Showing posts with label anti-corruption series. Show all posts
Showing posts with label anti-corruption series. Show all posts

Monday, August 28, 2017

Skimming (Theft of Cash) in Nonprofits

















Significant Fraud Schemes in Nonprofits
  1. Skimming
When an entity receives cash, it must record (recognize) it in its accounting system. Skimming occurs when an employee steals cash or checks BEFORE recording it in the entity’s accounting system. Skimming schemes are usually called “off-books” schemes. Because cash theft happens before cash is recorded in the accounting records, it is tough to detect such a scheme: there is no audit trail.  

For example, when a cashier of a supermarket receives cash from a customer, does not issue a cash sales invoice, and pocket the money into his wallet, we call this skimming. When a nonprofit volunteer collects a donation from a donor where she did not issue him a cash receipt and pocketed the donated money for personal use, we call this skimming. 

“A recent case illustrates the ease with which funds can be skimmed when both of these characteristics are present. The president of an organization personally solicited and collected contributions from donors. He skimmed more than $4 million of contribution income over a 15-year period before being detected. He was only detected once his successor solicited one of the donors who had contributed, under the impression that the individual had never made a contribution to the organization. When the donor indicated he had been a significant supporter of the organization for several years, the fraud was then uncovered.”

Who may commit skimming schemes? Any employee who receives cash or checks from donors may skim funds. Therefore, cashiers, employees receiving payments/donations through the mail, or volunteers who collect funds from remote locations are a great skimming risk.

Therefore, nonprofit management should focus on preventing and deterring skimming schemes as detection is difficult. A proper design and implementation of specific internal control processes for cash receipts would significantly help lower skimming schemes risks. For example, a deficiency in any of the following controls would constitute a “red flag” that management should handle in a special care and professional skepticism. 
  • The employee who opens the mail should be independent of the cashier and accounts receivable staff.
  • Unopened business mail should be kept away from employees having access to accounting records. 
  • The employee who receives mail should
    • Stamp (“For Deposit Only”) on all checks received?
    • Prepare a list of the money, checks, and other receipts? 
    • Forward all remittances to the person responsible for preparing and making the daily bank deposit?
    • Forward the total of all remittances to the person responsible for comparing it to the authenticated deposit ticket and amount recorded?
       
  • Cash receipts should be prenumbered and independently be checked daily and reconciled with cash collections.
  • Nonprofit should bond employees or volunteers handing cash. 
The following schemes and topics are discussed thoroughly in Part 2: Corruption Prevention, Deterrence, and Detection - Nonprofit Organizations.
  1. Check Tampering
  2. Expense Reimbursements
  3. Payroll Schemes
Fraud and Corruption Risk Assessment 

The Minimum a Nonprofit Can Do to Prevent and Deter Fraud and Corruption

Download the associated PDF document.

Check more free resources at the Anti-Corruption Library


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Saturday, April 8, 2017

Developing effective Corruption Prevention Policy: CHECKLIST


Tempe, March 29, 2017

Technical Staff

This document is a part of The AACI series of anti-corruption resources. The contents of this document constitute an integral part of the CACM Review textbook that would be available in countries where the CACM will only be offered by exam. 

Definition: A fraud and corruption prevention policy is a formal, written statement recording the entity's attitude and response to fraud and corruption. 

The policy could be standalone or included within the code of ethics. It should state clearly what the organization expects from its employees regarding fraud and corruption. 

A successful policy is one that:
  1. Embeds in it the “Perception of Detection” AND
  2. Implements a swift and consistent action when fraud or corruption is suspected or detected
Corruption Prevention Policy Benefits

The following is a "partial" list:
  1. Absence of confusion to what is fraud, corruption or misappropriation of assets
  2. Clear consequences for engaging in fraud and corruption
  3. Commitment of board of directors and management - the entity is not an easy target to fraud and corruption

    Corruption Prevention Policy Benefits

    Elements of Corruption Prevention Policy 

    Pre-requites for Effective Corruption Prevention Strategies, Plans, and Programs

    You may download the entire document when visiting The AACI Anti-Corruption Library: Free Resource

    Saturday, April 1, 2017

    Part 1(D): Fraud and Corruption Detection - Government Entities

    What is the resilience of an entity in preventing, deterring, and detecting fraud and corruption?

    Tempe, March 29, 2017
    Technical Staff

    Proper Anti-Corruption Competencies of Senior Civil Servants, Elected Public Officials, and Employees

    The prevalence of adequate anti-corruption education in government entities always determines to a large degree the effectiveness of internal control and corruption prevention policy in detecting fraud and corruption.

    Each governmental and / or management level requires a different set of anti-corruption competencies. For example, the internal department head anti-corruption skills differ from those of the deputy minister of a government entity. Each employee should possess the necessary anti-corruption knowledge and skills to meet what management expects her to do in detecting fraud and corruption.

    Surprisingly, central banks all over the world require their local banks to ensure that their employees obtain annual anti-money laundering training. Though money laundering is a very tiny and small part of corruption, central banks do not require their local banks to (a) have a corruption prevention policy, and (b) ensure that their employees obtain anti-corruption training annually. There are too many banks that do not have a corruption prevention policy, especially in developing countries.

    This is extremely odd as financial institutions are regarded more regulated and disciplined than other business sectors. This is a red flag that regulatory agencies should note due to its severe consequences on not only detecting fraud and corruption but also on financing terrorism.

    The AACI believes that the adequacy of anti-corruption competencies of senior public officials and those charged with governance should be quantitatively measured annually. Last year, we launched a certification program called Organizations Anti-Corruption Certification Program to support organizations of all types to quantify their anti-corruption competencies, among other things.

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    Part 1(C): Fraud and Corruption Deterrence - Government Entities



    What is the resilience of an entity in preventing, deterring, and detecting fraud and corruption?

    Tempe, March 29, 2017
    Technical Staff
    Increase the Likelihood of Detecting Corrupt Acts

    A government entity would enhance its deterrence of corruption when it increases the likelihood of detecting corrupt or fraudulent acts. The perpetrator would usually weigh the benefits and costs of his fraudulent act. Under normal psychological and emotional conditions, he will rationally decide whether to commit fraud or corruption. The more the perpetrator believes that his fraudulent act would be uncovered, the less likely he will commit fraud or corruption. For example, when a cashier knows that the internal audit department personnel are competent and usually carry out surprise physical cash count of money in his custody, he will not take a high risk of being caught “borrowing” cash from his custody. 

    Systems of internal control that are well designed and implemented effectively would support the organization’s deterrence of corruption. Although internal control systems have their inherent limitations, a whistle-blowing policy would create a significant deterrence impact on the perpetrator’s perception of the likelihood of being detected. Prevailing honesty and integrity within the government entity’s culture also support its deterrence of corruption.

    However, the efficacy of deterrence of corruption depends on the following two fundamental deterrence principles:

    (a)   Severity of punishment, and
    (b)   Certainty of punishment

    Severity of punishment

    Punishment is severe when it deters a perpetrator from committing a fraudulent or corrupt act. However, one cannot conclude that whenever there is corruption, its associated punishment is not severe. A severity of punishment would be measured by the degree to which a perpetrator understands the risks (costs) of corruption and the extent to which it deters him from committing fraud.

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    Wednesday, March 1, 2017

    Part 1(B): Fraud and Corruption Prevention - Government Entities

    What is the resilience of an entity in preventing, deterring, and detecting fraud and corruption?

    Tempe, February 27, 2017
    Technical Staff

    As we stated in Part 1(A): Fraud and Corruption Prevention - Government Entities, there is not a cut-and-dry measurement for fraud and corruption risks. These risks should be addressed at the following levels: internally and externally.

    The following questions and their respective answers would constitute a foundation for identifying and assessing the fraud and corruption risks attributed to the external environment of a government entity. The process should include the following factors:
    • Constituents and customers
    • Suppliers and creditors
    • Public expectations of services
    • State audit
    • Local laws, rules, and regulations
    • Society social norms, values, and culture
    • Prevailing corruption or perceived corruption in the community / country
    Constituents and Customers
    1. Does the government entity have a documented current system to receive, process, and respond timely and appropriately to constituents and customers' suspected corruption complaints?
    2. Does the government entity interact with its constituents and customers via social media platforms? If yes, does the government entity monitor its constituents and customers' perception of its integrity and ethical practices?
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    Part 1(A): Fraud and Corruption Prevention - Government Entities

    What is the resilience of an entity in preventing, deterring, and detecting fraud and corruption?

    Tempe, February 27, 2017
    Technical Staff

    Where to Start?

    A smart start at an entity to prevent fraud and corruption would be seeking an answer to the following question:

    What is the current status of fraud and corruption in the government entity?

    The answer to this question could be qualitative or quantitative. Qualitative responses, for example, could be very low, low, medium, medium-high, high, and catastrophic! Quantitative answers could be a point on a numeric or percentage scale.

    This is what we call fraud and corruption risk identification, or sometimes we call it fraud and corruption risk mapping. Fraud and corruption risk is a business risk. Because it is a business risk, it should be embedded in the organization’s strategy. Needless to say that neither this risk nor the strategy is static: they are dynamic.

    Fraud and Corruption Risks in a Government Entity

    There is not a cut-and-dry measurement for fraud and corruption risks. These risks should be addressed at the following levels: internally and externally.

    The following questions and their respective answers would constitute a foundation for identifying and assessing the fraud and corruption risks attributed to the internal environment of the government entity.

    Are the elected public officials financially literate?

    Is there an orientation program for senior officials and newly elected public officials

    Is there an effective internal audit function?

    Should circumstances warrant, does the government entity have effective and competent functions similar to those applied in its industry?

    Does the government entity have effective compliance function?

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    Sunday, January 29, 2017

    Fraud and Corruption Detection: Part 1 (D)


    January 29, 2017

    What is the resilience of an entity in preventing, deterring, and detecting fraud and corruption? 

    Part 1(D) Fraud and Corruption Detection in a For-Profit Organization

    Detection of fraud and corruption is directly related to fraud and corruption prevention and deterrence. While prevention of corruption is fundamentally based on anticipating what could or may go wrong, detection of fraud and corruption is principally designing and implementing policies, processes, and procedures to find out when fraud and corruption occur. Therefore, one will never systematically detect a fraud or corruption incident unless it was initially expected to happen. An effective internal control system is a partial answer for detecting fraud and corruption.

    Presuming a proper tone is set at the top, the foundation of detecting fraud and corruption consists of the following pillars:

    1.    Effective internal control system
    2.    Effective corruption prevention policy
    3.    Proper anti-corruption competencies of board members, executive management, and employees
    4.    Effective support functions

    As we will discuss each of these pillars separately in the anti-corruption series, the following section briefly discusses their fundamental importance and impact on fraud and corruption detection.

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    We will start rolling over the CACM via exam in selected countries and regions. CACM candidates of these countries will find the CACM Review material helpful. 

    Friday, December 30, 2016

    Fraud and Corruption Deterrence: Part 1(C)

    December 30, 2016

    What is the resilience of an entity in preventing, deterring, and detecting fraud and corruption? 

    Part 1(C) Fraud and Corruption Deterrence in a For-Profit Organization

    Corruption is an illegal and immoral act of serious existential consequences on organizations. Whatever the cost of fraud and corruption deterrence mechanisms organizations use, it would be less costly than what they would suffer from the ramifications of uncovered and publicized case(s) of fraud and corruption. Fraud and corruption deterrence aims to:

    1.    Set the proper tone at the top
    2.    Increase the likelihood of detecting corrupt acts
    3.    Heighten perpetrator's costs

    Read more when you log in. CACM members can access this series when they log in to the membership portal or click here.

    We will start rolling over the CACM via exam in selected countries and regions. CACM candidates of these countries will find the CACM Review material helpful.