that responsibility would become liability when gross negligence is shown. As long as one can show that he/she did what he/she could to prevent it, there’s a good chance that finger-pointing can be diverted once the incident occurs. All professions have to face that risk. In the security field, for instance, nobody wants to abide by the restrictions the security manager recommends. Then the day of an assault or kidnap arrives and everybody is finger-pointing security. So reducing the risk of liability in case of incident in an environment that is not overly cooperative is an intense back-covering exercise: emails, memos, reports, minutes, etc. As long as one did what he/she could and can prove it, there’s no reason why shared responsibility should become personal liability. And the day those back-covering efforts feel unprofessional or unethical, it’s a sure signal that one should move on to another company or career…

Cheers,
Lionel

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bigkell


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Thursday April 14, 2011 4:25 PM

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"When business gets so corrupt that you need an army of watchers, our nation will go bankrupt." - Plano

Me thinks we are getting real close now.

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Dilbert


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Tuesday April 26, 2011 1:10 PM

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As you may know, the US sentencing commission (USSC) publishes sentencing guidlines (USSG) for Federal crimes. Every quarter the traffic is summarized and posted. The categories of Federal crime number about 30. Fraud has its own category. Federal cases for fraud rank, in number, third, behind immigration and drugs. About 10% of all cases involve fraud.

The current rate of guilty pleas in fraud cases, per annum, is 5,5000. Most of the guilty pleas are from caucasian males of USA citizenship. Interesting facts. Imagine the litigation handle on this bonanza.

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bigkell


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Monday June 27, 2011 7:41 PM

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Damn those caucasians, damn them.

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Mark R. Simmons


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Thursday August 23, 2012 12:56 PM

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I thought I'd give this thread a bump because (a) it contains an excellent exchange of ideas and (b) having had two alleged fraud "scandals" reported ad nauseum by the media immediately prior to and during this thread's active period, and having had some time to reflect, I bring to the table some additional thoughts.


    (1) There will be sanctimonious, self-rightous people ignorant/not privy to all the facts who will nevertheless form and lock in opinions based on their incomplete knowledge.

    (2) Those same sanctimonious, self-rightous people will use (1) to create buzz by using their incomplete knowldge to advance a particular agenda by engaging the ignorant media.

    (3) The ignorant media will pick up on the buzz and increase it (or create the "buzz" if it doesn't already exist) by reporting what someone else has said (rather than engaging in professional journalism and doing any fact-checking or independent investigation). What better way for a lazy reporter to help increase circulation/viewers and advertising revenues, gaining the everlasting gratitude of the publisher/station owner, etc.?

    (4) If something appears in print or is repeated as fact three or more times, it must be true. Every "new" story reported will rehash all the previous stories to date. Thus fiction and semi-fiction become fact amongst the general population.

    (5) When the auditors, investigators, and courts have thoroughly examined all aspects of the allegation and concluded those responsible for (1), (2), (3) and (4) had been wrong in their understanding and perception, the media will drop the reporting but never admit being wrong (after all, they only reported what others were saying); and those with an agenda will cry cover-up and continue to hawk the debunked fictions as "factual".


Under such circumstances, in my opinion,
(a) If an internal audit department has promoted it's primary role to be that of "corporate cop" and "watch dog", it will be publicly castigated, regardless of the actual outcome of the audit and judicial process.

(b) If an internal audit department allows others to define it's primary role to be that of "corporate cop" and "watch dog", it will be publicly castigated, regardless of the actual outcome of the audit and judicial process.

On the other hand, if the internal audit department has been pro-active in promoting its role as an evaluator of the state of risk, governance and control; and has a BoD approved IA charter and corporate anti-fraud policy that places accountability for the prevention and detection of fraud squarely on the shoulders of management (which is where it belongs), the IA department is in a much better position to deal with the ignorance represented by the media's and the general public's misperception of the role of IA in an organization.

I don't think any group formed within an organization to prevent/detect fraud could be successful if the fraud is being perpetrated as corporate policy unless that fraud prevention/detection group were to report directly to the chair of the independent directors on the audit committee. While IA obviously fits that one criteria, it nevertheless should not assume that role unless there is within the IA function a dedicated group of trained and experienced individuals professionally certified to conduct civil and criminal investigations, gather and preserve evidence, and take sworn statements and testimony. I would argue, however, that such a group of specialists should exist outside the IA department, as it's hard enough already for people to have an informed understanding of the role of IA in an organization.

To bigkell's comment:


<< ..If you stay in "auditing," you (at least I think most of you will) question if it is really worth it... That's why I say to the "newbies," give it five years, and then give real strong consideration towards doing something else. >>


I can say absolutely, without equivocation, "Yes, I've had a worthwhile and rewarding career!". The primary reason is that I've consciously avoided working for neanderthal organizations. To the newbies to the profession - remember that the job interview is a two-way street. You are entitled to ask questions that are important to your professional values, growth, and accomplishment. Be proactive in identifying and seeking out those organizations that can meet your expections, and you will greatly improve your chances of a successful and rewarding career providing a service valued by your organization's management. I've been there, done that, and earned the T-shirt and mug.


Edited: Thursday August 23, 2012 at 1:30 PM by Mark R. Simmons

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Dilbert2


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Friday November 02, 2012 12:37 PM

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Dilbert stopped in today to check the scene. It's been a couple of years and much has changed in the forum. Unfortunately, not much has changed in the world of fraud. The SOX law got neutralized without a whimper. Just invite the SEC into your operations and you can operate with impunity. I have yet to find a single fraud case where culpability is directed at IA. Shouldn't it be?

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Mark R. Simmons


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Wednesday December 12, 2012 5:05 PM

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<< ...I have yet to find a single fraud case where culpability is directed at IA. Shouldn't it be? >>


Welcome back, Dilbert. I agree with you - IMO, these forums have changed dramatically. Seems like there are too many looking for easy answers, not many willing to engage in philosophical discourse - a sad turn of events.

Concerning the onus on an auditor when a fraud occurs, these are the issues I see: either (a) the auditor knew and did nothing - the auditor as a co-conspirator; (b) the auditor should have known but didn't - gross incompetence; or (c) the auditor took reasonable steps to identify significant fraud but was unable to do so.

For a criminal prosecution (situation "a"), the authorities must prove "mens rea" - the intent to actively participate in the fraud. Intent can be difficult to establish absent a cooperating witness with first hand knowledge (usually played out by "flipping" one of the conspirators); documentary evidence (incriminating video/audio; e-mails, etc.); or a chain of circumstantial evidence such that the only possible explanation is the guilt of the auditor "beyond a reasonable doubt" to the exclusion of any other reasonable explanation.

For civil litigation (situation "b"), the palintiff need only prove that a preponderence of the evidence would lead a reasonable, impartial person to conclude the auditor did not apply generally accepted practices in the normal course of work, and that another auditor, applying those same generally accepted practices, would have been able to discover the fraud.

If situation "c" occurred, then I don't see how the auditor could, or should, be held accountable.


Edited: Thursday December 13, 2012 at 5:09 PM by Mark R. Simmons

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Billcorton


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Wednesday February 20, 2013 11:41 AM

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About to read the discussions I think they are very useful for any one.

Thanks!!

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Mike_bill

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DISCUSSIONS > FRAUD [ REFRESH ]
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