The Good, the Bad and the Bernie Madoff's

Everyone has some "Bernie Madoff" in them. It isdetected will be reported to the police for further
said that for the "right price", many people mightinvestigation and where applicable, the company
compromise their values. Fortunately, the vastwill prosecute the offender.
majority of us have high moral and ethical3. All employees MUST take their vacation time.
standards so fraud is not even a consideration.In many cases, fraud will be detected by
For those very few who have a feeling ofsomeone else performing the duties of the
entitlement, how do we protect ourselves fromindividual perpetrating the fraud. Therefore,
them?employees who are hesitant and/or resistant to
Occupational fraud comes in a variety of typestake their vacations should be watched very
and forms. It can be perpetrated by manycarefully.
individuals within an organization. The term4. Rotate job responsibilities. Once again, fraud
"occupational fraud" may be defined as: "The usebecomes more difficult if the perpetrator does
of one's occupation for personal enrichmentnot have constant and sole access to certain data
through the deliberate misuse or misapplication ofand processes.
the employing organization's resources or assets."5. Develop stronger internal controls which include
According to a study published by the ACFEproper segregation of duties. Since many small
(Association of Certified Fraud Examiners) in 2008:businesses have limited staff, it becomes
- Occupational fraud schemes tend to beincreasingly difficult to define strong controls. For
extremely costly. The median loss caused bythis reason, the ACFE report stated that only
occupational frauds in this study was $175,000.16% of fraud was discovered through the
More than one-quarter of the frauds involvedcompany's internal controls. Many small business
losses of at least $1 million.owners delegate too much authority to their
- Occupational fraud schemes frequently continuebookkeepers and/or controllers. Beware of
for years before they are detected. The typicalweaknesses in your systems and implement the
fraud in the study lasted two years from thefollowing controls:a. The owner (or someone else
time it began until the time it was caught by thewithin the organization) MUST continue to review
victim organization.key financial reports and records. All
- Lack of adequate internal controls was mostdisbursements should have vendor invoices
commonly cited as the factor that allowed fraudattached to the check stub with the manager
to occur.supervisor responsible for the expenditure
- Small businesses are especially vulnerable toapproving it before payment.b. The person who
occupational fraud. The median loss suffered bysigns the checks should NOT be the one who
organizations with fewer than 100 employees wasperforms bank reconciliations. Detailed bank
$200,000. This was higher than the median loss inreconciliations should be reviewed and initialed by
any other category, including the largesteither the owner or an outside accountant who is
organizations.familiar with the process.c. The person responsible
- Occupational frauds were most oftenfor billing needs to get an approval from someone
committed by the accounting department (29%)outside of the accounting area in order to process
or upper management (18%).credits to customers.d. All suppliers added to the
It should be noted that many cases of fraud gosystem need to have an approval by the
undetected, and those that are identified, may notmanager requesting the product/services, in
be reported to the police or the extent of theaddition to that of the bookkeeper or controller. If
loss may not be fully discovered.the bookkeeper or controller is the one adding the
While it's impossible to detect 100% of fraudsupplier, the owner needs to approve it.e. A
because collusion can bypass normal companyreport of additions and deletions of customers
controls, it is much less expensive to implementand suppliers should be reviewed and approved
sound internal policies and controls than it is toregularly by someone outside the accounting
investigate and prosecute. According to the ACFEarea.f. Accounting systems should have security
2008 report, fraud was discovered in smallpermissions prohibiting accounting personnel from
businesses 42% of the time through tipsmaking certain changes to financial data.
(employees, customers, suppliers, etc) and 29%6. Before hiring new employees, perform
by accident. Only 16% of the time was the fraudbackground and credit checks. Many companies
discovered through the company's internalwill perform a background check on key
controls. The study also found that the medianemployees. However, 87% of the cases reflected
duration was 24 months with 52% of thethe perpetrator had no previous criminal record.
perpetrators being with the company for over 5The #1 reason for occupational fraud in small
years.businesses was due to financial pressures of the
So what steps can a small business owner takeperpetrator. Therefore, credit checks can be a
to minimize the frequency and magnitude ofstronger indicator than the background check.
fraud? Here are some key tips:7. Be aware of employees living beyond their
1. Develop a formalized mechanism for fraud tomeans or expressing personal financial difficulties.
be reported. A fraud hotline needs to beIn 77% of the occurrences discovered and
implemented and its purpose activelyreported to the ACFE in their 2008 survey,
communicated to all employees. There should alsoindividuals living beyond their means (41%) and
be a procedure where specific managers arepersonal financial difficulties (36%) were the key
identified as confidential contacts, enablingreasons fraud was perpetrated by employees of
employees to report their concerns or suspicions.small businesses.
This procedure needs to be documented in writingWhen it comes to fraud and the controls to deter
and should require that more than one managerand detect it, don't bury your head in the sand.
investigates the allegation.Take control and derail fraud before it rears its
2. Educate employees as to what constitutesugly head. It can happen to you. Can your
fraud and the cost to the company. While thiscompany afford to lose $150,000 (or more)?
sounds like common sense, it highlights to theIf you don't have expertise in this area, bring in a
employees the need to be observant and theirprofessional to take a look at your systems and
responsibility to report their suspicions. Make itcontrols. The investment will probably be the best
very clear to the employees that ALL fraudreturn your business will ever see.