Fake Bank Confirmation Responses: $6 Million Theft

By Charles Hall | Auditing

The Western District of North Carolina U.S. Attorney’s Office issued a press release on June 17, 2013, detailing how James Shepherd, an investment company owner, defrauded over 100 investors of approximately $6 million. How? By misusing funds and tricking his company’s external auditors with fake bank confirmation responses.

Hiding Theft with Fake Bank Confirmation Responses

The press release states, “Documents indicate that Shepherd built a $2 million residence in Vass, North Carolina, and used investor money to make mortgage payments on the residence.” The U.S. Attorney’s Office said, “For seven years Shepherd used his investment fund as his personal piggy bank and repeatedly lied to his investors who trusted him with their savings.” The release goes on to say the fraud was concealed as “Shepherd sent to investors certified financial statements…accompanied by an Independent Auditor’s Report.” The fraudulent December 31, 2012, financial statement reflected a $6,041,850 cash balance when in reality the fund had less than $100,000. So, how was Shepherd able to get an independent auditor’s report based on fraudulent numbers?

The auditor sent bank confirmations to a P.O. Box address provided by Shepherd. Additionally, the confirmations were sent to the attention of a “Charles Fisher,” a fictitious bank employee.

And who controlled the P.O. Box? Mr. Shepherd.

According to the U.S. Attorney’s Office, Shepherd would receive the bank confirmations, “forge the name Fisher on a fake bank letter” and “send forged bank statements with fake balances” to the auditor. The responses came in the form of both letters and faxes.

So, how were the forged bank statements created? The press release stated that “Shepherd generated the fraudulent bank statements using a version of Adobe Acrobat that enabled him to type false numbers over true bank statements.”

Given the false bank confirmations, how was Mr. Shepherd ever caught? In March 2013 the auditors “insisted on verifying the cash balance of funds’ bank account electronically through the audit confirmation website www.confirmation.com.” Shepherd then refused to give the accountant authority to utilize the site to verify the cash balance. After that, the auditor notified the National Futures Association that his audit opinion could no longer be relied upon.

Given this cautionary tale, how can auditors combat the threat of false bank contact information?

Designing Confirmations 

A while back, my friend James Ulvog brought to my attention the following clarified auditing section about confirmations.

AU-C Section 505.A7 states:

Determining that requests are properly addressed includes verifying the accuracy of the addresses, including testing the validity of some or all of the addresses on the confirmation requests before they are sent out, regardless of the confirmation method used. When a confirmation request is sent by e-mail, the auditor’s determination that the request is being properly directed to the appropriate confirming party may include performing procedures to test the validity of some or all of the e-mail addresses supplied by management.

Auditors often confirm bank accounts using:

1. Letters
2. Emails

Regardless of how an account is confirmed, auditors need to verify the contact information provided by the auditee–at least for some of the confirmations.

Bottom line

Audit standards require that steps be taken to ensure that confirmations are sent to the appropriate persons.

Using Confirmation.com reduces risk related to faulty confirmations. If you don’t use Confirmation.com, then consider checking street addresses by Googling them, or you might call the confirming party–especially for high-risk accounts.

The procedures used to verify mailing addresses, fax numbers, and email addresses should be documented in the auditor’s work papers.

Postscript

On February 11, 2015, Mr. Shepherd was sentenced to 84 months in prison and three years of supervised release. Shepherd pleaded guilty to one count of securities fraud in June 2013.

Inherent Risk: How to Understand

By Charles Hall | Auditing , Risk Assessment

Audit Documentation: Peer Review Finding

By Charles Hall | Auditing

Peer reviewers are saying, “If it’s not documented, it’s not done.” Why? Because standards require sufficient audit documentation in AU-C 230. And if it’s not documented, the peer reviewer can’t give credit. Work papers are your vehicle of communication. 

But what does sufficient documentation mean? What should be in our work papers? How much is necessary? This article answers these questions.

Insufficient Audit Documentation

Insufficient audit documentation has been and continues to be a hot-button peer review issue. And it’s not going away. 

But auditors ask, “What is sufficient documentation?” That’s the problem, isn’t it? The answer is not black and white. We know good documentation when we see it–and poor as well. It’s the middle that is fuzzy. Too often audit files are poor-to-midland. But why? 

First, many times it boils down to profit. Auditors can make more money by doing less work. So, let’s go ahead and state the obvious: Quality documentation takes more time and may lessen profit. But what’s the other choice? Poor work.

Second, the auditor may not understand what the audit requirements are. So, in this case, it’s not motive (make more money), it’s a lack of understanding.

Thirdly, another contributing factor is that firms often bid for work–and low price usually carries the day. Then, when it’s time to do the work, there’s not enough budget (time)–and quality suffers. Corners are cut. Planning is disregarded. Confirmations, walkthroughs, fraud inquiries are omitted. And yes, it’s easier–at least in the short run.

But we all know that quality is the foundation of every good CPA firm. And work papers tell the story–the real story–about a firm’s character. How would you rate your work paper quality? Is it excellent, average, poor? If you put your last audit file on a website and everyone could see it, would you be proud? Or does it need improvement?

Sufficient Audit Documentation According to AU-C 230

Let’s see what constitutes sufficient documentation.

AU-C 230 Audit Documentation defines how auditors are to create audit evidence. It says that an experienced auditor with no connection to the audit should understand:

• Nature, timing, and extent of procedures performed
• Results and evidence obtained
• Significant findings, issues, and professional judgments

While most auditors are familiar with this requirement, the difficulty lies in how to accomplish this. What does it look like? Here are some pointers for complying with AU-C 230. 

Experienced Auditor’s Understanding

Here’s the key: When an experienced auditor reviews the documentation, does she understand the work?

Any good communicator makes it her job to speak or write in an understandable way. The communicator assumes responsibility for clear messages. In creating work papers, we are the communicators. The responsibility for transmitting messages lies with us (the auditors creating work papers).  

A Fog in the Work Papers

So what creates fogginess in work papers? We forget we have an audience. Others will review the audit documentation to understand what was done. As we prepare work papers, we need to think about those who will see our work. All too often, the person creating a work paper understands what he is doing, but the reviewer doesn’t. Why? The message is not clear.

Just because I know why I am doing something does not mean that someone else will. So how can we create clarity?

Creating Clarity

Work papers should include the following:

• A purpose statement (what is the reason for the work paper?)
• The source of the information (who provided it? where did they obtain it and how?)
• An identification of who prepared and reviewed the work paper
• The audit evidence (what was done)
• A conclusion (does the audit evidence support the purpose of the work paper?)

When I make these suggestions, some auditors push back saying, “We’ve already documented some of this information in the audit program.” That may be true, but I am telling you–after reviewing thousands of audit files–the message (what is being done and why) can get lost in the audit program. The reviewer often has a difficult time tieing the work back to the audit program and understanding its purpose and whether the documentation provides sufficient audit evidence.

Remember, the work paper preparer is responsible for clear communication. 

And here’s another thing to consider: You (the work paper preparer) might spend six hours on one document, so you are keenly aware of what you did. The reviewer, on the other hand, might spend five minutes–and she is trying (as quickly as she can) to understand your work.

Help Your Reviewers

To help your reviewers:

1. Tell them what you are doing (purpose statement)
2. Do it (document the test work)
3. Then, tell them how it went (the conclusion)

Now let’s move from proper to improper documentation.

Examples of Poor Work Paper Documentation

So, what does insufficient audit documentation look like? In other words, what are some of the signs that we are not complying with AU-C 230?

Here are examples of poor audit work paper documentation:

• Signing off on audit steps with no supporting work papers (and no explanation on the audit program)
• Placing a document in a file without explaining why (what is its purpose?)
• Not signing off on audit steps
• Failing to reference audit steps to supporting work papers
• Listing a series of numbers on an Excel spreadsheet without explaining their source (where did they come from? who provided them?)
• Not signing off on work papers as a preparer
• Not signing off on work papers as the reviewer
• Failing to place excerpts of key documents in the file (e.g., debt agreement)
• Performing fraud inquiries but not documenting who was interviewed (their name) and when (the date)
• Not documenting the selection of a sample (why and how and the sample size)
• Failing to explain the basis for low inherent risk assessments
• Key bank accounts and debt are not confirmed
• Not documenting the reason for not sending receivable confirmations
• A lack of retrospective reviews
• A failure to document the current year walkthroughs for significant transaction cycles (the file contains a generic description of controls with no evidence of a current year review)
• Not documenting entity-level controls (e.g., tone at the top, management’s risk assessment procedures)
• A failure to document risk assessments
• Low control risk assessments without a test of controls
• A lack of linkage from the risk assessment to the audit plan
• No independence documentation though nonattest services are provided

This list is not comprehensive, but it provides examples to consider. This list is based on my past experiences. Probably the worst offense (at least in my mind) is signing off on an audit program with no support.

Strangely, however, poor work papers are not the result of insufficient documentation, but too much documentation. 

Too Much Audit Documentation

Many CPAs say to me, “I feel like I do too much,” meaning they believe they are auditing more than is necessary. To which I often respond, “I agree.”

In looking at audit files, I see:

• The clutter of unnecessary work papers
• Files received from clients that don’t support the audit opinion
• Unnecessary work performed on extraneous documents

For whatever reason, clients usually provide more information than we request. And then–for some other reason–we retain those documents, even if not needed.

If auditors add purpose statements to each work paper, then they will discover that some work papers are unnecessary. In writing the purpose statement, we might realize it has none. Which is nice–now, we can eliminate it.

One healthy exercise is to pretend we’ve never audited the company and that we have no prior year audit files. Then, with a blank page, we plan the audit. Once done, we compare the new plan to prior year files. If there’s any fat, start cutting. 

The key to eliminating unnecessary work lies in performing the following steps (in the order presented):

1. Perform risk assessment
2. Plan your audit based on the identified risks
3. Perform the audit procedures

Too often, we roll the prior year file forward and rock on. If the prior year file has extraneous audit procedures, we repeat them. This creates waste year after year after year.

Before I close this article, here is one good work paper suggestion from my friend Jim Bennett of Bennett & Associates: transaction area maps. 

Transaction Area Maps

Include transaction area maps in your file. A summary creates organization and makes it easier to find your work papers. It also provides a birds-eye view of what you have done. Here’s an example:

ACCOUNTS RECEIVABLE WORKPAPER MAP

4-02 Audit Program

4-10 Risk Assessment Analyticals

ACCOUNTS RECEIVABLE AGING

4-20 Customer aging report

4-21 AR break-out of intercompany balances

4-23 AR aging tie in to TB

4-24 Review of AR aging

ACCOUNTS RECEIVABLE CONFIRMATIONS

4-50 Planning worksheet – substantive procedures

4-51 AR confirmation reconciliation

4-52 AR confirmation replies

4-60 Allowance for doubtful accounts

4-70 Intercompany balances and sales to significant customers

4-80 Sales analytics

4-90 Sales cut-off testing

4-95 Revenue recognition 606 support and disclosures

Summary

In summary, audit documentation continues to be a significant peer review problem. We can enhance the quality of our work papers by remembering we are not just auditing. We are communicating. It is our responsibility to provide a clear message. We need to do so to comply with AU-C 230, Audit Documentation. 

Additional Guidance

The AICPA also provides some excellent guidance regarding work paper documentation. Download their work paper template; it’s very helpful. 

Also, see my article titled 10 Steps to Better Audit Workpapers.

Audit Risk Assessment: The Why and the How

By Charles Hall | Auditing

Today we look at one of most misunderstood parts of auditing: audit risk assessment.

Are auditors leaving money on the table by avoiding risk assessment? Can inadequate risk assessment lead to peer review findings? This article shows you how to make more money and create higher quality audit documentation. Below you’ll see how to use risk assessment procedures to identify risks of material misstatement. You’ll also learn about the risk of material misstatement formula and how you can use it to plan your engagements.

Audit Risk Assessment as a Friend

Audit risk assessment can be our best friend, particularly if we desire efficiency, effectiveness, and profit—and who doesn’t?

This step, when properly performed, tells us what to do—and what can be omitted. In other words, risk assessment creates efficiency.

So, why do some auditors (intentionally) avoid audit risk assessment? Here are two reasons:

1. We don’t understand it
2. We’re creatures of habit

Too often auditors continue doing the same as last year (commonly referred to as SALY)–no matter what. It’s more comfortable than using risk assessment.

But what if SALY is faulty or inefficient?

Maybe it’s better to assess risk annually and to plan our work accordingly (based on current conditions).

Are We Working Backwards?

The old maxim “Plan your work, work your plan” is true in audits. Audits—according to standards—should flow as follows:

1. Determine the risks of material misstatements (plan our work)
2. Develop a plan to address those risks (plan our work)
3. Perform substantive procedures (work our plan) and tests controls for effectiveness (if planned)
4. Issue an opinion (the result of planning and working)

Auditors sometimes go directly to step 3. and use the prior year audit programs to satisfy step 2. Later, before the opinion is issued, the documentation for step 1. is created “because we have to.”

In other words, we work backwards.

So, is there a better way?

A Better Way to Audit

During the initial planning phase of an audit, an auditor should do the following:

1. Understand the entity and its environment
2. Understand entity-level controls
3. Understand the transaction level controls
4. Use preliminary analytical procedures to identify risk
5. Perform fraud risk analysis
6. Assess risk

While we may not complete these steps in this order, we do need to perform our risk assessment first (1.-4.) and then assess risk.

Okay, so what procedures should we use?

Audit Risk Assessment Procedures

AU-C 315.06 states:

The risk assessment procedures should include the following:

• Inquiries of management, appropriate individuals within the internal audit function (if such function exists), others within the entity who, in the auditor’s professional judgment, may have information that is likely to assist in identifying risks of material misstatement due to fraud or error
• Analytical procedures
• Observation and inspection

I like to think of risk assessment procedures as detective tools used to sift through information and identify risk.

 

Just as a good detective uses fingerprints, lab results, and photographs to paint a picture, we are doing the same.

First, we need to understand the entity and its environment.

Understand the Entity and Its Environment

The audit standards require that we understand the entity and its environment.

I like to start by asking management this question: “If you had a magic wand that you could wave over the business and fix one problem, what would it be?”

The answer tells me a great deal about the entity’s risk.

I want to know what the owners and management think and feel. Every business leader worries about something. And understanding fear illuminates risk.

Think of risks as threats to objectives. Your client’s fears tell you what the objectives are–and the threats. 

To understand the entity and its related threats, ask questions such as:

• How is the industry faring?
• Are there any new competitive pressures or opportunities?
• Have key vendor relationships changed?
• Can the company obtain necessary knowledge or products?
• Are there pricing pressures?
• How strong is the company’s cash flow?
• Has the company met its debt obligations?
• Is the company increasing in market share?
• Who are your key personnel and why are they important?
• What is the company’s strategy?
• Does the company have any related party transactions?

As with all risks, we respond based on severity. The higher the risk, the greater the response.

Audit standards require that we respond to risks at these levels:

• Financial statement level
• Transaction level

Responses to risk at the financial statement level are general, such as appointing more experienced staff for complex engagements.

Responses to risk at the transaction level are more specific such as a search for unrecorded liabilities.

But before we determine responses, we must first understand the entity’s controls.

Understand Transaction Level Controls

We must do more than just understand transaction flows (e.g., receipts are deposited in a particular bank account). We need to understand the related controls (e.g., Who enters the receipt in the general ledger? Who reviews receipting activity?).

So, as we perform walkthroughs or other risk assessment procedures, we gain an understanding of the transaction cycle, but—more importantly—we gain an understanding of controls. Without appropriate controls, the risk of material misstatement increases.

AU-C 315.14 requires that auditors evaluate the design of their client’s controls and to determine whether they have been implemented. However, AICPA Peer Review Program statistics indicate that many auditors do not meet this requirement. In fact, noncompliance in this area is nearly twice as high as any other requirement of AU-C 315 – Understanding the Entity and Its Environment and Assessing the Risk of Material Misstatement.

Some auditors excuse themselves from this audit requirement saying, “the entity has no controls.”  

All entities have some level of controls. For example, signatures on checks are restricted to certain person. Additionally, someone usually reviews the financial statements. And we could go on.

The AICPA has developed a practice aid that you’ll find handy in identifying internal controls in small entities.

The use of walkthroughs is probably the best way to understand internal controls.

Sample Walkthrough Questions 

As you perform your walkthroughs, ask questions such as:

• Who signs checks?
• Who has access to checks (or electronic payment ability)?
• Who approves payments?
• Who initiates purchases?
• Who can open and close bank accounts?
• Who posts payments?
• What software is used? Does it provide an adequate audit trail? Is the data protected? Are passwords used?
• Who receives and opens bank statements? Does anyone have online access? Are cleared checks reviewed for appropriateness?
• Who reconciles the bank statement? How quickly? Does a second person review the bank reconciliation?
• Who creates expense reports and who reviews them?
• Who bills clients? In what form (paper or electronic)?
• Who opens the mail?
• Who receipts monies?
• Are there electronic payments?
• Who receives cash onsite and where?
• Who has credit cards? What are the spending limits?
• Who makes deposits (and how)?
• Who keys the receipts into the software?
• What revenue reports are created and reviewed? Who reviews them?
• Who creates the monthly financial statements? Who receives them?
• Are there any outside parties that receive financial statements? Who are they?

Understanding the company’s controls illuminates risk. The company’s goal is to create financial statements without material misstatement. And a lack of controls threatens this objective.

So, as we perform walkthroughs, we ask the payables clerk (for example) certain questions. And—as we do—we are also making observations about the segregation of duties. Also, we are inspecting certain documents such as purchase orders.

This combination of inquiries, observations, and inspections allows us to understand where the risk of material misstatement is highest.

In a AICPA study regarding risk assessment deficiencies, 40% of the identified violations related to a failure to gain an understanding of internal controls.

Need help with risk assessment walkthroughs?

See my article Audit Walkthroughs: The What, Why, How, and When.

Get my new book:

Audit Risk Assessment Made Easy

Click here to see it on Amazon.

Another significant risk identification tool is the use of planning analytics.

Preliminary Analytical Procedures

Use planning analytics to shine the light on risks. How? I like to use:

• Multiple-year comparisons of key numbers (at least three years, if possible)
• Key ratios

In creating preliminary analytics, use management’s metrics. If certain numbers are important to the company, they should be to us (the auditors) as well—there’s a reason the board or the owners are reviewing particular numbers so closely. (When you read the minutes, ask for a sample monthly financial report; then you’ll know what is most important to management and those charged with governance.)

You may wonder if you can create planning analytics for first-year businesses. Yes, you can. Compare monthly or quarterly numbers. Or you might compute and compare ratios (e.g., gross profit margin) with industry benchmarks. (For more information about, see my preliminary analytics post.)

Sometimes, unexplained variations in the numbers are fraud signals.

Identify Fraud Risks

In every audit, inquire about the existence of theft. In performing walkthroughs, look for control weaknesses that might allow fraud to occur. Ask if any theft has occurred. If yes, how?

Also, we should plan procedures related to:

• Management override of controls, and
• The intentional overstatement of revenues

My next post—in The Why and How of Auditing series—addresses fraud, so this is all I will say about theft, for now. Sometimes the greater risk is not fraud but errors.

Same Old Errors

Have you ever noticed that some clients make the same mistakes—every year? (Johnny–the controller–has worked there for the last twenty years, and he makes the same mistakes every year. Sound familiar?) In the risk assessment process, we are looking for the risk of material misstatement whether by intention (fraud) or by error (accident).

One way to identify potential misstatements due to error is to maintain a summary of the larger audit entries you’ve made over the last three years. If your client tends to make the same mistakes, you’ll know where to look.

Now it’s time to pull the above together.

Creating the Risk Picture

Once all of the risk assessment procedures are completed, we synthesize the disparate pieces of information into a composite image.

What are we bringing together? Here are examples:

• Control weaknesses
• Unexpected variances in significant numbers
• Entity risk characteristics (e.g., level of competition)
• Large related-party transactions
• Occurrences of theft

Armed with this risk picture, we can now create our audit strategy and audit plan (also called an audit program). Focus these plans on the higher risk areas.

How can we determine where risk is highest? Use the risk of material misstatement (RMM) formula.

Assess the Risk of Material Misstatement

Understanding the risk of material misstatement formula is key to identifying high-risk areas.

What is the risk of material misstatement formula?

Put simply, it is:

Risk of Material Misstatement = Inherent Risk X Control Risk

Using the RMM formula, we are assessing risk at the assertion level. While audit standards don’t require a separate assessment of inherent risk and control risk, consider doing so anyway. I think it provides a better representation of your risk of material misstatement.

Here’s a short video about assessing inherent risk.

And another video regarding control risk assessment.

Once you have completed the risk assessment process, control risk can be assessed at high–simply as an efficiency decision. See my article Assessing Audit Control Risk at High and Saving Time.

The Input and Output

The inputs in audit planning include all of the above audit risk assessment procedures.

The outputs (sometimes called linkage) of the audit risk assessment process are:

• Audit strategy
• Audit plan (audit programs)

We tailor the strategy and plan based on the risks..

In a nutshell, we identify risks and respond to them.

Next in the Audit Series

In my next post, we’ll take a look at Auditing for Fraud: The Why and How.

Audit Risk Assessment Made Easy – My New Book

My new book titled Audit Risk Assessment Made Easy is now available on Amazon. I’ve been working on this for over a year and a half. I think you’ll find it to be a valuable resource in understanding, documenting, planning, and performing risk assessment procedures.

 

Auditing for Fraud: The Why and How

By Charles Hall | Auditing , Fraud

Auditing for fraud is important, but some auditors ignore this duty. Even so, fraud risk is often present. 

So what is an auditor’s responsibility for detecting fraud? Today, I answer that question in light of generally accepted auditing standards in the United States. We’ll look specifically at AU-C 240, Consideration of Fraud in a Financial Statement Audit.

Here’s an overview of this article:

• Auditor’s responsibility for detecting fraud
• Turning a blind eye to fraud
• Signs of auditor disregard for fraud
• Incentives for fraud
• Discovering fraud opportunities
• Inquiries required by audit standards
• The accounting story and big bad wolves
• Documenting control weaknesses
• Brainstorming and planning your response to fraud risk 

Auditor’s Responsibility for Detecting Fraud – AU-C 240

I still hear auditors say, “We are not responsible for detecting fraud.” But are we not? The detection of material misstatements whether caused by error or fraud is the heart and soul of an audit. So writing off our responsibility for fraud is not an option. We must plan to look for material fraud.

Audits will not, however, detect every material misstatement—even if the audit is properly planned and conducted. Audits are designed to provide reasonable assurance, not perfect assurance. Some material frauds will not be detected. Why? First, an auditor’s time is limited. He can’t audit forever. Second, complex systems make it extremely difficult to discover fraud. Third, the number of potential fraud schemes (there are thousands) makes it challenging to consider all possibilities. And, finally, some frauds are so well hidden that auditors won’t detect them.

Even so, auditors should not turn a blind eye to fraud.

Turning a Blind Eye to Fraud

Why do auditors not detect fraud?

• We don’t look for fraud because we don’t understand it
• We disregard the importance of walkthroughs
• We believe that auditing the balance sheet is enough

Think of these reasons as an attitude—a poor one—regarding fraud. This disposition manifests itself in the audit file with signs of disregard for fraud.

Signs of Auditor Disregard for Fraud

A disregard for fraud appears in the following ways:

• Asking just one or two questions about fraud
• Limiting our inquiries to as few people as possible (maybe even just one)
• Discounting the potential effects of fraud (after known theft occurs)
• Not performing walkthroughs
• We don’t conduct brainstorming sessions and window-dress related documentation
• Our files reflect no responses to brainstorming and risk assessment procedures
• Our files contain vague responses to the brainstorming and risk assessment (e.g., “no means for fraud to occur; see standard audit program” or “company employees are ethical; extended procedures are not needed”)
• The audit program doesn’t change though control weaknesses are noted

In effect, auditors—at least some—dismiss the possibility of fraud, relying on a balance sheet approach.

So how can we understand fraud risks and respond to them? First, let’s look at fraud incentives.

Incentives for Fraud

The reasons for theft vary by each organization, depending on the dynamics of the business and people who work there. Fraudsters can enrich themselves indirectly (by cooking the books) or directly (by stealing).

Fraud comes in two flavors:

1. Cooking the books (intentionally altering numbers)
2. Theft

Cooking the Books

Start your fraud risk assessment process by asking, “Are there any incentives to manipulate the financial statement numbers.” For example, does the company provide bonuses or promote employees based on profit or other metrics? If yes, an employee can indirectly steal by playing with the numbers. Think about it. The chief financial officer can inflate profits with just one journal entry—not hard to do. While false financial statements is a threat, the more common fraud is theft.

Theft

If employees don’t receive compensation for reaching specific financial targets, they may enrich themselves directly through theft. But employees can only steal if the opportunity is present. And where does opportunity come from? Weak internal controls. So, it’s imperative that auditors understand the accounting system and—more importantly—related controls. 

Discovering Fraud Opportunities

My go-to procedure in gaining an understanding of the accounting system and controls is walkthroughs.  Since accounting systems are varied, and there are no “forms” (practice aids) that capture all processes, walkthroughs can be challenging. So, we may have to “roll up our sleeves,” and “get in the trenches.” 

For most small businesses, performing a walkthrough is not that hard. Pick a transaction cycle; start at the beginning and follow the transaction to the end. Ask questions and note who does what. Inspect the related documents. As you do, ask yourself two questions:

1. What can go wrong?
2. Will existing control weakness allow material misstatements?

In more complex companies, break the transaction cycle into pieces. You know the old question, “How do you eat an elephant?” And the answer, “One bite at a time.” So, the process for understanding a smaller company works for a larger one. You just break it down and allow more time.

Discovering fraud opportunities requires the use of risk assessment procedures such as observations of controls, inspections of documents and inquiries. Of the three, the more commonly used is inquiries.

Inquiries Required by Audit Standards

Audit Standards (AU-C 240) state that we should inquire of management regarding:

• Management’s assessment of the risk that the financial statements may be materially misstated due to fraud, including the nature, extent, and frequency of such assessments
• Management’s process for identifying, responding to, and monitoring the risks of fraud in the entity, including any specific risks of fraud that management has identified or that have been brought to its attention, or classes of transactions, account balances, or disclosures for which a risk of fraud is likely to exist
• Management’s communication, if any, to those charged with governance regarding its processes for identifying and responding to the risks of fraud in the entity
• Management’s communication, if any, to employees regarding its views on business practices and ethical behavior
• The auditor should make inquiries of management, and others within the entity as appropriate, to determine whether they know of any actual, suspected, or alleged fraud affecting the entity
• For those entities that have an internal audit function, the auditor should make inquiries of appropriate individuals within the internal audit function to obtain their views about the risks of fraud; determine whether they have knowledge of any actual, suspected, or alleged fraud affecting the entity; whether they have performed any procedures to identify or detect fraud during the year; and whether management has satisfactorily responded to any findings resulting from these procedures

Notice that AU-C 240 requires the auditor to ask management about its procedures for identifying and responding to the risk of fraud. If management has no method of detecting fraud, might this be an indicator of a control weakness? Yes. What are the roles of management and outside auditors regarding fraud?

• Management develops control systems to lessen the risk of fraud. 
• Auditors review the accounting system to see if fraud-prevention procedures are designed and operating appropriately.

So, the company creates the accounting system, and the auditor gains an understanding of the same. As auditors gain an understanding of the accounting system and controls, we put together the pieces of a story.

The Accounting Story and Big Bad Wolves

Think of the accounting system as a story. Our job is to understand the narrative of that story. As we describe the accounting system in our work papers, we may find missing pieces. Controls may be inadequate. When they are, we ask more questions to make the story complete.

The purpose of writing the storyline is to identify any “big, bad wolves.”

The threats in our childhood stories were easy to recognize. The wolves were hard to miss. Not so in walkthroughs. It is only in connecting the dots—the workflow and controls—that the wolves materialize.

So, how long should the story be? That depends on the size of the organization. Scale your documentation. If the transaction cycle is simple, the documentation should be simple. If the cycle is complex, provide more details. By focusing on control weaknesses that allow material misstatements, you’ll avoid distracting details.

But what if control weaknesses are noted?

Documenting Control Weaknesses

I summarize the internal control strengths and weaknesses within the description of the system and controls and highlight the wording “Control weakness.” For example:

Control weakness: The accounts payable clerk (Judy Jones) can add new vendors and can print checks with digital signatures. In effect, she can create a new vendor and have a check sent to that provider without anyone else’s involvement.

Highlighting weaknesses makes them more prominent. Then I can use the identified fraud opportunities to brainstorm about how theft might occur and to develop my responses to the threats.

Brainstorming and Planning Your Responses 

Now, you are ready to brainstorm about how fraud might occur and to plan your audit responses.

The risk assessment procedures provide the fodder for the brainstorming session. 

Armed with knowledge about the company, the industry, fraud incentives, and the control weaknesses, we are ready to be creative. 

In what way are we to be creative? Think like a thief. By thinking like a fraudster, we unearth theft schemes. Why? So we can audit those possibilities. This is the reason for risk assessment procedures in the first place.

[Tweet “We think like a thief. By thinking like a fraudster, we unearth theft schemes.”]

What we discover in risk assessment informs the audit plan. Now we are ready to perform our fraud risk assessment. With the information gained in from the risk assessment procedures, we know where the risks are. If, for example, there is a risk that fictitious vendors are present, we might assess the risk of material misstatement at high for the expense occurrence assertion. (Our risks of material misstatement should be assessed at the assertion level.) Then we plan our response which might be testing new vendors added to determine if they are legitimate. So the fraud risk assessment occurs after we perform our risk assessment procedures. This tells us where the risks of material misstatement are. 

The Auditor’s Responsibility for Detecting Fraud – AU-C 240

In conclusion, I started this post saying I’d answer the question, “What is an auditor’s responsibility for detecting fraud?”

Hopefully, you now better understand fraud procedures. But to understand the purpose of them, look at a standard audit opinion:

The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the consolidated financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the entity’s preparation and fair presentation of the consolidated financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control. Accordingly, we express no such opinion.

The purpose of fraud risk assessments is not to opine on internal control systems or to discover every fraud. It is to assist the auditor in determining where material misstatements—due to fraud—might occur.

Additionally, even well-performed audits will not detect all material fraud. As we saw above, some frauds are extremely difficult to detect. Audits are designed to provide reasonable assurance, not perfect assurance. The standard audit opinion states:

The Why and How of Auditing: A Blog Series About Audit Basics

Check out my series of posts: The Why and How of Auditing?

You’ll see how to audit cash, receivables/revenues, payables/expenses, investments, and other transaction cycles. You’ll also see how to perform risk assessment procedures before you plan your further audit procedures. 

Also, see my book The Why and How of Auditing on Amazon.