The Anti-Fraud Toolkit
The Anti-Fraud Toolkit
Prevent, Detect and Eliminate Fraud
Let’s be honest.
The simple fact that you are considering
The Anti-Fraud Toolkit says a lot.
It tells me that you are a special person. A true leader in the anti-fraud effort – regardless of your position in the organization chart, your length of service in the business environment, or what your technical specialty areas might be. You are unique in your intention to attack fraud risks – and to do something about it.
My Purpose in Creating The Anti-Fraud Toolkit
A few days ago, a friend and business associate asked me, “Why did you create The Anti-Fraud Toolkit? What exactly are you trying to accomplish?” Great questions from a great friend.
To give you a bit of context about my perspective before you go any further, here’s the answer.
I’ve been a Certified Public Accountant, auditor, corporate leader, consultant, and professional speaker for a total of 35 years. For most of that time, my sub-specialty has been in the technical areas of fraud prevention, quick detection and effective incident handling.
In my live anti-fraud training events – over 1,500 such events so far – there is a pattern to the questions that get asked.
- “What should we be doing to manage our business fraud risks?
- “What are the most important steps for us to take organizationally to fight wrongdoing and fraud?”
- “As the CEO, what should I expect of my team and how and when should I say it?”
- “What key infrastructure pieces do we need to have in place to increase our chances of fraud prevention – policies, controls, even daily behaviors? What works best for busy people with many other priorities?”
- “Why do our anti-fraud controls seem to fail over time – allowing internal and third-party wrongdoers to get us?”
Once again – great questions by folks like you who are seriously interested in fighting fraud right where they work every day.
What I’ve attempted to do through The Toolkit is to answer these and other common questions by drawing on my years of witnessing the best work of my great consulting and training clients.
My objective is to share a framework, system, structure or plan of attack
that increases (potentially dramatically!) the Probability
that you will create and maintain a business environment where:
The likelihood of fraud and other wrongdoing is minimized
Incidents that do occur are detected promptly
Detected incidents are handled efficiently and effectively
That’s it. One broad objective and three short targets. And here’s how we’ll do it.
Instructions for Using The Anti-Fraud Toolkit
The Toolkit was created as a comprehensive self-guided coaching program. It is a general battle plan against your fraud risks and exposures. But it is a plan that must be modified to your objectives and your organization.
IT IS YOUR JOB TO MODIFY AND TAILOR THE IDEAS IN THE TOOLKIT
TO THE SPECIFIC EXPOSURES AND CHALLENGES
IN YOUR UNIQUE BUSINESS ENVIRONMENT.
The Anti-Fraud Toolkit Structure
In 9 modules, more than 6 hours of recorded video lecture, over 250 PowerPoint slides, and many practice ‘To-Do’ action items and practice tools (downloadable in each module), you’ll get the step-by-step, turn-by-turn instructions you need to take action right now. Short on theory and long on action steps, the lectures and tools in each module will enable you to take confident, effective action by building on the successes I’ve witnessed in my clients all of these years.
You’ll also get guidance on what not to do in the fight against fraud – to help you avoid common mistakes, focus your precious limited energy, and avoid undermining your own efforts through inefficiency and uncertainly!
Here’s exactly what we’ll cover.
Module 1 – Introduction
This module gives you a comprehensive overview of the fundamentals of effective Anti-Fraud Campaigns. It defines key terms and concepts to provide a common context for a wide audience of Toolkit users and lays down the foundation for the remaining modules. Don’t be fooled by the ‘Introduction’ title to this module. You are strongly encouraged to review Module 1- Introduction in detail as well as review the entire video lecture before proceeding to the other eight modules.
Module 2 – Leadership
The message of this module is simple: Nothing will happen without strong, visible, vocal executive leadership. And by ‘executive’ I mean the Chief Executive Officer – whatever their title may be in your organization.
The #1 executive must lead the anti-fraud charge. They must be willing to speak publicly and enthusiastically. They must provide you with the resources you need to initiate and sustain your anti-fraud initiative. They must embrace that fighting wrongdoing and fraud is a campaign waged over time with their continued support. It is not a once and done event that receives encouraging words but no meaningful follow-though. Your #1 job as an anti-fraud leader is to recruit and secure meaningful executive leadership support. Module 2 – Leadership will give you the specifics details of what you will need from the executive management team.
Module 3 – Core Infrastructure
Once you have secured the support of your top leaders, Module 3 will lead you through the general infrastructure components you’ll need in place. Examples include:
- Ethical operating practices (of course!)
- Useful Codes of Conduct that provides detail behavioral guidance in real-world business situations
- The critical Policy on Fraud Responsibilities
- Work-group fraud risk brainstorming
- A safe environment for those seeking guidance or reporting suspicions
And of course, you’ll need effective anti-fraud internal controls and associated daily behaviors. Anti-fraud controls and behaviors are so important that they will be the subjects of their own modules – specifically Modules 4 and 5.
Module 4 – Anti-Fraud Controls
Module 4 – Anti-Fraud Controls is very straight forward. You must have formal control policies and procedures in place that deter fraud and make it more likely to be promptly detected should deterrence efforts fail. Examples include policies covering:
- Use of assets & information
- Limiting physical access
- Segregation of incompatible duties
- Appropriate transaction review and authorization
- Proper documentation
- Monitoring and meaningful results analysis
- Independent reviews
There’s a pretty good chance that a lot of attention has already been placed on your anti-fraud controls. And there are several outstanding controls models in general business use (for example, the COSO Internal Control Integrated Framework www.COSO.org). So Module 4 will stress the tweaking you’ll likely need to address to shore up any weaknesses, soft-spots and blind-spots in the organization rather than a step-by-step discussion of how to start building controls.
Module 5 – Anti-Fraud Behaviors
Module 5 addresses the need for effective human execution of anti-fraud control procedures. This concept is extremely important. Here’s why.
I’ve been keeping score for the last 15 years on all fraud cases I’ve personally handled for clients in addition to specific cases where I had a consulting or advisory role. What I’ve found is in over 90 percent of these cases the design of control procedures was generally adequate, but the human execution of those controls failed. That’s right: 90% in my own experience.
Module 5 walks you through why this happens (including 10 reasons why controls break down) and what you and your anti-fraud leadership can do about it.
Module 6 – Training
In Module 3’s Policy on Fraud Responsibilities, you’ll formally recruit the help of every employee, manager and executive to your anti-fraud efforts. In Module 5, we stressed the importance of daily anti-fraud behaviors that make controls come to life. Here is Module 6 we wrap these concepts together and teach the Anti-Fraud Skills that everyone must have to know what fraud looks like, when they should speak up, and how they can do so safely.
Since substantially all employees come to the job on day one without a deep understanding of fraud schemes and red flags, this training is needed to close the gap between anti-fraud expectations and action.
Module 7 – Special Challenges
You’ll experience measurable success against a broad array of fraud risks by implementing the ideas in Modules 1 through 6. But there are several specific fraud risks that demand an even greater level of attention. They are addressed in Module 7 – Special Challenges, and include the inherent risks and special challenges of:
- Intentional override of controls by managers and executives
- Third-party relationships, such as joint-venture partners, suppliers and contractors
- Limited staffing in small businesses and many not-for-profits
- Limited time to check details in any organization
Module 8 – Fraud Incident Response
Despite best efforts to prevent or at least deter fraud, some incidents will slip through anyway. That’s just an unfortunate fact of business life. So when these cases surface, we need to be ready to handle them efficiently and effectively. Just like a professional firefighter, you and your leaders need to be completely prepared before the alarm sounds. Module 8 provides a plan of what to consider in advance of fraud detection so that you can be ready – even if it never happens to you.
Module 9- Summary
Module 9 wraps it all together and also introduces several new anti-fraud ideas not covered in the other modules. After you have worked through all of The Toolkit modules and materials, look to attachments for Module 9 for a master list of action suggestions that you can compare to the list you developed as you work through each module.
Time to Get Started – And How I Can Help
The Anti-Fraud Toolkit was designed as a self-paced guide, you really aren’t alone in your work.
I’ll do my best to answer your questions, clarify points made in The Toolkit, or discuss how I might assist you more formally through my anti-fraud consulting and training services. All you have to do is ask and we can see what would work best for you.
Now – get started, make a difference, and enjoy the praise and positive feedback that will certainly be yours as you move your own Anti-Fraud Campaign forward.