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Fraud in Accounts Payable
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Table of Contents

Preface xvii

Acknowledgments xxiii

Part One: Where Accounts Payable Fraud Can Happen in Your Organization 1

1 Profiles of Fraud in the Business World 3

Three Big Myths 4

Fraud Statistics 4

Occupational Fraud: It’s a Big Problem 5

Definitions and Frequency 5

Who Gets Hit the Hardest? 6

How Fraud Is Detected 7

Who Commits Occupational Fraud? 7

To Prosecute or Not 8

Is Fraud an Equal Opportunity Crime? 9

Fraud in the Eyes of the Beholder 9

Effect of Status of Fraudster 10

Big Boss Issue 11

Why Do Insiders Steal? 11

Conditions that Permit Frauds to Occur 12

Why Aren’t More Fraudsters Prosecuted? 13

Fraud in the Real World 13

Concluding Thoughts 14

2 Check Fraud: Still a Huge Problem 17

Internal Controls to Prevent Check Fraud by Insiders 17

Recommended Controls 19

What Else Can You Do? 20

How Bad Is the Check Fraud Problem? 20

What Does the Law Say? 21

Impact on Accounts Payable 22

What Should You Do? 22

Positive Pay and Its Cousins 23

Internal Controls, Segregation of Duties, and Positive Pay Exceptions 25

Internal Controls and Paper Checks 26

What Can Go Wrong 26

Consequences of Poor Internal Check Production Processes 27

The Right Way 27

The Best Way 29

Questions that Reveal Your Internal Check Controls 29

Best Check-Handling Practices between Printing and Mailing 30

Mailing Checks 30

From Printing to Mailing: Do You Know Where Your Checks Are? 31

When the Checks Are Signed and Returned 33

Wire Transfers 34

Rebate and Refund Checks 34

Rush Checks 34

Why Returning Checks to Requisitioners Can Be a Problem 35

How Companies Handle Check Return Requests by Requisitioners 36

Fraud in the Real World 38

Concluding Thoughts 41

3 Check Stock: Stop the Fraudsters’ Presses 43

Security Features in Your Check Stock 43

What Else? 45

Some Check Fraud Security Features 45

A Word about Void Pantographs 49

Void Pantographs and Positive Pay 49

Fraud in the Real World 50

Concluding Thoughts 50

4 P-Card: Not as Big an Issue as You Might Think 51

Printing of the Invoice 51

Start Off on the Right Foot 52

Policy and Procedures Manual 52

Spell Out Consequences 53

Require Documentation 54

Don’t Overlook Receipts 54

Role of a Program Administrator in Fraud Prevention 55

Approvals and Compliance 55

Role of Limits with Respect to Fraud 56

Train, Train, and Then Train Again 56

What About Inappropriate Use? 57

Fraud in the Real World 58

Closing Thoughts 59

5 Electronic Payment Fraud: Not a Growth Industry—Yet! 61

ACH Blocks 61

ACH Filters 62

ACH Positive Pay 63

Payment Account Data: Is It Accurate? 63

Ach Data Accuracy: Real-Life Solutions to a Very Practical Problem 65

CPA’s Perspective 68

Fraud in the Real World 70

Closing Thoughts 70

6 Desktop Fraud: Few Think About This—But Everyone Should 71

Example 71

Overview 72

Issues 73

Recommendation 74

Lovallo’s Guidelines 74

Bringing It All Together 76

Fraud in the Real World 77

Concluding Thoughts 78

7 Travel and Entertainment Fraud: Not All Your Employees Are Honest 79

The Book that Teaches Your Employees How to Steal 80

Danger Signs 80

Other T&E Scams 81

Drawing a Line 82

Latest T&E Issue: Verifying Boarding Passes Printed at Home 82

Solutions to the Boarding Pass Issue 83

T&E Fraud Prevention Best Practices 84

Detecting Expense Reimbursement Fraud 85

Uniform Enforcement of the T&E Policy 86

What to Do When Expense Reimbursement Fraud Is Detected 86

Last-Ditch Collection Efforts 87

Fraud in the Real World 88

Closing Thoughts 90

8 Petty Cash Fraud: Petty Indeed 93

Petty Cash Awful Practices 93

How Much Money Should the Box Have? 94

Petty Cash Box 95

Surprise Audits 96

Where Does Responsibility for the Box Lie? 96

Do We Still Need Petty Cash? 97

Receipt Review 97

Petty Cash versus T&E 98

Fraud in the Real World 98

Concluding Thoughts 99

9 Vendor and Invoice Fraud: Not Every Invoice (Or Vendor!) Is Legit 101

Fraudulent Invoices—or Not 102

Solicitations that Look Like Invoices 102

Other Common Invoice Frauds 103

Fraud and Poor Payment Practices 104

A Word about Collusion 106

Brief Commentary on Purchasing 106

Up-Front Vendor Verification 107

Control Challenge in Real Life 107

Advice from the Better Business Bureau 111

Fraud in the Real World 112

Concluding Thoughts 113

10 Master Vendor File Fraud: How Employees Play Games with Your Records 115

Some Really Bad Master Vendor File Practices 116

Master Vendor File Reports 116

Coding Standards Prevent Fraud 117

Cleansing the Master Vendor File 118

Who Has Responsibility for the Master Vendor File 119

A New System 120

Master Vendor File and Your Employees 121

Fraud in the Real World 121

Closing Thoughts 122

11 Payroll Fraud: Ghostbusting and More 123

Phantom Employees 123

What You Can Do to Detect and Prevent Ghost Employees 124

Falsified Hours and/or Salary 125

What You Can Do to Detect and Prevent Employees from Falsifying Data 126

Commission Schemes 127

False Workers’ Compensation Claims 128

Some Overall Prevention Tactics 129

Fraud in the Real World 130

Concluding Thoughts 131

12 Telecom Fraud: Yes, It Can Happen to You 133

Types of Phone Fraud 133

Nuisance Fraud 134

Examples of Cramming 134

Getting Refunds and Combating Cramming 135

Slamming 136

Phone System and Voice Mail Fraud 137

Social Engineering Fraud 138

Call Forwarding/Conferencing Problems 139

VOIP Fraud 140

Fraud in the Real World 141

Concluding Thoughts 142

Part Two: Strategies to Deter, Prevent, And Detect All Sorts of Accounts Payable Fraud 143

13 Best Practices—Not: Tactics that Unintentionally Promote Fraud 145

Closing Thoughts 147

14 Fraud Monitoring Reports: A Necessary Evil 149

Automated Monitoring 149

How Anyone Can Run Reports 150

A Word about More Sophisticated Monitoring 150

How Much Checking Is Enough? 151

The Big Report Everyone Should Run 152

The Easy Report 152

Other Fraud Detection Reports 153

The ACT List 159

Closing Thoughts 160

15 Fraud Detection and Prevention: Simple Tactics You Can Use 161

2006 Report to the Nation Fraud Detection 161

PricewaterhouseCoopers 2007 Global Economic Crime Survey Fraud Detection 162

Anonymous Hotlines 162

What Companies Can Do to Prevent Fraud 163

Simple Tactics to Make Sure No One Robs the Till on Your Watch 163

Fraud in the Real World 166

Closing Thoughts 167

16 Sarbanes-Oxley 169

Sarbanes-Oxley 169

Overview of the Act 170

Sarbanes-Oxley Survey 170

Impact of the Act on Accounts Payable Operations 171

Outside Influences 172

Functions Improved 172

T&E Reimbursement and Review Processes 173

Internal Audit Reviews 173

Backup for Check Requests 174

Records Retention Policy 174

1099 Reporting 174

Invoices 175

Master Vendor File 176

Other Regulatory Concerns 176

Using the Act to Enforce Needed Change 176

The Act and Its Effects on Private Companies 177

Whistle-Blower Protections 178

The Anonymous Hotline 178

Concluding Thoughts 179

Appendix A: Fraud Schemes: Physical and Virtual Checks 181

Appendix B: 2007 Top Frauds 183

Appendix C: Segregation of Duties 185

Appendix D: The Sarbanes-Oxley Act of 2002 Titles 187

Resources 191

Index 195

About the Author

Mary S. Schaeffer is a nationally recognized accounts payable expert. She is the founder and Editorial Director of Accounts Payable Now & Tomorrow, a newsletter for professionals interested in payment issues. She is the author of twelve books and has written hundreds of articles that have appeared in publications such as the New York Times, Corporate Cashflow, Treasury & Risk, Business Credit, the Writer, Newsday, and newsweek.com. She has an MBA in finance and is a member of the New York Financial Writers' Association. She is a regular contributor to AICPA's Corporate Finance Insider publication.

Reviews

"The author has significant experience in this area and offers compelling best practices to detect and prevent fraud from occurring within your organization. This book goes a long way to get your organization thinking and acting to detect and prevent fraud." (Auditnet.org, October 2008)

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