Podcasts about fraud triangle

Protect your finances from fraud, embezzlement, and scams with expert strategies from Kelly Todd, President of Forensic Strategic Solutions. In this episode, she shares how to detect, prevent, and recover from financial fraud before it devastates your business or personal assets.

Set up a call:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Check out our website:https://calendly.com/cuexamsolutions/talk-to-mark-about-any-exam-topic?month=2024-10Are you worried about an NCUA exam in process or looming on the horizon? Don't face it alone!We're ex-NCUA insiders with decades of experience, ready to guide you to success. Our team understands the intricacies of NCUA examinations from the inside out.Hire us and gain:• Peace of mind during your exam process• Insider knowledge of NCUA procedures and expectations• Strategies to address potential issues before they become problems• Continuous access to our extensive subject matter expertiseWith our access retainer, you'll have on-demand support from former NCUA experts. We're here to ensure your credit union passers its exam with flying colors in its next examination.Contact Credit Union Exam Solutions today to learn more about our services and how we can help your credit union succeed.# With Flying Colors Podcast: Fraud and the Necessity of On-Site Exams## Episode SummaryMark Treichel discusses the importance of on-site exams by NCUA (National Credit Union Administration) in detecting and preventing fraud in credit unions. He explores the concept of the Fraud Triangle and explains why a physical presence is crucial in maintaining the integrity of financial institutions.## Key Points1. NCUA Chairman Todd Harper emphasized the need for increased travel budget to accommodate on-site exams.2. Recent credit union failures involved fraud as a contributing factor.3. The Fraud Triangle consists of three elements: pressure, opportunity, and rationalization.4. Physical presence of examiners can deter fraudulent activities by reducing opportunities.5. While virtual examinations have their place, on-site visits remain essential for thorough oversight.## Notable Quotes- "As examiners return on site, they have found an increase in record keeping deficiencies, problems with internal controls, and instances of fraud." - NCUA Chairman Todd Harper- "The opportunities available for committing the fraud motivate the fraudsters to commit the fraud." - Mark Treichel## ConclusionMark Treichel argues that while the pandemic has shown that many examination procedures can be done remotely, NCUA should maintain a balance between virtual and on-site examinations to effectively prevent and detect fraud in credit unions.## Resources Mentioned- Credit Union Exam Solutions: marktreichel.com---*Subscribe to "With Flying Colors" for more insights on achieving success with NCUA.*

Blake and David examine the mysteries and motives surrounding the recent Macy's accounting scandal, where a single employee allegedly concealed $132-154 million through improper accrual entries. They also examine Trump's proposed 25% tariff plan on imports from Mexico and Canada (plus an additional 10% on China), discussing its potential impact on American businesses and consumers. SponsorsZoho - http://accountingpodcast.promo/zohoSuralink - http://accountingpodcast.promo/suralinkCloud Accountant Staffing - http://accountingpodcast.promo/casChapters(00:46) - Macy's Accounting Error: Breaking News (01:40) - Understanding the Impact of Macy's Error (02:46) - The Mystery Behind Macy's Accounting Error (02:53) - Join the Live Discussion (03:42) - Upcoming Topics and Teasers (05:15) - Thanking Our Sponsors (06:42) - Diving Deeper into Macy's Accounting Mystery (19:29) - Exploring the Fraud Triangle (27:54) - Auditors and Materiality Standards (32:04) - Auditors' Role in Detecting Fraud (33:25) - Impact of Fraud on Macy's Stock (33:47) - Challenges in Auditing Practices (34:08) - Internal Controls and Their Limitations (38:53) - Expense Fraud: A Growing Concern (44:01) - AI in Auditing: The Future of Fraud Detection (52:28) - Trump Tariffs and Their Economic Impact (01:03:13) - Thanksgiving Reflections and Closing Remarks  Show NotesMacy's says employee hid up to $154 million in expenses, delaying Q3 earningshttps://apnews.com/article/macys-accounting-quarter-b1cb0927d9b6a58ee4396838df7973c9Macy's says accountant hid as much as $154M in expenseshttps://www.cfodive.com/news/macys-says-accountant-hid-as-much-as-154m-in-expenses-retail-retailing-consumers/733960/UPS to Pay $45 Million SEC Penalty Over Improper Valuationhttps://finance.yahoo.com/news/ups-hit-45-million-penalty-144424675.htmlStrippers, Christmas gifts and an RV: Workers push it with company cardshttps://abcdpf.livemint.com/industry/strippers-christmas-gifts-and-an-rv-workers-push-it-with-company-cards-11732157906943.htmlEx-Jaguars employee who stole $22 million from team files lawsuit against FanDuelhttps://www.nytimes.com/athletic/5809925/2024/10/01/jaguars-lawsuit-fanduel-amit-patel/Trump's Truth Social tariffs pledge is a teachable moment for Americahttps://www.msnbc.com/opinion/msnbc-opinion/trump-truth-social-tariffs-deportation-thanksgiving-rcna182079What does Trump's latest tariff plan mean for the U.S.?https://www.pbs.org/newshour/politics/what-does-trumps-latest-tariff-plan-mean-for-the-u-sWalmart CFO Says They Don't Want To Raise Prices, But 'Prices Will Go Up For Consumers' Due To Upcoming Tariffshttps://finance.yahoo.com/news/walmart-cfo-says-dont-want-161640110.htmlNeed CPE?Get CPE for listening to podcasts with Earmark: https://earmarkcpe.comSubscribe to the Earmark Podcast: https://podcast.earmarkcpe.comGet in TouchThanks for listening and the great reviews! We appreciate you! Follow and tweet @BlakeTOliver and @DavidLeary. Find us on Facebook and Instagram. If you like what you hear, please do us a favor and write a review on Apple Podcasts or Podchaser. Call us and leave a voicemail; maybe we'll play it on the show. DIAL (202) 695-1040.SponsorshipsAre you interested in sponsoring the Cloud Accounting Podcast? For details, read the prospectus.Need Accounting Conference Info? Check out our new website - accountingconferences.comLimited edition shirts, stickers, and other necessitiesTeePublic Store: http://cloudacctpod.link/merchSubscribeApple Podcasts: http://cloudacctpod.link/ApplePodcastsYouTube: https://www.youtube.com/@TheAccountingPodcastSpotify: http://cloudacctpod.link/SpotifyPodchaser: http://cloudacctpod.link/podchaserStitcher: http://cloudacctpod.link/StitcherOvercast: http://cloudacctpod.link/OvercastClassifiedsForwardly - https://www.forwardly.com/Client Hub - https://clienthub.app/Want to get the word out about your newsletter, webinar, party, Facebook group, podcast, e-book, job posting, or that fancy Excel macro you just created? Let the listeners of The Accounting Podcast know by running a classified ad. Go here to create your classified ad: https://cloudacctpod.link/RunClassifiedAdTranscriptsThe full transcript for this episode is available by clicking on the Transcript tab at the top of this page

What is stranger than fiction? The stories of worldwide corruption. In this podcast series, co-hosts Tom Fox, the Voice of Compliance and Mike DeBernardis, partner at Hughes Hubbard, discuss some of the most audacious corruption cases in anti-corruption enforcement. More importantly, they will discuss the lessons learned on what your organization can do to prevent running afoul of international anti-bribery laws. In this episode of Season 2, Tom and Mike explore the Barings Bank scandal The focus is on the actions of Nick Leeson, a trader who single-handedly bankrupted the historic institution. The discussion highlights the critical mistakes made by the bank, including a lack of oversight and the dangerous combination of trading and settlement roles. The podast also explores the broader implications for compliance and risk management in financial institutions, emphasizing the importance of segregation of duties and the pressures that can lead to unethical behavior. Key Highlights: The Rise and Fall of Barings Bank The Role of Oversight in Financial Institutions Lessons Learned from the Barings Bank Scandal How does the Fraud Triangle apply? Segregation of Duties-as basic a control as you can have in place Memorable Quotes (all from Mike DeBernardis) “Nick single-handedly bankrupted the oldest merchant bank.” “He was a golden boy trader making tons of money.” “Barings Bank was sold for one pound.” Resources: Mike DeBernardis on LinkedIn Hughes Hubbard & Reed Tom Fox Instagram Facebook YouTube Twitter LinkedIn Texas Tax rate at 80% of 8.25%

Banking on Fraudology is presented by Unit21. Unit21's Risk and Compliance Infrastructure empowers your team to proactively combat financial crime and make informed decisions throughout the customer lifecycle. Configurable to your organization's unique risk profile, Unit21 unifies data silos into a comprehensive, end-to-end solution that helps reduce the impact of financial crime on your organization and your customers.Learn more about our sponsor, Unit21:- See Unit21 in action https://www.unit21.ai/podcast- Follow Unit21 on LinkedIn https://www.linkedin.com/company/unit21/- Watch Unit21 Virtual Summit Hailey session replay https://hubs.li/Q02LbZmC0-------------------------In this episode, we uncover the powerful dynamics of pressure, rationalization, and peer influence that lead to sabotage, discrimination, and even fraud within organizations. Marta shares groundbreaking methodologies her company developed using artificial intelligence and natural language processing to predict and prevent fraud, highlighting the importance of cultural and generational communication differences.We'll also explore the state of bank fraud today, discuss the significance of understanding employee behavior, and talk about essential resources like the "Report to the Nation." Marta emphasizes the need for clear company values and zero-tolerance policies for unethical behavior while addressing the impact of crises like Covid on fraudulent activities.Tune in for an eye-opening discussion filled with Marta's expert insights and practical advice on implementing effective controls and advocating for better tools and technology in your organization. Subscribe on Apple, Spotify, or your preferred platform to ensure you never miss an episode. Let's dive in!-----------------------About Hailey Windham:As a 2023 CU Rockstar Recipient, Hailey Windham, CFCS (Certified Financial Crimes Specialist) demonstrated unbounding passion for educating her community, organization and credit union membership on scams in the market and best practices to avoid them. She has implemented several programs within her previous organizations that aim at holistically learning about how to prevent and detect fraud targeted at membership and employees. Windham's initiatives to build strong relationships and partnerships throughout the credit union community and industry experts have led to countless success stories. Her applied knowledge of payments system programs combined with her experience in fraud investigations offers practical concepts that are transferable, no matter the organization's size. Connect with Hailey on LinkedIn: https://www.linkedin.com/in/hailey-windham/

Welcome back to the Inner Edison Podcast! In this episode, host Ed Parcaut sits down with Sarah Webb, a fractional CFO and founder of WebbCFO.com, to explore the intricate world of small business financial management. **Timestamps:** 00:00 - Introduction 02:15 - Ed discusses challenges in the industry and the importance of the right team 06:40 - Sarah explains the fraud triangle and its impact on small businesses 11:50 - Real stories of internal financial fraud: Lessons to learn 16:30 - Niche marketing strategies for private medical practices and law offices 21:45 - The "no jerk policy": Working only with good companies 27:00 - Managing cash flow and credit terms in small businesses 34:45 - When to consider hiring a fractional CFO 39:20 - The importance of having a forward-looking CFO 42:15 - Sarah's experience with IRS issues and payroll challenges 49:00 - Outsourcing services to solve staffing issues 54:30 - Selecting the right legal entity structure 58:40 - The impact of government and politics on small businesses 1:04:10 - The role of AI in improving job efficiency 1:10:50 - Financial strategy and the role of a CFO in business growth 1:17:00 - Importance of flexibility and education in adapting to changes 1:21:30 - Final thoughts and how to contact Sarah Webb at WebbCFO.com **Key Facts:** - Financial fraud risks in small businesses and the importance of segregation of duties. - Cash flow management challenges, especially in medical practices and law offices. - The pivotal role of a fractional CFO in helping businesses strategize, forecast, and budget. - How niche marketing and a "no jerk policy" contribute to business success. - The critical role of AI in enhancing job productivity and alleviating lower-end job roles. - The importance of selecting the right legal entity structure and understanding government regulations. - How businesses can adapt to unforeseen factors such as interest rate changes and political influences.

In this discussion, Shiyan Koh, Managing Partner of  Hustle Fund, and ​​Jeremy Au talked about three main themes: 1. Founders Reviewing VCs: Shiyan reflected on founders conducting due diligence on their funding sources. They discuss the value (and further improvements) of public reference lists like TechinAsia's Glasswall which indexes the fundraising process, and how founders should seek private feedback from (post-fundraise) portfolio companies. 2. Startup Fraud Triangle: Jeremy and Shiyan examined the darker side of the regional startup culture, including fraudulent accounting trends and their impact on the local funding ecosystem. They agree that while most founders don't set out to defraud, poor decisions under pressure can take the opportunity to conduct unethical actions. 3. Difficult Wind-Down Decisions: The vast majority of startups fail to meet expectations after substantial fundraising. Shiyan shared the rarity but reputational importance of attempting to return capital to investors when a pivot isn't feasible. She advises founders to treat investors with respect during wind-downs, as the startup industry is a "repeated game" where one's actions can influence future opportunities. They also talked about the emotional toll of admitting failure, potential for biased VC reviews, and the societal role of media in reporting startup successes and failures. Watch, listen or read the full insight at https://www.bravesea.com/blog/founders-reviewing-vcs Get transcripts, startup resources & community discussions at www.bravesea.com WhatsApp: https://chat.whatsapp.com/CeL3ywi7yOWFd8HTo6yzde TikTok: https://www.tiktok.com/@jeremyau Instagram: https://www.instagram.com/jeremyauz Twitter: https://twitter.com/jeremyau LinkedIn: https://www.linkedin.com/company/bravesea TikTok: https://www.tiktok.com/@jeremyau Instagram: https://www.instagram.com/jeremyauz Twitter: https://twitter.com/jeremyau LinkedIn: https://www.linkedin.com/company/bravesea English: Spotify | YouTube | Apple Podcasts Bahasa Indonesia: Spotify | YouTube | Apple Podcasts Learn more about HDMall here:  htps://www.hdmall.co.th https://www.hdmall.id

Get ready for part two of our insightful ESG (Environmental, Social, and Governance) discussion on the Count Me In podcast. Our expert panel, Douglas, Dan, and Catie, unpack the pressures and fraud risks inherent in ESG reporting, offering invaluable insights gleaned from real-world scenarios. But it's not just about identifying risks; they also provide practical guidance for those embarking on their ESG journey. Learn how to start with what you have, concentrate on materiality, and establish a robust, cross-functional ESG team. Tune in for an essential roadmap to navigate the complexities of ESG reporting in today's business landscape. This is one episode you won't want to miss!Connect with our speakers:Catie: https://www.linkedin.com/in/ctserex/Dan: https://www.linkedin.com/in/dan-mosher-8552519/Doug: https://www.linkedin.com/in/douglas-hileman-fsa-crma-cpea-p-e-6abbb71/Download the reports mentioned into today's podcast:Achieving Effective Internal Control Over Sustainability ReportingManaging Fraud Risks in an Evolving ESG EnvironmentFull Episode Transcript:Adam:            Welcome back to Count Me In. Today we have part two of Unraveling ESG. We're joined, again, by Catie Selex, Douglas Hileman, and Dan Mosher for the completion of their conversation. Now, if you didn't hear part one, I encourage you to pause right now and listen to that first. In today's episode, we explore the challenges and risks of ESG reporting, including the potential for fraud. Our experts delve into the pressures companies face and discuss real-world examples of how well-intentioned sustainability efforts can sometimes lead to misreporting and potential fraud. But it's not all about the pitfalls, they also offer essential guidance to those new to ESG. Emphasizing the importance of starting with existing resources, focusing on materiality, and setting up the dedicated cross-functional ESG team. Don't miss this invaluable conversation, so let's get started. [00:00:55]       < Music > Dan:                Doug, I mentioned the ACFE's Fraud Triangle earlier, and I'm eager to hear some of your perspectives on applying that Fraud Triangle to ESG.  Doug:              Thank you, Dan, it can be done too. It's a familiar construct, and I was fortunate to be an in-house at a Big Four when Sarbanes-Oxley hit. And at the very beginning of designing internal controls and testing internal controls, we had to consider the possibility of fraud.We had to design controls to prevent fraud, in audits we had to detect fraud.  Being an environmental specialist, and then with the IIA coming out with changing their IPPF, their framework, to require testing for fraud. I've been testing for fraud and considering fraud for 20 years, in the environmental space since 2002. It looks a little different for ESG, but not as different as you might think. There is pressure, pressure can be, "We've got to get this report out." "The customer wants this answer." "We have to say, for example, that our products didn't come from Bangladesh, so what the heck? How will they find out?" There's so much pressure. I see that people are involved in ESG, in this non-financial reporting, as an add-on to their jobs. It might be 20% of their job, and it's the 20% between 120 and 140% of what they're supposed to do. People are under, and companies, are under tremendous pressure to put the right answer out there.  They have the opportunity to do so because the controls are not designed, and have not been implemented with the potential for fraud in mind. So where there are weak controls or no controls, the opportunities are there. I see this comes into play, also, when data and information comes from outside the organization. There's this tricky thing where so much of what we do, in ESG, is not only what the organization controls but what the organization can influence. There are some challenges there, how do you control what you don't control?  So the opportunity is there because the controls can be weak or nonexistent. And the rationalization can be, "Well, everybody does it."  Or "It's not about money, it's about prestige." "It's not really this, we want the award." We've seen, for example, there's a magazine, an organization, that rates colleges, the 10 best colleges in each thing. And we've started to see, in recent years, where the colleges are even fudging the information to get the prestige of being in that award. That may have secondary effects for how many people go to that college or what they're willing to pay for tuition, but that's fraud.  In my book, if you submit data and information that is incorrect, or inaccurate, or misleading, with the intent to deceive at the expense of others. Especially if that turns into actual or potential financial gain, I call that fraud. So that applies on all three sides of the triangle. It's just a matter of thinking about this ESG and non-financial world and how that can happen. Dan:                Excellent, Doug. Yes, maybe, just to add a couple of extra points around those pressures and incentives. Today we are seeing that there is incentive compensation for certain executives that is linked to various ESG measures. If you think about that and the opportunity for management override of certain controls that are out there, that's a great incentive.  If you're going to get paid a bigger bonus because of greater ESG metrics, and your ESG, for example, your emissions information is held in Excel spreadsheet, which in many cases that is the case. I saw a survey, not so long ago, of more than a thousand executives saying that, I think, it was 86% of them had their emissions data just sitting in a spreadsheet. And if you could change that with a few keystrokes, at the executive level, to boost your bonus, someone might do that. Other things I think of are from an incentive or pressure standpoint. Things around ESG-linked bonds or credits where there are a key performance indicators and you're required to maintain those metrics, to maintain certain interest rates or payment on your bond. Those things are out there and they're going to influence some portion of those that are held to them. Catie, maybe, you have some other thoughts around this as well? Catie:              Yes, Dan, so one of the things that we're seeing in ESG, especially because people are so compelled to make great strides on their data and to make progress towards their targets, in a very quick manner, is there's an emerging market of solutions that some are absolutely legitimate and there's good actors, but they're also bad actors. So one real-life example of this happening is the Vatican used a third party to preserve a forest area, as part of its carbon offset effort and to help move towards its emissions reductions targets. So, in this instance, the Vatican thought that it had protected an area of Hungarian Forest as part of that reductions plan, but that actually never happened.So while there were good intentions to reduce the Vatican's emissions footprint, ultimately, that desire left them to susceptible to fraud by this third party. So that's something else to think about is as you're incorporating other entities, that are outside of your organizational boundaries to help you reach these targets, are they genuine good actors?  Have you conducted the due diligence to ensure that they're going to support you in getting to those targets, as opposed to hinder or even mislead you, which could lead to misreporting on your part? And, Dan, I wanted to get back to that pressure element. A lot of the clients that we're working with are in those early stages of ESG reporting, and are just getting their program started. So, Dan, Doug, and I am happy to contribute, as well, but what are some guidance that we can give to listeners? In terms of for those who are at ground zero and need to start reporting, and disclosing, and to ease some of the pressure that they're experiencing from stakeholders and regulators. What are some ways that they can approach this? What are some tools that they can use to mitigate associated risks?  Dan:                I'll go ahead and start. So I refer back to some of those frameworks, that you have mentioned, Catie, as a starting point. In terms of the kinds of disclosures that an organization might make in a certain business sector. I think that they should be taking stock of the various channels in which they might be reporting that information, and looking at the various kinds of scenarios, in which the information might be incomplete or inaccurate. So even just thinking about those processes will get them on a good path forward.  I think that you probably want to think about starting fairly small, with the kinds of disclosures, and build upon those as your maturity from an ESG perspective grows. Doug, what are your thoughts? Doug:              For companies just starting out, or in the early stages, what I would say to them is, first, just recognize this is not a hobby. This is not a nice to do, this is a business imperative and it is not going away. Put the right people on it and devote resources to it, who can really get things moving. Another thing I would say is, one of my phrases, is begin with what you've got because you really can't begin with anything else. A gap assessment is a really good idea. What are the requirements that are expected from the general capital markets?  What are the questions you're getting from impact investors and customers, where you're getting that pull and you're expected to provide something? Well, what is it you have? Companies may have a little more information than they think they have. Because much of this information is already being collected to achieve regulatory compliance obligations, with let's say the EPA, or with OSHA, or the Department of Labor. Is that data and information fit for purpose or can it be modified a little bit, to meet the expectations of the stakeholders who want this kind of reporting and disclosures? Another point I would say, we've touched upon the cross-functional team. This cannot be the responsibility of any one person. This is a team effort because this non-financial information touches every part of your business internally, and it touches many parts of your business externally. With your providers of capital, your banks, your insurance companies, your customers. So all the people who engage in external relations with folks outside the company, it has to include those.  One tip I would say is climate change is the single biggest issue of our time and climate change and climate change reporting, greenhouse gas emissions reporting, is expected of everybody. So climate change has got to be on your agenda. There is some specialized expertise that comes with that.  I would suggest that climate change has even its own team and its own work streams. I think supporting that when the ISSB put out their two exposure drafts. They had one for all sustainability reporting disclosures and one for climate change risk and exposures. So you've got to address climate change. And, finally, I would say I put in a shameless plug for using the COSO Framework, that if the data is going to be complete. If it's going to be accurate, if it's going to be verifiable if you're going to have the right people with access to it and only the right people with access to this data. There's nowhere better to start than that COSO Internal Controls Framework. And even backing up that COSO Enterprise Risk Management Framework to lead into materiality. And to lead into what are the issues where we should be reporting on and focus our efforts.  To use an extreme example, if you're a Chevron you're not going to bet the company on recycling paper. So what are the issues that matter to you as a company? Where you invest your time, your resources, your people, and your initiatives on improving performance.  Catie:              And, Doug, you brought up a great point when it comes to materiality, and I want to make sure that for our listeners, they know that when it comes to ESG and sustainability, materiality is separate and distinct from the concept of materiality under federal state securities law, as well as GAAP. And that's because items that are material to ESG they're not, necessarily, the same as those that are material under securities law or GAAP.  So one of the ways that we help clients and, especially, our year zero clients who are trying to uncover what is material to their company. We always recommend starting with a materiality assessment, and ESG strategy and policy development. This is going to help you set your own guardrails so that you don't overextend or overcommit on ESG. Doug mentioned that climate change is becoming one of those topics, that companies absolutely need to have resources and teams dedicated to. And I'm seeing that with most of my clients, climate, even if it's not on the horizon immediately, it's coming.  And, so, it's something that you will need to consider and continue to refresh what's material to you. So having those assessments, we recommend every two to three years because material topics for ESG are not stagnant. You don't select them, and then that's what you have for the entirety of your company's lifespan. They change because society changes, the political environment changes, and the actual environment changes. So you want to make sure that you're staying on top of and looking ahead to what those risks are.  So that you've got the data, mechanisms, and the internal control processes in place, to be able to have that data, have those baselines that you need. And then as you're planning out your ESG programming, set realistic goals and targets. So that you're not overextending yourself and that you are setting commitments that you know that you can achieve, and you're not falling victim to the fraud triangle in an attempt to achieve those commitments that you set for yourself. Dan:                Doug, I know you talked a bit about the great importance of climate change and emissions reporting. I did want to give our listeners some food for thought around emissions reporting. If you think about how some of that emissions reporting takes place, it's a calculation. So, for example, I've been in touch with a large organization. They calculate some of their emissions, taking their rented square footage of office space and applying the relevant coefficient to it, to come up with an estimate of their emissions.  I asked the question, well, "You have a number of offices across the country. What would happen if you, accidentally, forgot the Dallas office? Would someone catch it?" And the answer was, "Not necessarily." And, so, the care and the completeness, and the extra effort to make sure you have that completeness, it can be challenging, but I think it's completely necessary. Because if something could be forgotten accidentally, it could be forgotten on purpose, and if it's forgotten on purpose that's contributing to fraud.  Catie:              And to add to that point, Dan, some of the frameworks, specific to climate, already have built-in mechanisms to help you guard against that fraud. So, for instance, The Greenhouse Gas Protocols Corporate Standard sets guidelines for when to recalculate your corporate base year emissions. Because companies are setting their targets and their reduction strategies based upon that base year calculation. And, so, there are some particularities in terms of, for instance, if your company goes through an acquisition and your footprint goes by X percent, that is what triggers a base year recalculation for your emissions metrics specifically. And, so, that's a policy example. That's an example of a policy that you would want to have in place for some of these metrics.  So that as your company continues to grow, and circumstances change, and your footprint either shrinks or increases, based upon your operational size. You'll want to have policies in place so that you know when to recalculate your base year, so that you're continuing to report complete and accurate data.  Doug:              I think carbon emissions reporting, encapsulates everything we've discussed on this podcast and everything that's in both of our reports, the COSO Report and ACFE Report. And I think we could probably do a separate podcast on that. I'd encourage our listeners, many of whom are accountants, to read the Greenhouse Gas Protocol and become familiar with it.  There are operational and technical people doing it, but at its heart it really is an accounting protocol. We've discussed how you put together data and information to meet different purposes. I've worked with clients who get called upon to publish a greenhouse gas report, greenhouse gas emissions, using an operational control basis. Using the equity share basis, using the financial… So there's the same data that needs to be sliced and diced three different ways and for different reporting periods. Catie brings up the good point that there are protocols to restate or to correct errors when identified, or to account for forgotten facilities. There are uncertainties documented in it because many of these emissions that are reported involve estimates. What if you get better estimates? Do you apply that to this reporting period or do you retroactively do that and report it? Much of this involves judgment. What is a material change? So maybe you apply materiality in ways that you would apply it elsewhere or differently. All this has to be documented and the possibility of fraud starts to creep in, when there is the pressure to say, "We are on target for getting carbon neutral by 2030, in accordance with senior management's directives." So they can get their compensation bonus, and we can stay in that ESG-preferred trading fund, and we can get our low-interest rate from the bank or decline from that. If you understand, if accountants, and business folks, and operations, and environmental people take a good look at the Greenhouse Gas Protocol and you overlay that with the COSO Internal Control Framework, and you overlay that with that terrific publication on ESG fraud, from the ACFE. A lot of what we're saying will start to make sense and you will understand where you can contribute to more effective and more efficient reporting, and prevention, and detection, of fraud.  Catie:              So we know that, especially, because ESG is still an emerging discipline and there's different interpretations of data, and some of the data points themselves are evolving. So what do you say to those who are concerned about, unintentionally, misreporting data. And realizing two to three years down the road, "Oops, we made a mistake." How should they approach that in the future?  Doug:              Well, that's a great question, Catie, and we see that all the time. And I predict we will see it a lot more as this field matures, and as companies mature their processes and controls, and as more people take a look at it, both, assurance providers, investors, and the like, we're going to see more of that. And it's understandable that everybody will be handwringing and so afraid of making a mistake. And I go back to what we said 20 years ago, at the beginning of Sarbanes-Oxley. I was on many financial audit teams supporting them as ESG specialist for asset retirement obligations, environmental liabilities. And, well, we don't know the right number. We don't know if it's going to happen, and my advice, at the time, as a non-CPA, just an engineer and auditor is to say, "Well, in good faith, read, interpret what is required, develop a process, document the process, and then follow the process and document that you followed the process and the output from that process." That's what goes on the line item in your financial reporting.  If somebody determines that that was not correct or it can be improved. Maybe it's an internal suggestion, maybe it's from an auditor, maybe it's from an enforcement authority. It doesn't really matter how you discover something that needs to be changed. At least you can produce what it was you did and show that you were consistent with the design. The operation was consistent with the design. If you need to change it later, then change it later. Then comes the question, do we change it from this point going forward or do we have to do an adjustment for prior reporting periods? So that can be part of your process and your criteria. Set a threshold, a materiality threshold for that. Develop a process for how teams consider that and who decides yes or no. It's really using processes that you already have, and apply those for non-financial reporting.  Catie:              And just to jump in there from the ESG perspective, Doug, I think, not every year will be one marked by progress towards your targets. There's a million different circumstances that can affect progression on your commitments. And, so, again, going back to being transparent and communicating challenges and setbacks to your stakeholders, goes a long way in the ESG space. In terms of them continuing to have faith that you are reporting these disclosures, as they go along, and highlighting where you are experiencing those challenges and setbacks. Doug:              That's right.  Dan:                One part of the ACFE's Fraud Triangle is rationalization, and I think that this longer time horizon that Catie was just pointing to, actually, causes some rationalization to happen. Because there's a longer time horizon, someone might say to themselves, "Well, I can catch up next year.Let me fudge the number a little bit this year, and show some progress, and I will make it all better next year." And, so, there is something particular to ESG with that longer time horizon for those commitments being made around, "I'm going to be net zero by such and such a date. Well, that's a long time from now, let me just show that I have progression every year and hope that I can catch up in reality." Dan:                I maintain that non-financial reporting has a couple of attributes that are a little different from financial reporting, or at least they occur in greater proportion. Two of those attributes are much more narrative in non-financial disclosures, descriptions of processes, and also some forward-looking statements. Companies are encouraged to announce goals and targets, which sets the stage for reporting in future reporting periods on their progress to the goals and targets.  One of the things that is starting to look a little different, companies will say, "We are committed to meeting our climate goals for 2040." Where they make some grand, forward-looking narrative statements, and talking to some folks who are reviewing that, and even some of the external auditors, they're comparing those forward-looking narrative statements to where the companies are spending their money.  So if you're making statements and disclosures that are these grand, forward-looking projections, and the auditors see you're spending $7, a year, towards meeting that goal. Well, is that statement itself? Is that disclosure? Is that negligent?  Is that sloppy, or is that in order to get into an ESG fund, or to attract Helen, in ways? Is that tiptoeing into fraud?  I think the dust is yet to settle on that, but the topic is coming up. Dan:                I think it's a great point, Doug, and I'm sure that there are a host of attorneys out there who will, gladly, be spending time to figure out when the line has crossed into fraud. Catie:              And I will add to that, we're seeing a lot of companies set 2040 goals. And just for context, that comes out of the Paris Agreement, saying that the global target for net zero needs to be… Hang on, Adam, let me pause and make sure that I don't misstate this. So part of that Paris Agreement was this global recognition that net zero needs to happen by 2040.  And, so, that's why you're seeing that number come up in a lot of different corporate targets, when it comes to their net zero goals. That said, there is still a lot of work that needs to be done, at the company level, in order to achieve that. And there are things that are beyond your control.  So the different breakthrough technologies that are needed in order to accelerate transitioning to a decarbonized economy. There's still a lot of research being done in terms of the electrical grid and the different green technologies that can generate energy, to help reduce that carbon footprint. So I urge caution in terms of setting your goals because it needs to be, again, coming back to the point, it needs to be realistic and something that you think you can achieve. So one thing that we encourage our companies to do is it's great to have a moonshot goal, and if 2040 is your moonshot goal, then that's awesome. But setting those intermediary milestones to hold yourself accountable, to that moonshot goal, is something we really encourage our clients to do.  So that could be as simple as setting your baseline year for Scope 1 and 2 emissions. So that you have a complete understanding of your carbon footprint. And then from there you can understand what are those emission sources that we have? What can we do, that's in our power, to reduce those emissions? Are there simple process changes that can reduce our footprint?  So it's important, again, just go back to what you have already, what you know, and work from there. And there's no shame in having a really great moonshot goal if it's 2040 or if it's not 2040. But I think that setting those intermediary goals is going to be what really helps you to not fall susceptible to the fraud triangle.  Dan:                I think, we've had a really good conversation here and we've covered a lot of ground. Everything from visibility into your supply chain and the challenges raised by that. All of the complexities around data quality for emissions reporting and other sorts of reporting. I really have enjoyed this conversation immensely.  Doug:              As have I, it was a privilege. I hope our listeners enjoyed it as much as we enjoyed having the conversation. Catie:              Yes, thank you to Dan and Doug for this discussion. I really enjoyed chatting with you and, hopefully, the listeners will get some useful information out of this that they can take back to their organizations, and start to implement some of those tools and mechanisms to help them guard against fraud. [00:29:20]       < Outro > Announcer:    This has been Count Me In, IMA's podcast. Providing you with the latest perspectives of thought leaders from the accounting and finance profession. If you like what you heard and you'd like to be counted in, for more relevant accounting and finance education, visit IMA's website at www.imanet.org.

As highlighted in the recent COSO publication on Internal Controls over Sustainability Reporting, good governance and systems for sustainable business activities and ESG reporting require attention to potential risks around fraud and greenwashing.  Reflecting Grant Thornton's recent report on control activities related to these risks, join us as we take a dive deep into the world of Environmental, Social, and Governance (ESG) in business with our latest episode of the 'Count Me In' podcast. Hosted by a panel of experts, which includes Catie Serex, Douglas Hileman and Dan Mosher, our podcast uncovers the truth behind ESG, its importance in today's business world, the challenges it presents, and importantly, its potential role in fraudulent activities. Tune in for a fascinating conversation on ESG reporting, corporate purpose, sustainability, and the latest trends affecting investors, employees, and stakeholders alike. Don't miss this chance to stay informed and ahead of the curve in the ever-evolving world of business.Connect with our speakers:Catie: https://www.linkedin.com/in/ctserex/ Dan: https://www.linkedin.com/in/dan-mosher-8552519/Doug: https://www.linkedin.com/in/douglas-hileman-fsa-crma-cpea-p-e-6abbb71/Download the reports mentioned into today's podcast:Achieving Effective Internal Control Over Sustainability ReportingManaging Fraud Risks in an Evolving ESG EnvironmentFull Episode Transcript:Adam:            Hello, and welcome back to another enlightening episode of Count Me In. I'm your host, Adam Larson, and today we're diving deep into the complexities of Environmental, Social, and Governance, ESG, with a distinguished panel of experts. We're joined by Douglas Hileman, an experienced sustainability consultant, with over three decades of experience in environmental management systems, and internal controls.  Alongside him, we have Dan Mosher, a seasoned professional who excels in helping businesses navigate the complexities of sustainability and environmental risks. Last but not least, we welcome Catie Serex. A leader in environmental, health, and safety, auditing and management who assists businesses in integrating sustainable and socially responsible practices.  Today's discussion will delve into the importance of ESG, the challenges businesses face in managing ESG data, and the potential risk of fraud in ESG reporting. Here we go, let's listen in together. [00:01:00]       < Music > Doug:              And one of the things that we might kick off is with a very basic question of what is ESG? Dan, when people ask you this, how do you answer? Dan:                Well, it really is a big umbrella, and I'll ask for some help from Catie in this regard. But ESG stands for Environmental, Social, and Governance. And, so, lots of things under that environmental area. Everything from waste management and air quality, climate change. From a social perspective, it could be your human capital management, health and safety matters. Governance, I think of anticorruption, data risks, and the like. So it really is a broad title when we say ESG. Catie, do you have some things you'd like to add to that comment? Catie:              Yes, Dan, you definitely covered the gamut as far as some of the phrasings and the terminology, and really the topics that fall under that ESG umbrella. What I would want to add is that ESG is certainly one of the buzziest words in business today. But you might not know that ESG is, very simply, the newest iteration of concepts you've likely known for a long time. It's been previously known as corporate purpose, sustainability, even philanthropy.  But what differentiates ESG from these previous versions is that it now represents the closest alignment, to date, of business operations, so think about your tangible assets. To those intangible elements of business that drive value. And, in this case, I'm referring to things like customer loyalty, labor environments, community engagement support. And because of this connection, ESG is moving from a nice-to-have to a need-to-have for companies, but also their investors, their customers, and other key stakeholders like their employees. Doug:              I also think of ESG as a convenient taxonomy for all things non-financial. Many people have published those pillars or the word clouds that's in the ACFE report, and what topic goes where. For financial reporting, we know where sales goes and we know where EBITDA goes. We know where those are in a format and how to put the data and information together for clarity and reporting. For all things non-financial, it's just such a sprawling array of topics that ESG serves for one reason, in one way, as just simply a taxonomy. And there are some issues, such as climate change, like Dan mentioned, that really transcend more than one category, if you will. But for purposes of just where do you find it, and how do you manage it, and it can just serve as a taxonomy. Catie, to your point, on how to organize some processes, some controls, some recordings to understand what the organization is doing. Dan:                And I'd be interested in hearing your thoughts on the various channels in which this information is being put out there in the public. Catie, maybe you have some thoughts around the wide scope of that. Catie:              Yes, so in terms of the reporting side of things and getting to the nuts and bolts of what, I'm sure our listeners are interested in, in terms of, what am I on the hook for? There are a lot of reporting frameworks out there that are guiding folks. And I know that that's been a point of confusion for people is understanding, there are all these different acronyms out there. That I can report to like SASB, or the Global Reporting Initiative, GRI, Task Force for Climate-Related Financial Disclosures or TCFD. There are a lot of frameworks out there, but the field is narrowing.  So some of the communication that we've been seeing from these wider umbrella frameworks, are that they are working together to consolidate. To make things a little bit more straightforward, and to make things a little bit more uniform across the reporting landscape. But that's currently in progress, and this is just a result of this being not in nascent stages, but still in its growth period, and really honing down what are the things that shareholders, regulators, and such need to see when it comes to these ESG disclosures. Dan:                And I know that Doug has been on the front line when things are misreported or omitted, and I'd love to hear some of his worst stories. Doug:              Thank you, Dan. The question about reporting channels is a very good one, and Catie brought up several things that are happening in reporting to general capital markets. I also observe that there are other channels for reporting, including impact investors who may be interested in one particular topic. The general purpose capital reporting takes in one tranche, if you will, of topics that need to come external from an organization, a company.  There are other investors who are interested, let's say, in human rights, or in product conformity, or in diversity, or in commitment to climate, and they want more information about those topics. So you may get information from investor groups or analyst groups, and that's a type of report.  Another channel of reporting that I see is B2B reporting. The customers, and business partners, and banks, joint venture participants, are looking more into non-financial risk management. Non-financial performance and alignment, which is ESG. So before entering business relationships, and even during business relationships up and down the value chain, there's also ESG reporting that happens there.  It is starting to align in some ways that they're asking questions about the same topics, but the questions themselves can be different. And, in many cases, the reporting, the demand for reporting has outpaced companies' abilities to report on the data and information. So that pull has created a bit of a vacuum. And many companies are scrambling to come up with processes, systems, and controls so they can generate the data and information that these stakeholders are expecting in terms of reporting. Catie:              Doug, just to jump in there, from a client perspective, we are seeing that a lot of our clients are getting, especially, those B2B requests from either their suppliers or their downstream supply chain vendors. And the way that we're seeing that manifest is a lot of these larger companies are looking at their supply chain. If you think about greenhouse gas emissions, they're looking at their Scope 3 emissions, which is all value chain.  And, so, they're sending requests to clients like ours that are asking, "What are your Scope 1 and 2 emissions? Because we need to report that." We are seeing clients feeling the pressure to respond to that, to continue to be part of those wider supply chains.  And, so, they're coming to us asking for assistance in figuring out what those ESG metrics are and being able to respond in complete and accurate ways. So that they can continue to have those key customers that are asking for that information. Dan:                Yes, and I'd like to pick up on that point, too, and Catie was just touching on it. I think some of the key challenges are, for businesses today, what is the providence of their ESG data?  What is the confidence they have over the accuracy and completeness of it?  And what is the integrity and quality of that data as it travels along its life cycle, from where it started to where it was reported? And has it maintained that integrity all along? Because bringing this back to our main topic of fraud, there are many pressures and incentives that might have someone misstate or omit information in their ESG reporting. Doug:              I'd like to pick up on a topic that Catie discussed on climate change and greenhouse gas emissions. It does, inherently, involve a complex web of data from different sources, including suppliers. And companies may be asked to produce or report the greenhouse gas emissions for themselves, as a company, on Scope 1 and Scope 2. I hope our listeners know what that means. Or on a part of Scope 3, or their carbon emissions as a company, or their carbon emissions in a particular country or state, or their carbon emissions for the products they manufacture for a certain customer.  So those are different ways to slice and dice much of the same data. And it all goes back, I'll put in a plug here for the COSO report mapping the internal control framework to ESG. That can be applied to anything, any topic, any company, including, for example, greenhouse gas emissions. In terms of fraud, there can be a difference between just sloppy, or just unavailability of data and willful reporting of incorrect or misleading data.  For example, to get preferred treatment at a customer, or to get preferred inclusion in an ESG index fund, or to get a reduction on interest rate from a line of credit, from a financial institution that's looking for green investments. So we're still seeing an increase in awareness of the fact where, "Well, we can just report this because nobody cares." Or, "Well, it's not regulatory, so we'll just let it go." And willful deceit in order to get a benefit at the expense of other competitors in these areas, which goes into the fraud bucket. That ACFE and Grant Thornton touched upon in that report. Dan:                Yes, thank you, Doug. The report that Doug is referring to is a joint publication of the Association of Certified Fraud Examiners and Grant Thornton called Managing Fraud Risks in an Evolving ESG Environment. You can get it from our website and from the ACFE, and within that, we did develop an ESG fraud taxonomy.  It encompasses both some of the traditional areas of fraud that have always been there. Corruption, asset misappropriation, and financial statement fraud. And there are certainly ways in which ESG fraud manifests itself under each of those headings.  To that traditional fraud tree we have added an additional area of non-financial reporting fraud, which Doug was alluding to. And the things that might happen under there, there could be false labeling or advertising. Think of things like declarations of saying that it's "Dolphin-free tuna" that has certainly been an area of litigation in the past. I'm thinking about false disclosures or representations, and that might be along the B2B relationships. Where you are omitting information or misstating information to a company that you are a supplier to. Lots of ways that things can be contorted, and misrepresented, and misstated, omitted, and if it is done intentionally, then we're going to consider it fraud. Doug:              Dan, I can't say enough good things about the report that came out and, certainly, my hat is off to you, and Catie, and everybody who contributed to that. I know that was a massive effort. What I think is so elegant about that report is that many of our listeners struggle with how to get their arms around ESG, this sprawling issue is so new, it's so different.  The report begins with a construct that's familiar to everybody who deals with fraud, that famous ACFE fraud tree. And the report adds a leaf, if you will, if you look at that tree at the bottom row, that provides an ESG example for the fraud tree as everybody knows it. And then it was very elegant how you added that branch, if you will, for the ESG, the non-financial reporting with nine different twigs to describe a taxonomy there, and then the leaves with the examples, it was really well done.  So anybody familiar with fraud and the fraud tree. Anybody who has been involved in developing procedures to prevent fraud or to detect fraud on the audit side, you can just use that reference document and get pretty close to how you think about ESG fraud to prevent it and detect it.  Another thing I would observe that the human rights, no product was made with child labor. Non-financial reporting and compliance exists in a lot of places out there, and it can be possible, it can be easy for stakeholders to compare information that arises from different reporting channels for consistency. For example, Dan mentioned one of the claims could be, "None of our products use forced labor".  In the U.S. there's a law called the The Uyghur Forced Labor Prevention Act. That has the rebuttable presumption that products made from a certain area, in China, if you cannot prove that those products were made absent forced labor, the assumption is that they were made with forced labor. And the Customs and Border Protection is seizing products at the docks before they come into the country, and waiting on companies to provide evidence that the products are forced-labor-free.  So if you have claims on your website, or on products, or in contract documents that they're forced labor free, and the Customs and Border Protection is reporting that your goods are being held and not allowed into the country. There is an inconsistency there that can be embarrassing, at a minimum, to companies. And it can cost the company sales, customers, and reputational damage if it turns out that those claims cannot be supported. Dan:                Yes, so just picking up on what Doug was talking with The Uyghur Forced Labor Prevention Act, this is a big stick for the government in they have a presumption of guilt, so to say. That if they suspect that a good has any raw material or input within it because it is in whole or in part of your good that's being imported, is suspected of having forced labor in it, and that means every tier of your supply chain down to the raw material or seed, if it's an agricultural product. If there is a suspicion that it is tainted by forced labor, it will not be allowed into the country unless you can prove otherwise. And, I think, it's going to become, increasingly, challenging for companies to know their supply chain inside and out. And from a fraud perspective, whether any part of that supply chain is deceiving the rest of the supply chain on whether or not it's tainted by forced labor.  I was just reading over the holidays, there is a tremendous report that came out from Sheffield Hallam University, in the UK, around the various risks in the auto industry for being tainted by forced labor in the production of raw materials. it's really a very difficult area, and it is something that our clients are coming to us, asking for help around.  Dan:                Catie, do you have some other thoughts around the regulatory environment in which this is probably just one small piece? Catie:              Yes, Dan and Doug, you both brought up a great point of there are current existing regulations that apply to certain areas of ESG. But what we're seeing is a global movement towards more overarching regulations across different jurisdictions. So, for instance, last year, the European Union approved the Corporate Sustainability Reporting Directive Regulation, also called CSRD, and that sets reporting standards for entities that meet certain EU reporting thresholds.  In the UK, there IS BEIS, which is focused on climate-related disclosures for entities that operate in the UK. And then, of course, for our U.S. listeners, I'm sure you all have heard about the coming SEC final rule when it comes to climate disclosures. We anticipate that being finalized as early as April of this year. But all that to say that the regulatory environment, itself, from an ESG perspective, there is a growing recognition that there needs to be standards that companies adhere to. So that there is comparability across the landscape when it comes to ESG data. Because it is hard for whoever is looking at this data to discern what certain data points may mean because they may be defined differently.  So these standards are helping to create an environment that is more accountable and more comparable which, hopefully, will help clarify some things and clarify the way that you go about reporting. That said, even though some of those regulations are very early stage or haven't been released, yet, there are already consequences for misreporting.  So we saw last year, or in the past couple of years, that Goldman Sachs was fined $4 million and BNY Mellon was fined $1.5 million for what were considering material misstatements. And in the future, we see that more frequent consequences could be around the corner. But I can't speak to what that looks like just, yet. Dan, do you have any experience, or Doug, in terms of any additional consequences that you're seeing for misreporting of ESG data? Dan:                Yes, well, for me, as you said, there are consequences from misstating, publicly, the information. There are just a ton of business consequences of misstating the information. So, for example, I myself was involved in an investigation in which there was a licensor of images for the front of T-shirts and the like. There was a requirement that none of the production would take place in Bangladesh after the tragedy in 2013, in which a building collapsed, killing more than 1000 apparel workers.  And, so, there was a requirement that no production take place in Bangladesh, and there was wide-scale deception on that point. Such that there was a lot of production going on in Bangladesh, but it was being misreported to the licensor as being produced in India or in other jurisdictions throughout Asia. That finding, in the investigation that we carried out, was the subject of whether or not a billion-dollar license would go forward or not. Doug:              I can see several potential risks or consequences for misreporting or misleading content and reporting, and they vary according to the reporting channel. For example, there is ESG content in financial statements, in income statements and balance sheets. There are reserve estimates for contingent environmental liabilities.  Something that's a little newer is asset values for Emission Reduction Credits or expected costs in the future for Emission Reduction Credits, if that's part of a company's strategy for reducing greenhouse gas emissions. Those have a vintage and the value depends on the vintage. If those are, knowingly, misstated, you're subject to all the things that come with that in financial reporting, disclosure controls, and procedures, and the like. For misrepresentation and misreporting in the Form 10-K, the analysts and the investors are using this to make investment decisions. There are shareholders who are quite happy to file proxy filings or to file suit by claiming to be misled for the content in there. Some of those are starting to see the light of day or to get quietly settled. There was an instance of a major European bank, an employee blowing a whistle, publicly, saying that their screening process for companies to include in an ESG index fund was just not very good or, maybe, a sham.  So there's the reputational damage that can be a hit to a company and the market cap for many companies, the reputation, the intangible value, exceeds the value of PP and E - Plant Property and Equipment. So intangible value and brand value is something to watch out for too and that can take a hit, with misrepresentation or loss of reputation in ESG and non-financial matters. Catie:              And, Doug, just to piggyback on that point, there's the financial disclosure side of that, but there's also, as we talked about, the intangible side of that. So customers are increasingly wanting to purchase sustainably made goods, and engage with companies that align with their own personal moral values and beliefs.  And, so, when they learn that whether it's a good that's claiming to be sustainably made is actually unsustainable, you could lose members of your customer base. At times it inspires boycotts and protests and, especially, in the age of digital media, just imagine someone telling their community about their experience, and that going on Twitter, or TikTok, or something of that nature.  Those are some of the risks that we're seeing from not a regulatory penalty approach. But also there are consequences when it comes to your customer base, the value of your brand, and your brand reputation. Doug:              We've discussed a lot of different data, a lot of different stakeholders, a lot of different needs. So how do companies manage this kind of reporting. When everybody wants something different. There are different ways to slice and dice. How does a company get their arms around this and make sure that it's right? Catie:              Yes, that's a great question, Doug. So as I said before, there are a lot of different frameworks out there. But they are working to consolidate the frameworks and to consolidate the data expectations of those frameworks.  From what I'm seeing, it appears that SASB, GRI, and TCFD, all of which I previously mentioned, are emerging as the big three of ESG data disclosure frameworks. And it's important that our listeners understand that while these frameworks are not required for disclosure, they can help guide your reporting. And, ultimately, they can help your company be more aware of any potential fraud risks and avoid being susceptible to associated fraud with those activities and reporting.  Of course, the frameworks, themselves, are not mandatory for disclosure. They are, as I said, guidelines and we talked, previously, about the different regulations that are emerging. I think the thing that's important to know here is that some of these frameworks are being utilized to inform those regulations. So we know that the SEC climate disclosure draws heavily from TCFD reporting framework.  And, so, some of our clients are asking us to conduct TCFD reporting gap analysis to help them prepare for those upcoming SEC-required disclosures. We have clients who are asking us to do assurance readiness services because they know that they will fall in that year one reporting group, the large accelerated filers for the SEC.  And, so, having us test their existing processes, internal controls, things of that nature, and validate that their data is complete and accurate is something that they're doing to prepare for the upcoming regulatory framework. So the way to think about those frameworks is that it's a helpful way for you to organize your disclosures in anticipation of future reporting requirements.  Dan, do you have any thoughts from the fraud risk perspective of how those frameworks can usually help you. In terms of guarding against any potential misreporting or intentional or unintentional? Dan:                Yes, so when I think about this, I usually do go back to the ACFE's Fraud Triangle, thinking about incentives and pressures, the opportunities for fraud, and the rationalizations one might apply to committing those frauds. So when I think about reporting what is the role of that report?  Is it going to a regulator?  Is it going into a corporate social responsibility or a marketing publication? All of those bear different kinds of risks. So in terms of on this reporting topic, that people and companies should be thinking about taking an inventory of all the ways in which that ESG information is going out to the public, across those different channels. And ensuring that as they're building up their capabilities and infrastructure to maintain good data quality, that it is also ensuring consistency across all of those reporting channels.  What I anticipate, and I think we're starting to see it, is that there will be cases where the same information is reported in one channel, but is inconsistent with how it was reported in another channel, and that will be held against the company. You should not be finding yourself saying one thing to the government and something else in a publication. Doug:              Dan, I absolutely agree with that. I would say to this question, it comes back to a familiar trilogy that we hear as the answer to so many questions, and that is people, process, and technology. And I'll start at the end and work my way back, there are many vendors offering technology fixes and even companies, in-house, building technology fixes to gather and report data.  But the data and the information is only as good as the process it took to come up with the data. You can automate the wrong process and just get the wrong answer faster. So you back up to the process and say, "Well, since this non-financial information originates in so many parts of the company, and even from other companies, suppliers, customers, business partners, and the like. What is the process to get them?" There are also challenges I see on reporting periods. Governments, like EPA, may have an annual reporting process. There are companies with a non-calendar fiscal year, who need to report some of this on a fiscal year basis. So where are the reporting periods? What is the process to collect information and report to a state agency, to a stakeholder, to a customer? So those processes need to be nailed down, and that's where that wonderful COSO internal controls framework comes in. Just follow that and apply it as it's appropriate. And because that data and information comes from so many different sources, I encourage people to have the right people involved.  If companies establish a cross-functional team and get folks from all the places who provide this information. Real estate, operations, safety, procurement, R&D if they understand their roles and responsibilities in collecting this information to enable the kind of reporting that Catie has mentioned and others, then that goes a long way to making the process more effective and more efficient. Dan:                Yes, and I would like to add on to what Doug was saying. That in terms of the fact that this information is coming from different parts of organizations, that haven't necessarily undergone third-party assurance procedures. That this is a transition period here where, I think, a broader spectrum of people, within an organization, are going to be changing their mindset around the accuracy and completeness of the data because they know that they are subject to that third-party assurance. Catie:              And, Doug, you had mentioned, I think, very rightly, that having the right team in place is critical to being able to have the right processes and technology also in place, to ensure that your reporting is complete and accurate. And we're seeing on the client side that a lot of our clients don't, necessarily, have the resources in place to start to organize that.  So I wanted to ask, in your opinion, and Dan, feel free to jump in. How important is it to not just assign one person to do all of your ESG reporting? But how important is it to have that cross-functional team approach to these non-financial disclosures? Doug:              I think it is absolutely essential. One structure that I see work a lot is to have a steering committee. To set strategy and to be plugged into those reporting frameworks that you've mentioned, Catie, and some of the customer demands and organizational strategy and where things are going. And a more tactical working group that's closer to operations, and the systems, and controls to really modify those systems and controls and talk to each other.  A couple of things I've seen work really well. I've seen those committees be assembled, and people show up, and they don't know why they're in the room. And it really helps to have a coach or an external resource to help facilitate all that. To make sure that people are talking the right language and not talking past each other. So you get everybody on the same page to take actions in ways that are aligned with the company objectives, that helps a lot.  A couple of functions that I don't see on those teams but, I think, should be there a lot more than they are IT, for sure. And many of our listeners are from accounting, I would say accounting. I don't see on those cross-functional teams as much as I think they should be. Much of what is required for the sustainability reporting, it comes from accounting. You get utility bills from accounting. Get a list of assets from accounting. Get a list of our ten largest customers from accounting. Accounting has the master key to a lot of this information. But the information that's in company systems, in my experience, was not designed for the way the information needs to be reclaimed and used now. So there are some changes that need to be made in accounting to enable this reporting and to enable the systems and controls. To, then, ensure accurate reporting, verifiable reporting, and the fact that we tighten down the controls so that we can prevent the possibility of fraud. Dan:                Yes, great points, Doug. I really appreciate you bringing up the steering committee. Someone at the top of an organization that is there to set strategy. And I think that it is common, and it will become more commonplace, to have that steering committee require that any fraud risk assessments, that are being done within an organization, include ESG fraud as part of what they're doing.  And in conducting a fraud risk assessment that is a stress test, that's looking for ways in which various kinds of scenarios. Such as the scenarios we brought up in our report with the ACFE, of ways in which ESG fraud could be committed. And then looking at whether the controls in place within the organization, are sufficient to prevent and detect or detect those occurrences.  So, Doug, I know that you've been contributing to an exciting report, that's been recently released from the IMA. Could you give us a few highlights in that regard? Doug:              Sure, I'd be happy to. I was one of the primary authors of this document, the only non-CPA on the team. I provided the ESG specialist input for this very important report. It's a COSO report and IMA is, of course, a member of COSO and their leadership had a terrific role in pulling this together. And it will resemble a lot kind of the report you've had major involvement with from the ACFE, on fraud, ESG fraud. In that it begins with a framework that everybody knows and is very familiar with, the COSO Internal Controls Framework, and there's something old and something new.  There is a summary of some of the key points of the COSO Internal Controls Framework, the components, and the points of focus. And on each of the components there's some information demonstrating how the internal controls framework can be applied to ESG.  So that in terms of non-financial management of information, and of reporting, and of communications, and of control environment. It can be applied and it points you in the right direction on how it can be adopted to improve the effectiveness, and the efficiency of company organization, management, and reporting. I encourage everyone to read it and use it. [00:36:50]       < Outro > Announcer:    This has been Count Me In, IMA's podcast. Providing you with the latest perspectives of thought leaders from the accounting and finance profession. If you like what you heard and you'd like to be counted in for more relevant accounting and finance education, visit IMA's website at www.imanet.org.

In this episode we discuss the fraud triangle and why NCUA will always do exams onsite.What is the Fraud Triangle?The fraud triangle is a framework commonly used in auditing to explain the reason behind an individual's decision to commit fraud. The fraud triangle outlines three components that contribute to increasing the risk of fraud: (1) opportunity, (2) incentive, and (3) rationalization.

Marta is the co-founder of NOFRAUD.  NOFRAUD uses AI, data analytics and a library of over 90k terms related to the Fraud Triangle. This is a fascinating area of work to proactively risk score.  It is a tool for fraud professionals to utilize in their work.  

The Fraud Triangle is a very powerful tool used by fraud investigators and anti-fraud professionals in helping to determine how fraud occurs and looking for possible behaviors where fraud is involved. In this episode, we examine the Fraud Triangle. Opening and Closing Music: Penguin music - ModernChillout - Background Music [NCS Release] --- Send in a voice message: https://anchor.fm/gene-tausk/message

Unternehmen sind gefordert, eine breite Palette potenzieller Schadensfälle zu verhindern. Mögliche Täter:innen kommen auch aus dem Unternehmen selbst. Wie können Unternehmen die sie betreffenden Risiken adäquat bestimmen und die Maßnahmen, die sie wirksam schützen, entsprechend identifizieren und umsetzen? Dies diskutieren Christoph Kampmeyer und Kurt Kuckelmanns aus dem Bereich Forensic bei KPMG in Deutschland im Gespräch mit David Rohde. Sie sprechen über Prävention, Risikomanagement und -wahrscheinlichkeiten und Maßnahmen, um schädigendes Verhalten zu unterbinden. Dabei geht es unter anderem um Werte, den Code of Conduct, Kontrollen und das Fraud Triangle, das zwar aus den 1930er Jahren stammt, aber bis heute aktuell ist. Christoph Kampmeyer und Kurt Kuckelmanns geben spannende Einblicke in ihre Arbeit und beschreiben Beispiele für Warnzeichen, bei denen ein Unternehmen genauer hinschauen sollte.

We discuss a range of topics, including: the Fraud Triangle, greed, how to think about enough, how to recover from mistakes, and what we will and won't emulate in fatherhood. 

What's going on at the Center of the Universe in Tulsa, OK? How does the fraud triangle help us understand when people are likely to commit crime? What makes counting nuclear weapons so tricky? All this and more in this week's listener mail. Learn more about your ad-choices at https://www.iheartpodcastnetwork.com

Join Hannah and Steve as they peel back the onion of the 2016 Wells Fargo banking fraud that had been going on since 2011. Learn how the tone at the top encouraged an environment of cross-sell and creating fake accounts for incentives that ultimately cost the company millions of dollars in remedies. Thanks for listening this week! Stay subscribed to True Crime Archives wherever you get your Podcasts. Please rate us on Apple Podcast, we would love to hear your feedback. Follow us on Instagram @truecrimearchivespodcast and Twitter @TCArchivesPod for regular updates, sneak peaks, and our story! Wells Fargo to pay $3 billion over fake account scandal (nbcnews.com) Wells Fargo Fraud - Ethics Unwrapped (utexas.edu) Wells Fargo Gets Into Trouble Yet Again Over Alleged Fraud (forbes.com) The Wells Fargo Cross-Selling Scandal (harvard.edu) wells-fargo-case-study.pdf (wordpress.com) Wells Fargo account fraud scandal - Wikipedia Wells Fargo Fined $185 Million for Fraudulently Opening Accounts - The New York Times (nytimes.com) How Wells Fargo's Fake Accounts Scandal Got So Bad | Fortune

Marta Cadavid is co-founder and CEO at NoFraud, an organization dedicated to fighting fraud by using technology to anticipate criminal behavior. NoFraud specializes in forensic audit, cybersecurity, and investigations of economic crimes. As a Certified Anti-Money Laundering Specialist (CAMS), Certified Fraud Examiner (CFE), AML Anti-Money Laundering Certified Associate (AMLCA), Marta possesses valuable experience that sets her a cut above the rest. She is also Consultant and International Coach of Auditool. Marta discusses how fraud triangle theory can be used to improve fraud detection. Fraud, corruption, waste, corporate abuse and other misbehaviors destroy an organization's value. They are the silent enemy that kills companies, Marta shares. This enemy was the driving force behind the conception of NoFraud; their goal was to be one step ahead of these misbehaviors. They now help corporations build value through the prediction, prevention, and detection of undesirable conduct at the workplace. According to Marta's research, 15-25% of people are never involved in unethical actions. Unfortunately, the larger percentage of people are prone to behaving according to the moment. NoFraud combines fraud triangle theory with artificial intelligence, data analytics and semantics to monitor patterns of keystrokes or communications from an individual.  Resources Marta Cadavid on LinkedIn Email: marta.cadavid.a@gmail.com  NoFraud.la | MartaCadavid.com To learn more, and contact Vincent Walden, please visit Alvarez and Marsal

Julie and Mike discuss the psychological relevance of GoFundMe's decision to cheat the donators for truckers who are opposing mandates. We look at the origin of the fraud triangle and how these variables relate to the current social context and moral integrity.audio editing by: http://JayPrescott.com

In this episode I talk to former NCUA Subject Matter Experts Farrar and Miller on the NCUA Exam Priorities Letter to Credit Unions for 2022. Topics range from Loan Participations, Fraud, the Fraud Triangle, Merit, CAMELS, taping your examiner during official meetings, and more.

In this episode I talk to former NCUA Subject Matter Experts Farrar and Miller on the NCUA Exam Priorities Letter to Credit Unions for 2022. Topics range from Loan Participations, Fraud, the Fraud Triangle, Merit, CAMELS, taping your examiner during official meetings, and more.

I spoke with Stuart Clarke, the head of product for Blackdot Solutions in Cambridge, England, which is an open-source data platform that helps organizations investigate data risks. We discussed the impact of remote work on financial crimes, best practices for financial institutions interested in limiting financial crimes, and the link between environmental conservation and financial crime.

I spoke with Stuart Clarke, the head of product for Blackdot Solutions in Cambridge, England, which is an open-source data platform that helps organizations investigate data risks. We discussed the impact of remote work on financial crimes, best practices for financial institutions interested in limiting financial crimes, and the link between environmental conservation and financial crime.

Enron is one of the largest accounting frauds in U.S. history. Most of us remember that, but many of us don't understand the actual ways that Enron "cooked the books". In our latest episode, our financial experts break down the accounting "fraud triangle" and how Enron got lost in it. 

Do honest people steal? Our guest, Kelly Paxton investigates and researches low level crimes such as book-keeping fraud; also known as Pink Collar Crime. She discusses how a hostile work environment and the prospect of financial difficulties at home can lead “good” people to rationalize dishonest behavior. Kelly Paxton is a former federal agent who was used to dealing with “bad guys.” Once she started working embezzlement cases, she quickly realized that honest people steal.  The term pink-collar crime describes embezzlement type crimes that are typically committed by females. Can a man be a pink collar criminal?  The simple answer is yes.  It's the position not the gender but in these "pink" positions there are just more women than men.    Topics we Discuss With Kelly Paxton  (4:25) Welcome and speed round questions. (6:39) Why you should be concerned if your bookkeeper never takes a vacation. (7:15) What is Pink Collar Crime?  (10:20) How Kelly's career and curiosity lead her into investigating Pink Collar Crime. (14:48) What is The Fraud Triangle? (19:14) Do women steal differently than men?  (28:35) What are the common behaviors of people who embezzle?  (31:17) Who benefits and who takes the blame for embezzlement?  (37:53) Who should you trust? (42:39) How people rationalize their dishonesty. (45:49) What should companies do to prevent pink collar crime?  (49:49) Kelly's favorite music and playlists.   Join us on our follow-on discussion in Episode 239 where Kurt and Tim have a Grooving Session on what Kelly has brought up in her interview and how we can apply insight from her interview into our own businesses. © 2021 Behavioral Grooves Links Kelly Paxton: https://www.linkedin.com/in/kellypaxton/ Kelly Paxton, Embezzlement: How to Detect, Prevent, and Investigate Pink-Collar Crime: https://amzn.to/3i57hN1  Great Women in Fraud: https://greatwomeninfraud.com/  Great Women in Fraud Podcast: https://podcast.greatwomeninfraud.com/  Dan Ariely: https://danariely.com/  The Dishonesty Project: https://www.thedishonestyproject.com/film/  Pink Collar Crime: https://pinkcollarcrime.com/what-is-pink-collar-crime  How to Have a Good Day: Harness the Power of Behavioral Science to Transform Your Working Life by Caroline Webb: https://amzn.to/3eAaNhJ  Episode 33: Caroline Webb: Having a Good Day: https://behavioralgrooves.com/episode/caroline-webb-having-a-good-day/ Go Fraud Me: http://gofraudme.com/  Rita Crundwell: https://en.wikipedia.org/wiki/Rita_Crundwell  Talking to Strangers: What We Should Know about the People We Don't Know by Malcolm Gladwell: https://amzn.to/3i1sKGw  Duped: Truth-Default Theory and the Social Science of Lying and Deception by Timothy Levine: https://amzn.to/3ehpWUC  Big Little Lies: https://en.wikipedia.org/wiki/Big_Little_Lies_(TV_series)  Episode 86: Christian Hunt: Mitigating Human Risk and The Algorithmic Mind: https://behavioralgrooves.com/episode/christian-hunt-mitigating-human-risk-and-the-algorithmic-mind/ Behavioral Grooves Patreon: https://www.patreon.com/behavioralgrooves Musical Links Foo Fighters “The Pretender”: https://www.youtube.com/watch?v=SBjQ9tuuTJQ  Harold Van Lennep “Liberation”: https://www.youtube.com/watch?v=EEzMeDybBG0  Micheal Kiwanuka “Cold Little Heart”: https://www.youtube.com/watch?v=nOubjLM9Cbc&ab_channel=MichaelKiwanukaVEVO   

Leandra Lederman, professor of tax law at Indiana University Bloomington, joins the Business Scholarship Podcast to discuss her article The Fraud Triangle and Tax Evasion. Lederman uses the fraud triangle, a well-studied topic in the accounting literature that is often missing in other contexts, to frame and examine tax fraud and compliance. This episode is hosted by Andrew Jennings, assistant professor at Brooklyn Law School.

Hey guys! This season, we are focused on taking preventative measures to avoid fraud and other financially improper conduct related to nonprofits. In this episode, we are examining what makes up a “fraud triangle”. We look at several factors that can lead someone to commit fraud, such as lack of internal controls, pressures both inside and outside the organization, and rationalizing whether the act of fraud is wrong. This is an informative episode that can help you determine if there are opportunities for financial wrongdoing in our organization. Tune in!   Highlights Opportunity for Fraud to Happen due to lack of internal controls Internal and external pressure from the organization People rationalizing potential wrongdoings   Connect with Chyla and CNRG Accounting Advisory: Follow us on Instagram: https://www.instagram.com/cnrgadvisory/  Like us on Facebook: https://www.facebook.com/cnrgadvisory/  Follow us on Twitter: https://twitter.com/cnrgadvisory  Connect with us on LinkedIn: https://www.linkedin.com/in/chyla-graham-cpa-94a30280/  Take the Impact Basics course - https://cnrg-school.thinkific.com/courses/impact-basics  Book a Strategy Session - https://calendly.com/cnrg/strategy

Hi Welcome to ValuationPodcast.com - A podcast and video series about all things related to business and valuation.  My name is Melissa Gragg, and I am a valuation expert witness in St. Louis Missouri.   I have the pleasure of discussing Pink Collar Crime, Fraud and Embezzlement with Kelly Paxton – a private investigator and certified fraud examiner in Portland Oregon.  Welcome Kelly!  How did you get into the fraud world and become a private investigator? What is Fraud?  What is Pink Collar Crime? What is embezzlement? Does fraud happen in all industries? How can you help as a certified fraud examiner (or CFE) with a business that has been embezzled? How can you be proactive when selling a business and not be concerned as a buyer that fraud has taken place? Tell me about a case where valuation was skimped on and how it hurt the parties?   Melissa Gragg CVA, MAFF, CDFA Expert testimony for financial and valuation issues Bridge Valuation Partners, LLC melissa@bridgevaluation.com http://www.BridgeValuation.com http://www.ValuationPodcast.com http://www.MediatorPodcast.com Cell: (314) 541-8163 Kelly PaxtonCFE, PI SPEAKER & FRAUD CONSULTANT  PHONE: (503) 521-6167 EMAIL: kelly@kellypaxton.com WEBSITES: kellypaxton.com  • pinkcollarcrime.com https://www.linkedin.com/in/kellypaxton https://twitter.com/pdxcfeSupport the show (http://valuationpodcast.com)

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the actions of Denver Mayor, Michael Hancock. Just before Thanksgiving he told folks to stay at home to avoid Covid-19 transmission and then promptly traveled to Mississippi for the Thanksgiving holidays. Some of the issues we consider are:  Is there always an inherent conflict in a human leader? How do leaders rationalize misconduct? What are the dangers when they do so? Do as I say, not as I do. Are we all simply our parents? What is the role of compliance? How do Hancock’s actions fit into the Fraud Pentagon? Resources For more information see Matt’s blog post: More Misadventures in Leadership  For more information on the Fraud Triangle see Jonathan Marks’ blog post: Fraud Pentagon Learn more about your ad choices. Visit megaphone.fm/adchoices

Hello to you. My name is Michael Santos and on behalf of everyone on our team, I welcome you. Our websites include PrisonProfessors.com and ComplianceMitigation.com.   We offer services to help people and businesses with risk mitigation and avoiding government investigations.   For those who have been targeted for prosecution, we create mitigation strategies. We help with sentencing and preparations for the journey ahead.   Visit us at either Prison Professors dot com or compliance mitigation dot com. Call or text 949-205-6056.   Episode: 153: Why Every Business Should Invest in Compliance Training   If we ask any group to give us their impression of successful technology companies, we’re likely to hear the following names: • Apple, • Google, • Facebook, • Amazon, and • Microsoft. Many of us would consider the above-mentioned companies as models of excellence. They’re famous for creating trillions of dollars in value, creating millions of jobs, generating billions of dollars in tax revenues, and providing enormous value to consumers. Besides being success stories, the companies share something else in common. Each of the above-mentioned companies has been the subject of a government investigation. Our team at Compliance Mitigation does not make a judgment call with regard to the reasons behind the investigation, or the usefulness that the investigation would serve. Rather, we want more entrepreneurs, business leaders, and team members to understand how government investigations can threaten businesses and careers. The more a person knows, the more equipped a person becomes to make better decisions—hopefully to avoid being brought in as a witness, a subject, or a target of a government investigation. From our perspective: • Business leaders define success by solving problems for customers, bringing value to shareholders, and creating jobs that contribute to vibrant communities. • When investigators begin their task, they define success by obstructing business operations, or complicating the lives of business leaders and the entire teams that they target. Big-government leaders do not limit their attacks to the most successful companies. Elected officials create many government agencies that investigate business operations, business leaders, and people who have decision-making power in businesses. That means even small companies—and leaders of those companies that have decision-making power—are also vulnerable to government investigations and to charges for white collar crimes. For that reason, it makes sense for business leaders to learn about government investigations. That insight can help people involved in businesses both save and make money. You might ask, “How can investing in compliance help a company or people make more money?”  • Compliance is all about transparency. It’s about documenting processes and following best-practice approaches to business. The more we train people how to follow such procedures, the more effective we become at messaging. If we communicate well, we’re more successful at showing the value proposition we offer. How does investing in compliance help a company or an individual save more money? • Investing time and energy to develop effective compliance systems is like an insurance policy. It can lead to lower business insurance costs, and it can lower the enormous risks that business owners and decision makers have to reserve for litigation expenses. Good compliance systems can also lower the risk levels to corporate fraud. Besides saving or making money, investing in ongoing compliance training represents an excellent insurance policy for the company. No company wants to become the subject of a government investigation. They are costly. In many cases, those costs exceed millions of dollars, both for the business and in many cases, for individuals. Investigations, potentially, can obliterate a business and lead to loss of liberty for some people.   Evaluation: In June 2020, the Department of Justice’s Criminal Division updated its Evaluation of Corporate Compliance Programs. Essentially, the government white paper offered guidelines for prosecutors to consider when they deliberated over offering leniency, non-prosecution agreements, or deferred-prosecution agreements to businesses. According to the guidance, prosecutors must question the business as follows: 1. Is the corporation’s compliance well designed? 2. Is the program being applied earnestly and in good faith? In other words, is the program adequately resourced and empowered to function effectively? 3. Does the corporation’s compliance program work in practice? If we know that prosecutors will ask those questions when assessing a business’s compliance program, then business leaders and team members should ask similar questions. By investing time, energy, and resources to understand the importance of compliance, leaders can design a best-practice approach in the design of their compliance training. Large companies may deploy resources to hire white-glove law firms that specialize in risk management. Those law firms may earn millions of dollars in fees by doing a deep dive to understand a company’s operations. They will perform risk assessments to identify potential problems, assessing the regulatory landscape, the potential clients and the business partners, as well as transactions with foreign governments, payments to foreign officials, use of third parties, political contributions, and so forth. Small to mid-size companies may not have the resources to hire such law firms. Yet if they’re doing business, their lack of resources will not make them any less vulnerable to investigations and potential prosecution. In fact, those small- to medium-sized businesses may be easier targets for government investigators. For this reason, all businesses benefit by helping team members learn more about the real-life consequences that followed for people that lost their liberty as a result of government investigations. Such training spreads awareness on the collateral consequences that follow bad decisions made during the course of business. In making people more aware, our team at Compliance Mitigation can lessen risks for individuals, and for businesses that want to show a commitment to minimizing problems with regulators. Companies that want to minimize risk levels would do well to train their team members. As we say at ComplianceMitigation.com, we did the time so you won’t have to.   Corporate Fraud: Internal corporate fraud is an ever-growing problem. Government prosecutors bring charges against thousands of people every month for white collar crimes. Those charges leave businesses vulnerable to ongoing problems, including massive legal fees, large fines, and potentially, criminal liabilities. Management leaders may not have a clear process on how to prevent fraud, or how to respond if they uncover a fraud. We offer this introductory compliance course to assist companies with the following objectives: (i) Help all team members understand the implications of a government investigation, (ii) Identify best practices within corporate operations, and encourage employee compliance, (iii) Improve messaging and corporate storytelling, (iv) Minimize risk to litigation, (v) Teach businesses how to develop a best-practice approach to respond to a government investigation, (vi) Develop a mitigation strategy in the event of a government investigation. We encourage company leaders to use the modules our team at Compliance Mitigation creates to help more people understand the costs and collateral consequences of a government investigation. Strength comes through proper preparation. Members of our team have worked with numerous entrepreneurs that didn’t know their business practices violated regulations, or how their policies could expose them to the enormous costs of litigation or a government investigation. For example, a small business that advertised debt-relief services accepted advance payments from consumers. The business owner hired scores of telemarketers that sold the service. By accepting advance payments from consumers, the business leaders and decisions makers made themselves vulnerable to government investigations. They didn’t understand the Federal Trade Commission’s prohibitions against collecting advance fees.   Nor did they understand how a government investigation could lead to: • litigation, • an asset freeze, and • forfeitures that would cripple their business. Good compliance training helps leaders make better decisions. By investing time to both learn and teach, leaders can create a culture that minimizes exposure to risks in an era of big government. Larger companies have different complications. People become complacent, expecting that they’re operating without risk to regulation or interference from government. Sadly, many rank-and-file employees get dragged into investigations. Their responses to the investigations can bring them into further problems. Our nation’s prison system confines thousands of people that once worked in large companies. Prosecutors convicted those people of white-collar crimes, even though the people professed to be doing their jobs without any knowledge that they were breaking laws. Other people began working in a company with the best of intentions. Yet something happened during the course of the person’s career. Thinking that they could get away with something, they engaged in behavior without fully understanding the consequences. For example, consider the case of David Smith, who faced charges for crimes he committed while on the job as a manager at Quest Diagnostics. David concocted a reimbursement scheme, creating systems that would lead his employer to reimburse him for fraudulent expenses that ran through a complex web of transactions. Smith created fake companies, invoices, and expense reports for payments he’d supposedly made on Quest’s behalf. An internal investigation revealed that Smith had forged his boss’s signature. The internal investigation uncovered losses totaling more than $1.2 million. Quest referred the case to the FBI. A judge sentenced Smith to five years in prison. Beside the financial loss and Smith’s criminal liability, the distraction undermined confidence in Quest Diagnostic’s management team.   Better compliance training serves companies and individuals by: • Broadening an awareness of the consequences that follow white collar crime, • Helping people think before they compromise their values, • Providing transparency into businesses processes, potentially lessening occurrences of internal corporate fraud.   Fraud Triangle: People like David, in the example above, may not set out to engage in fraudulent behavior. Educators identified a “Fraud Triangle” that, theoretically, created a perfect storm for fraud. The three corners of the triangle include: • Opportunity: A person like David Smith had to be in the position that would allow him to create the scheme. If he were not in a managerial position, he would not have been able to initiate the scam. • Pressure: David Smith’s supervisors may have considered him a competent, trustworthy employee. They may not have known pressures he felt in his personal life. • Rationalization: A person like David Smith may think that the company is so big and profitable that no one would even notice the missing funds.   Although hindsight is 20/20, we can always learn from real case studies: • What if Quest Diagnostics invested more resources in its compliance systems? • What if the training systems included lessons on the high costs of corporate fraud, both for the business and for the people that knowingly engage in white-collar crime? • David Smith may have been in a position to commit the fraud, he may have felt pressure, and he may have been able to rationalize his crime. The question remains: would better training have convinced him to act with more integrity? Consider the example of Walt Pavlo, a person who writes a popular column for Forbes online. In January 2001, a federal judge sentenced Walt Pavlo to 41 months in federal prison. The sentence followed Pavlo’s conviction for white-collar crimes that included money laundering, wire fraud, and obstruction of justice. Walt had worked hard to earn an engineering degree and an MBA. Those credentials led to a leadership position at MCI WorldCom, one of the world’s most valuable companies at the turn of the century. In his role as a finance manager, Walt described pressure he felt to report higher revenues than the company earned. The supervisors that oversaw his department wanted to boost WorldCom’s financial performance, likely with pressure from the top. When Walt saw that other leaders entered fraudulent transactions, he felt justified to create his own fraud to enrich himself. Ordinary people may not expect a multi-billion-dollar, global corporation like WorldCom to engage in fraud. Neither would they expect a family man with a professional education to exploit the fraud he discovered—then create his own scam. Members of our team have met and interacted with thousands of people that served time for white-collar crimes. Despite leading or working with companies that had compliance-training manuals, they did not get the message.   Human Stories of Noncompliance and Fraud: To make compliance a part of any corporate culture, leaders should include regular training that includes real-life stories. Those stories will help all team members appreciate the magnitude of problems that come with a government investigation. When leaders and team members grasp the severity of consequences, fewer people will participate in the type of behavior that can increase risk levels for businesses and organizations. As an added bonus, by investing in compliance training that works, businesses and individuals may qualify for leniency or mitigation in the event that investigators begin asking questions. It’s impossible to predict who might commit fraud within an organization. The vast majority of people that engage in white-collar crime do not have criminal histories. Yet as the theory of the fraud triangle suggests: • those people may be in a position to commit fraud; • they may feel pressure that induces them to participate in fraud; • they may rationalize their behavior for any number of reasons. Good training may lower risk levels for businesses and for individuals. Consider statements that our team at Compliance Mitigation found online:  According to Carnegie Mellon University’s report on Insider Fraud in Financial Services, employees working in accounting, operations, sales, upper management, customer service, purchasing, and finance commit 75% of all corporate fraud.  Employers frequently assume that people always act with integrity, even after being hired. Since businesses incentivize managers to focus on meeting targets and goals rather than detecting fraud, commitment to ongoing compliance training frequently suffers.  In a report that Intel published, Grand Theft Data, inside sources cause 42% of all company security breaches. Those security breaches can lead to government investigations and litigation, exposing businesses and individuals to enormous levels of stress.  Corporate fraud represents one of the government’s highest criminal priorities. The FBI estimates that white-collar crime costs Americans more than $300 billion annually. Those crimes run the gamut, from accounting schemes designed to deceive management, investors, auditors, and analysts about the true financial condition of a company, to cases involving fraud on the government and insurers, vendors, and clients.  Government agencies scrutinize telemarketers, brokers, crypto currency businesses, cannabis, financial services, and the healthcare field.  The FBI partners with numerous agencies to capitalize on their experience in specific areas such as securities, taxes, pensions, energy, and commodities. The Bureau has placed greater emphasis on investigating allegations of these frauds, and FBI agents frequently broaden their reach by partnering with other agencies, such as the:  Securities and Exchange Commission  Commodity Futures Trading Commission  Federal Trade Commission  Internal Revenue Service  Department of Labor  Federal Energy Regulatory Commission,  US Postal Service  Secret Service.  The Department of Homeland Security has its own independent mandate to criminally pursue fraud, financial crimes involving blackmail, contract fraud, grant fraud, money laundering, bribery, immigration fraud and program theft.   Government investigations are likely to increase as a result of COVID-19. The CARES Act, subjects companies to additional scrutiny by establishing three new oversight bodies:  (i) the Office of the Special Inspector General for Pandemic Recovery within the Treasury Department;  (ii) the Pandemic Response Accountability Committee, consisting of the IGs for Departments of Defense, Education, Health and Human Services, Homeland Security, Justice, Labor and the Treasury, among others; and  (iii) the Congressional Oversight Commission.  In fact, dozens of cases have already been brought in connection with abuse of the Payroll Protection Program (PPP). The Value Proposition Building a compliance program will protect businesses, shareholders, communities, and individuals. On the surface, the investment may feel like a wasteful expense and hassle. Yet effective compliance programs represent an opportunity to both increase revenues and decrease risk for debilitating costs. They provide an excellent return with peace-of-mind. As an aside, they may pay for themselves in a variety of ways, including: • Eliminating fraud, waste, and theft of company assets • Creating a more inspiring corporate culture with transparency • Opening opportunities for increased efficiencies An effective program will improve internal communications and messaging with prospective customers. Good compliance metrics may also put a company in a good position for a deferred prosecution agreement (DPA), which may avoid total disruption. In these cases, the government brings an action but realizes it needs the assistance of the company itself in order to prove wrongdoing by the individuals involved. For example, federal prosecutors entered into Deferred Prosecution Agreement with Samsung Heavy Industries in 2019. The company agreed to settle matters by paying a fine and cooperating in with the government’s investigation of bribery. The DPA likely saved millions of dollars for shareholders and may have spared some people from going to prison. Maintaining compliance equips employees to do their jobs well, reach career goals, and keep customers happy. To paraphrase Warren Buffet: • It takes five years to grow a reputation, and five minutes to ruin it.   An integrated compliance program becomes a valuable corporate asset. Leverage the compliance training so that people can empower themselves to reach their highest potential. By showing everyone to act in accordance with corporate values, leaders protect the enterprise, the team members, and shareholder value.        

Hi Welcome to ValuationPodcast.com - A podcast and video series about all things related to business and valuation.  My name is Melissa Gragg, and I am a valuation expert in St. Louis Missouri.  I have the pleasure of discussing Fraud and Forensic Accounting with Chris Ekimoff, a certified fraud examiner and CPA in Washington DC. Chris also serves as an expert witness in matters of SEC financial reporting, complex GAAP accounting policy issues, whistleblower allegations and mortgage-backed securities litigation. Welcome Chris!!   Let's first discuss some basics regarding this topic and maybe shed some light on the industry.  How did you get into forensic accounting? What does “forensic accounting” mean, and what does it mean to you and your clients? What are some of the unique challenges faced as a forensic accountant? Any good fraud stories you can share from past experience? What areas do you see as common in the forensic accounting and fraud space? Investing Cybersecurity Digital Assets   Melissa Gragg CVA, MAFF, CDFA Expert testimony for financial and valuation issues Bridge Valuation Partners, LLC melissa@bridgevaluation.com http://www.BridgeValuation.com http://www.ValuationPodcast.com http://www.MediatorPodcast.com Cell: (314) 541-8163  Chris Ekimoff CPA, CFF, CFE, CGMA - Director Areas of focus: Forensic Accounting, Dispute Advisory Washington, D.C. chris.ekimoff@rsmus.com Support the show (http://valuationpodcast.com)

We discuss how the Fraud Triangle relates to the business world, the Star Wars galaxy, and the actions of chronic TDS sufferers. --- Support this podcast: https://anchor.fm/conspiracyintheforce/support

Hi Welcome to ValuationPodcast.com - A podcast and video series about all things related to business and valuation.  My name is Melissa Gragg, and I am a valuation expert in St. Louis Missouri.  I have the privilege of interviewing Ben Allen of Allen Forensics today. He is a forensic investigator and certified fraud examiner in Dallas, Texas and we will be discussing Third-Party Fraud and tips on how to “prevent identity fraud” in this podcast.  Welcome Ben!!   What is fraud or third-party fraud and how is it carried out? Why should it matter to me? Why is this type of fraud so easy to undertake? Who are the perpetrators of this fraud? Who do they target? What role does the financial institutions and law enforcement play in this? How can I protect myself from being a victim? If it's happened to me in the past, how can I prevent it from happening again? What is a certified fraud examiner and do I need to hire one? Tell us more about your firm and the services you provide.   Melissa Gragg CVA, MAFF, CDFA Expert testimony for financial and valuation issues Bridge Valuation Partners, LLC melissa@bridgevaluation.com http://www.BridgeValuation.com http://www.ValuationPodcast.com http://www.MediatorPodcast.com Cell: (314) 541-8163  Ben AllenMBA, CFE Managing Partner Cell: (903) 818-1409 Email: ben@allenforensics.com Support the show (http://valuationpodcast.com)

99% Certified Podcast - Episode 009 Topics: Sun Gazing, VHS Tapes, The Pirate Bay, Vaccines, Working From Home, Older Colleagues, Pre-nups, South Vs East, What Is Crime?, Moral Vs Legal Crime, Good Vs Bad Behaviour, The Fraud Triangle, Bait Car, Entrapment, Finding £100k, Ethical Crimes, Stealing Food, Doorstep Robbery, Nonce Hunting, Decriminalised Drug Use, Anthony: Morphine Story, Narco-Terrorism, Baz: Shakedown Story, Anthony: Failed Robbery Story, Dee: Stolen Goods Story, Sunny: Border Control Story, Anthony: Marijuana Story, Dee: Robbery Story, Brick Phones, Baz: Pizza Scam Story, Stealing Food From Housemates ... What is the difference between legal and moral crime? What would you do if you found £100K? How do you survive a shakedown? The 99% Certified provide a hard-hitting analysis as they don their bally's and black gloves and leng down some truth on crime in our society. Follow us on social media. Twitter: @99percent_certi Insta:@99percent_certi Anthony Menezes: Insta @ant_menezes7 Sunny Singh: Insta @real_sunnysingh Baz: Insta @b.baz11 Music: The 99% Certified Themetune ©, Sound effects - 'The Richard Pryor Dialogue' - 1976, 'Shook ones (part 2)' - Mobb Deep, 1995

Podcast explaining Fraud Triangle and Ethics in International environment topic from CMA-US-Part-2-Section-F-Ethics

Nationally renowned 'Pink Collar Crime Expert', Kelly Paxton shares her journey of identifying and catching those pretty little criminals lurking in your business. She shares the blaring warning signs often missed. Who's likely to be the culprit in your company, the simplicity of the paper trails, the #1 misconception, and the BEST money you could spend after being a victim. Kelly candidly unveils the 'No-brainer' Fraud Triangle. And, what to do when that little voice is telling you something is wrong! A MUST listen to episode for any business owner!

In this two part series, John Michael Kledis of Peridot Consulting discusses what he does as a Certified Fraud Examiner. In this Part 1 we explore first the top 10 well known fraud cases in US history such as Madoff, FIFA, Enron and more. We also review the local Asheville cases of Fraud from small businesses to our local government.  We also explore the basics of fraud - the Fraud Triangle - what three elements usually exist that create an environment for fraud to happen? How can companies setup internal controls to prevent, discourage or detect fraud? What is a Fraud Risk Assessment and what are the three main types of fraud schemes?

On this episode, we’re putting Freud to fraud and getting inside the minds of crooks. Today’s white collar criminals have decades of technological evolution at their fingertips, creating new opportunities for fraudsters to inflict crippling loss to organizations. Which means it’s time to update and expand the elements of the traditional Fraud Triangle, to account for this new and vastly different world. The Fraud Pentagon Donald Cressey created the original concept of the Fraud Triangle way back in the 1950s to explain why someone might decide to commit fraud. The three original elements of the triangle are Pressure, Opportunity, and Rationalization, but we need to be gravitating more toward the advanced meta-model of fraud which also considers the act of concealment strategy and the conversion piece. This introduces two new elements to the Fraud Triangle, expanding it into the Fraud Pentagon:  Arrogance, especially unchecked arrogance, enables individuals to see themselves as superior or entitled to the point where policies and laws simply do not apply to them. Competence contributes in two ways: a greater understanding of procedures expands on the Fraud Triangle’s Opportunity element, but it also enables them to create a wall of trust that shields them from suspicion. Get inside the mind of a fraudster  Let’s take a look at Sam Antar, the CFO of Crazy Eddie.  For Antar, arrogance was not only the foundation on which Crazy Eddie was built, it was the soil on which the seeds of fraud were planted. Most people aren’t willing to start a public company for the main purpose of defrauding the public, and as far as this fraudster goes, it takes a real amount of arrogance to do that.  His actions also perfectly represent the two ways a fraudster can use competence to steal. He knew the business of accounting and how to socially control the situation to Crazy Eddie’s advantage. He was a nice guy. He knew he had to get people to like him, trust him, and respect him to lower their levels of skepticism. If you’re nice to people, they’ll be nice to you — like looking away or not asking the tough questions.  What you can do By utilizing all five elements, you’re going to be more able to identify potential risks beyond legitimate individuals who simply have arrogance and competence as part of their persona.  First, start with a hands-on cultural assessment to determine the ethical pulse of your organization. Next, make it known to your board and ethics team that you have zero fraud tolerance within the organization, including at the top. Finally, make periodic checks to monitor the pressure points and values that affect individual behaviors.  Final thoughts We need to pay more attention to the human element of fraud. In doing so, we’ll understand fraud a lot better and be able to build more effective controls. 

On this episode, we’re putting Freud to fraud and getting inside the minds of crooks. Today’s white collar criminals have decades of technological evolution at their fingertips, creating new opportunities for fraudsters to inflict crippling loss to organizations. Which means it’s time to update and expand the elements of the traditional Fraud Triangle, to account for this new and vastly different world. The Fraud Pentagon Donald Cressey created the original concept of the Fraud Triangle way back in the 1950s to explain why someone might decide to commit fraud. The three original elements of the triangle are Pressure, Opportunity, and Rationalization, but we need to be gravitating more toward the advanced meta-model of fraud which also considers the act of concealment strategy and the conversion piece. This introduces two new elements to the Fraud Triangle, expanding it into the Fraud Pentagon: Arrogance, especially unchecked arrogance, enables individuals to see themselves as superior or entitled to the point where policies and laws simply do not apply to them. Competence contributes in two ways: a greater understanding of procedures expands on the Fraud Triangle’s Opportunity element, but it also enables them to create a wall of trust that shields them from suspicion. Get inside the mind of a fraudster Let’s take a look at Sam Antar, the CFO of Crazy Eddie. For Antar, arrogance was not only the foundation on which Crazy Eddie was built, it was the soil on which the seeds of fraud were planted. Most people aren’t willing to start a public company for the main purpose of defrauding the public, and as far as this fraudster goes, it takes a real amount of arrogance to do that. His actions also perfectly represent the two ways a fraudster can use competence to steal. He knew the business of accounting and how to socially control the situation to Crazy Eddie’s advantage. He was a nice guy. He knew he had to get people to like him, trust him, and respect him to lower their levels of skepticism. If you’re nice to people, they’ll be nice to you — like looking away or not asking the tough questions. What you can do By utilizing all five elements, you’re going to be more able to identify potential risks beyond legitimate individuals who simply have arrogance and competence as part of their persona. First, start with a hands-on cultural assessment to determine the ethical pulse of your organization. Next, make it known to your board and ethics team that you have zero fraud tolerance within the organization, including at the top. Finally, make periodic checks to monitor the pressure points and values that affect individual behaviors. Final thoughts We need to pay more attention to the human element of fraud. In doing so, we’ll understand fraud a lot better and be able to build more effective controls.  Learn more about your ad choices. Visit megaphone.fm/adchoices

In this special five-part podcast series, I interview John Gill, the Vice President for Education at the Association of Certified Fraud Examiners (ACFE). In this series, John discusses five well-known fraudsters; including what caused them to engage in fraud, the fraud scheme they employed and how they were caught. More significantly we tie this what compliance professionals need to have in place to detect and prevent corruption.  In this Episode 1, we discuss Nathan Mueller and the Fraud Triangle. Some of the highlights include: How does the Fraud Triangle help to explain Mueller’s fraud?How can everyday pressures lead to an employee engaging in fraud?How does a merger provide cover for a subsequent fraud?What led to Mueller’s downfall and being caught? For a free Fraud Risk Assessment Tool, click here. For more information on the ACFE, click ACFE.com.  Learn more about your ad choices. Visit megaphone.fm/adchoices

The Dental Amigos were happy to host David Harris, Chief Executive Officer of Prosperident, the world's largest firm investigating financial crimes committed against dentists. In addition to being a good guy, David is a licensed private investigator, a CPA who is “dual certified” in fraud investigation and a tremendous resource for the dental industry. Paul and Rob chatted with David Harris about employee theft and fraud in dental practices: “Needy Thieves v. Greedy Thieves,” the Fraud Triangle and the importance of the distinction between “Delegation” and “Abdication” in dental practices. Our listeners can contact David Harris at david@dentalembezzlement.com, through his firm's aptly titled website at www.dentalembezzlement.com or by calling 888-398-2327. David has also graciously made his Embezzlement Risk Assessment Questionnaire available for free through February 28, 2019 for our listeners (regularly a $139.00 value) which can be accessed by clicking the following link: https://www.prosperident.com/embezzlement-risk-assessment-questionnaire-giveaway-for-dental-nachos/

In this podcast, I chat with one of the authors, Jonathan Marks, a partner at Marcum LLP, on the limitations of the Fraud Triangle and why a new model can be helpful in the modern fraud detection and prevention context. Learn more about your ad choices. Visit megaphone.fm/adchoices

Today, I want to discuss how to assess for your internal controls regime for international operations. It is incumbent that you need to review as much information so you can to understand the financial and operational structure of an entity and how the financial and operation structure outside the US is integrated with the corporate headquarters, or the US business unit’s financial and operation structure, if the foreign operation is part of a US business unit.  You could begin with the Transparency International (TI) Corruption Perceptions Index (CPI) to garner a sense of the reputation of the country in which your business unit is located, as well as the CPI for all other countries in which the location either markets business or has current customers. Another area for inquiry or review is the scope of your operations at a location outside the US. This means you will need to consider your sales model, whether employee based or primarily using third party representatives. You will also need to consider if such third party representatives are coming into a commercial relationship with your company through your supply chain.  Other areas of inquiry should include whether your company’s finance and accounting staff produce financial statements that are integrated into the parent’s financial statements; whether your international business locations utilize a local bank account for local sales receipts as well as funds transfers from the US and whether the account has local check signers and whether dual signatures are required on the checks. You may also want to consider the extent to which local disbursements are made in local currency and, of course, is there a local petty cash fund.  As with many other areas around internal controls, it is important to consider the local Delegation of Authority (DOA) and whether it is consistent with your corporate DOA. Some of the considerations regarding the local DOA should extend to which corporate or US business unit approvals are required for transactions initiated locally, such as: (1) Approval of vendor invoices, (2) Disbursements of funds, including wire transfers; (3) Execution of facilities leases; (4) Execution of contracts with agents; and (5) Approval of pricing and credit terms to customers and distributors. You should also review whether the local DOA provides appropriate segregation of duties at the local business unit level.  You should consider how sales of product are conducted. For example, is an inventory maintained at the local operation for shipment to customers? Are products drop shipped from US directly to the customers of the local operation? Are products drop shipped to distributors for delivery to the ultimate customer?  Hopefully you are already doing the above but you should review what is being done to determine if employees or local contractors who are local nationals have gone through your due diligence process so that they have been properly vetted to determine whether they are government officials in any capacity or are relatives of government officials. Along the lines of a more formal FCPA analysis you should review to see if there has been any investigation of alleged fraud, including FCPA violations, at the location and if so, what were the results of the investigation? In the area of customers, you should review with whom each international location does business to determine the extent to which its current customers are local government entities as well as the extent to which the location is pursuing sales activities for other local government entities.  If there has not been a sufficient assessment of controls, the compliance professional must then decide how to best determine whether the local controls are sufficient to satisfy the requirement of the FCPA and accurately reflect all transactions and prevent concealment of improper transactions. Some of these considerations would be an inadequate segregation of duties because the separation of responsibility for physical custody of an asset from the related record keeping is a critical control. In practice, this means that persons who can authorize purchase orders (Purchasing) should not be capable of processing payments (Accounts Payable). Further, the employee who prepares the deposit should not post the receipts to the customer accounts. You should look to see if there is inappropriate access to assets. If there is internal controls should be created to provide safeguards for physical objects such as inventory and cash, restricted information, critical forms, and update applications. This means that an employee who only needs to view computer information should be restricted to Read and File Scan access and should not be granted Write and Create access. Moreover, controls should prevent the unauthorized removal of resale inventory and movable fixed assets from the premises.  It is not necessary to prove a bribe to have been paid in order to have an enforcement action against a company for violation of the internal controls provisions of the FCPA.  In the SEC enforcement action against Smith & Wesson, that was the situation. It was this lack of effective internal controls, not the payment of a bribe, which was the basis for the civil enforcement action. This means that you should look to make certain the situation is not one of form over substance, where controls can appear to be well designed but still lack substance, as is often the case with required approvals.  Such a situation could arise in several different scenarios. The first is where an account manager's signature attests to the accuracy of the payroll voucher information, but if the account manager does not have assurance that the supporting time records are accurate, the approval process lacks substance. Other examples are where a supervisor who approves expense reports but routinely does not look at the supporting documentation; a Country Manager provides a true control as an approver; or where the Country Manager or the local Finance Manager has ability to conceal the true nature of transactions without detection by anyone else.  Another important area involves sales and compensation for the international business unit in question. On the sales side of the equation, you review the three-year historical sales for the location and what are the budgeted sales for the upcoming year. This can give insight into the relative pressure on employees to grow the business and, accordingly, the possibility of an employee seeing a bribe as a good way to grow the business. The inquiries can lead to questions about compensation such as what is the sales incentive compensation plan for local sales personnel and for the Country Manager; as this inquiry gives insight into the possibility of personal benefit which might result from someone paying a bribe in order to win a contract which results in a large sales incentive compensation to the employee.   All of these reviews, questions, inquiries and analyses are designed to locate the pressure points involved in any company’s sales processes. This is because pressure is a key element of occupational fraud and the risk of fraud, including corruption, increases as the pressure increases. Since corruption is viewed as a subset of fraud, it might be a good time to review the Fraud Triangle, which lays out breeding ground for fraud in the corruption context:  Pressure which has financial implications, whether it be personal financial needs that are unmet or pressure to reach sales goals; Rationalization – a fraud perpetrator always rationalizes that he / she is not a criminal and when committing fraud for personal benefit, the perpetrator intends to repay the money; when committing fraud for company benefit, the perpetrator rationalizes that the company really wants to meet its goals and that the perpetrator’s actions are in furtherance of the company’s goals; and Opportunity – the perpetrator must be in a situation where the internal controls do not prevent the fraud and its necessary concealment.  Three Key Takeaways You must understand the financial and operational structure of your company and how the financial and operation structure outside the US is integrated with the corporate headquarters. Are your financial statements and reporting systems integrated? Always consider the fraud triangle? For more information on how to improve your internal controls management process, visit this month’s sponsor Workiva at workiva.com. Learn more about your ad choices. Visit megaphone.fm/adchoices