Audit Risk Assessment: The Why and the How

By Charles Hall | Auditing

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.

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.

How to Identify and Manage Audit Stakeholders

By Harry Hall | Auditing

Some auditors perform the same procedures year after year. These individuals know the drill. Their thought is: been there; done that. But, before we start the engagement, we need to identify the audit stakeholders. 

Imagine a partner or an in-charge (i.e., project manager) with this attitude. He does little analysis and makes some costly stakeholder mistakes. As the audit team starts the audit, they encounter surprises:

• Changes in the client stakeholders – accounting personnel and management
• Changes in accounting systems and reporting
• Changes in business processes
• Changes in third-party vendors
• Changes in the client’s external stakeholders

Furthermore, imagine the team returning to your office after the initial work is done. The team has every intention of continuing the audit; however, some members are being pulled for urgent work on a different audit.

These changes create audit risks–both the risk that the team will issue an unmodified opinion when it’s not merited and the risk that engagement profit will diminish. Given these unanticipated factors, the audit will likely take longer and cost more than planned. And here’s another potential wrinkle: Powerful, influential stakeholders may insist on new deliverables late in the project.

So how can you mitigate these risks early in your audit?

Perform a stakeholder analysis.

“Prior Proper Planning Prevents Poor Performance.” – Brian Tracy

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Preliminary Analytical Procedures: Audits

By Charles Hall | Auditing

Assessing Audit Control Risk at High

By Charles Hall | Auditing

At times, auditors errantly assess control risk at less than high. Why? Because the (lower) assessment is not supported by a test of controls.

So can you assess control risk at high without testing controls? Yes–and you may want to. Below you’ll see why.

We have been told that “you can’t default to maximum risk.” While we can’t default to maximum (the old pre-risk-assessment standards term), we can–and in many audits should–assess control risk at high (the present risk assessment term).

Assessing Control Risk at High

First, the auditor should determine the existence and location of risks–the purpose of risk assessment procedures. Once risk assessment procedures (walkthroughs, inquiries, analytics, etc.) are performed, we know more about what the risks are and where they are. Then—if controls are appropriately designed and working—we can assess control risk (CR) at whatever level we desire. If CR is assessed at below high, then controls must be tested to support the lower risk assessment.

The Efficiency Decision

At this point, our assessment of control risk becomes a question of efficiency. We can:

1. Assess control risk at high and not perform additional tests of controls, or
2. Assess control risk at low to moderate and test the operating effectiveness of controls

The salient question is, “Which option is most efficient?”

Here’s a video that will help you understand when it’s best to use a test of details or test controls for effectiveness.

Risk Assessment Procedures

Risk assessment procedures, such as walkthroughs, generally are not sufficient to support a low to moderate control risk assessment. A walkthrough (often a test of one transaction) allows us to see if appropriate controls are in place. They don’t, however, tell us if the controls are consistently working.

Testing Controls

AU-C Section 330.08 states: The auditor should design and perform tests of controls to obtain sufficient appropriate audit evidence about the operating effectiveness of relevant controls if the auditor’s assessment of risks of material misstatement…includes an expectation that the controls are operating effectively (that is, the auditor intends to rely on the operating effectiveness of controls in determining…substantive procedures).

A test of one transaction–often performed in walkthroughs–generally is not considered “sufficient appropriate audit evidence” to assess control risk at less than high.

Back to the Efficiency Issue

Now, let’s look at audit planning decisions.

To test and rely on controls, the auditor should examine more transactions. We might, for example, test forty disbursements for proper purchase orders. If the control is working, then we can assess control risk at low to moderate and decrease our substantive work. We could, for example, test fewer additions to plant, property and equipment.

If it takes longer to test controls (e.g., the forty purchase orders) than to perform substantive tests (e.g., vouching invoice support for additions to plant, property and equipment), then it makes more sense to assess control risk at high and perform substantive procedures. And we should do just that–if we desire to make a higher profit on the engagement (and I’m betting you do).

For example, if it takes six hours to test forty transactions for appropriate purchase orders, and it takes four hours to vouch all additions to plant, property, and equipment, then we should assess control risk at high and not perform the test of controls. We should perform the substantive procedure of vouching all significant additions to plant, property, and equipment.

Reducing Substantive Tests (Without Testing Controls)

Can we assess the risk of material misstatement (RMM) at low to moderate without testing controls?

Yes.

If the inherent risk (IR) is low to moderate, then our combined risk of material misstatement can easily be low to moderate. (Let me encourage you to assess risk at the assertion level and not at the transaction level.)

For example, a low inherent risk and a high control risk can yield a low to moderate RMM. In an equation it looks like this:

 IR         CR         RMM            Audit Approach
Low X High = Moderate              Basic

This approach produces a moderate RMM without testing controls. A moderate RMM supports a basic approach, and a basic approach means we are performing fewer substantive tests (a high RMM means the auditor will perform more substantive tests).

In short, many times inherent risk is low to moderate. If you combine a low to moderate inherent risk with a high control risk, you can assess RMM at low to moderate. This low to moderate RMM comports with a basic audit approach. Continuing with our plant, property and equipment example from above, you can–with the low to moderate RMM–test fewer asset purchases. And no test of controls is necessary.

This approach–assessing control risk at high after performing risk assessment procedures–often creates greater audit efficiency and is compliant with audit standards. Alternatively, we should assess control risk below high and test controls if this approach takes less time.

Conclusion

I started this post by saying we sometimes errantly assess control risk. By this, I mean we sometimes assess control risk at low to moderate without a sufficient test of controls. If we assess control risk at less than high, then we must test controls.

What are your thoughts about assessing control risk?

See my article about the audit risk model for more information about risks of material misstatement.