In this chapter, one of the major issues examined is the concept
of fraud. Fraud can be defined in many ways, but
for the purposes of this course we define it as the act of
intentionally deceiving a person or organization or misrepresenting
a relationship in order to secure some type of benefit, either
financial or nonfinancial. We initially discuss it in a broader
sense and then concentrate on the issue of fraud as it relates to
the accounting environment and profession.
Workplace fraud is typically detected by anonymous tips or by
accident, so many companies use the fraud triangle to help in the
analysis of workplace fraud. Donald Cressey, an American
criminologist and sociologist, developed the fraud
triangle to help explain why law-abiding citizens
sometimes commit serious workplace-related crimes. He determined
that people who embezzled money from banks were typically otherwise
law-abiding citizens who came into a “non-sharable financial
problem.” A non-sharable financial problem is when a trusted
individual has a financial issue or problem that he or she feels
can't be shared. However, it is felt that the problem can be
alleviated by surreptitiously violating the position of trust
through some type of illegal response, such as embezzlement or
other forms of misappropriation. The guilty party is typically able
to rationalize the illegal action. Although they committed serious
financial crimes, for many of them, it was their first offense.
The fraud triangle consists of three elements: incentive,
opportunity, and rationalization (Figure
8.2). When an employee commits fraud, the elements of the fraud
triangle provide assistance in understanding the employee’s methods
and rationale. Each of the elements needs to be present for
workplace fraud to occur.
Figure 8.2 Fraud Triangle. The three components
identified in the fraud triangle are perceived opportunity,
incentive, and rationalization. (attribution: Copyright Rice
University, OpenStax, under CC BY-NC-SA 4.0 license)
Perceived opportunity is when a potential fraudster thinks that
the internal controls are weak or sees a way to override them. This
is the area in which an accountant has the greatest ability to
mitigate fraud, as the accountant can review and test internal
controls to locate weaknesses. After identifying a weak,
circumvented, or nonexistent internal control, management, along
with the accountant, can implement stronger internal controls.
Rationalization is a way for the potential fraudster to
internalize the concept that the fraudulent actions are acceptable.
A typical fraudster finds ways to personally justify his or her
illegal and unethical behavior. Using rationalization as a tool to
locate or combat fraud is difficult, because the outward signs may
be difficult to recognize.
Incentive (or pressure) is another element necessary for a
person to commit fraud. The different types of pressure are
typically found in (1) vices, such as gambling or drug use; (2)
financial pressures, such as greed or living beyond their means;
(3) work pressure, such as being unhappy with a job; and (4) other
pressures, such as the desire to appear successful. Pressure may be
more recognizable than rationalization, for instance, when
coworkers seem to be living beyond their means or complain that
they want to get even with their employer because of low pay or
other perceived slights.
Typically, all three elements of the triangle must be in place
for an employee to commit fraud, but companies usually focus on the
opportunity aspect of mitigating fraud because, they can develop
internal controls to manage the risk. The rationalization and
pressure to commit fraud are harder to understand and identify.
Many organizations may recognize that an employee may be under
pressure, but many times the signs of pressure are missed.
Virtually all types of businesses can fall victim to fraudulent
behavior. For example, there have been scams involving grain silos
in Texas inflating their inventory, the sale of mixed oils labeled
as olive oil across the globe, and the tens of billions of dollars
that Bernie Madoff swindled out of investors and
not-for-profits.
To demonstrate how a fraud can occur, let’s examine a sample
case in a little more detail. In 2015, a long-term employee of the
SCICAP Federal Credit Union in
Iowa was convicted of stealing over $2.7 million in cash over a
37-year period. The employee maintained two sets of financial
records: one that provided customers with correct information as to
how much money they had on deposit within their account, and a
second set of books that, through a complex set of transactions,
moved money out of customer accounts and into the employee’s
account as well as those of members of her family. To ensure that
no other employee within the small credit union would have access
to the duplicate set of books, the employee never took a vacation
over the 37-year period, and she was the only employee with
password-protected access to the system where the electronic
records were stored.
There were, at least, two obvious violations of solid internal
control principles in this case. The first was the failure to
require more than one person to have access to the records, which
the employee was able to maintain by not taking a vacation.
Allowing the employee to not share the password-protected access
was a second violation. If more than one employee had access to the
system, the felonious employee probably would have been caught much
earlier. What other potential failures in the internal control
system might have been present? How does this example of fraud
exhibit the three components of the fraud triangle?
Unfortunately, this is one of many examples that occur on a
daily basis. In almost any city on almost any day, there are
articles in local newspapers about a theft from a company by its
employees. Although these thefts can involve assets such as
inventory, most often, employee theft involves cash that the
employee has access to as part of his or her day-to-day job.
LINK TO LEARNING
Small businesses have few employees, but often they have certain
employees who are trusted with responsibilities that may not have
complete internal control systems. This situation makes small
businesses especially vulnerable to fraud. The article “Small
Business Fraud and the Trusted Employee” from the Association of
Certified Fraud Examinersdescribes how a trusted employee may
come to commit fraud, and how a small business can prevent it from
happening.
Accountants, and other members of the management team, are in a
good position to control the perceived opportunity side of the
fraud triangle through good internal controls, which are policies
and procedures used by management and accountants of a company to
protect assets and maintain proper and efficient operations within
a company with the intent to minimize fraud. An internal
auditor is an employee of an organization whose job is to
provide an independent and objective evaluation of the company’s
accounting and operational activities. Management typically reviews
the recommendations and implements stronger internal controls.
Another important role is that of an external
auditor, who generally works for an outside certified
public accountant (CPA) firm or his or her own private practice and
conducts audits and other assignments, such as reviews.
Importantly, the external auditor is not an employee of the client.
The external auditor prepares reports and then provides opinions as
to whether or not the financial statements accurately reflect the
financial conditions of the company, subject to generally accepted
accounting principles (GAAP). External auditors can maintain their
own practice, or they might be employed by national or regional
firms.
ETHICAL CONSIDERATIONS
Internal Auditors and Their Code of Ethics
Internal auditors are employees of an organization who evaluate
internal controls and other operational metrics, and then ethically
report their findings to management. An internal auditor may be a
Certified Internal Auditor (CIA), an accreditation granted by the
Institute of Internal Auditors (IIA). The IIA defines internal
auditing as “an independent, objective assurance and consulting
activity designed to add value and improve an organization’s
operations. It helps an organization accomplish its objectives by
bringing a systematic, disciplined approach to evaluate and improve
the effectiveness of risk management, control, and governance
processes.”2
Internal auditors have their own organizational code of ethics.
According to the IIA, “the purpose of The Institute’s Code of
Ethics is to promote an ethical culture in the profession of
internal auditing.”3
Company management relies on a disciplined and truthful approach to
reporting. The internal auditor is expected to keep confidential
any received information, while reporting results in an objective
fashion. Management trusts internal auditors to perform their work
in a competent manner and with integrity, so that the company can
make the best decisions moving forward.
One of the issues faced by any organization is that internal
control systems can be overridden and can be ineffective if not
followed by management or employees. The use of internal controls
in both accounting and operations can reduce the risk of fraud. In
the unfortunate event that an organization is a victim of fraud,
the internal controls should provide tools that can be used to
identify who is responsible for the fraud and provide evidence that
can be used to prosecute the individual responsible for the fraud.
This chapter discusses internal controls in the context of
accounting and controlling for cash in a typical business setting.
These examples are applicable to the other ways in which an
organization may protect its assets and protect itself against
fraud.