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Leonard W. Vona

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Uncover hidden fraud and red flags using efficient data analytics Fraud Data Analytics Methodology addresses the need for clear, reliable fraud detection with a solid framework for a robust data analytic plan. By combining fraud risk assessment and fraud data analytics, you'll be able to better identify and respond to the risk of fraud in your audits. Proven techniques help you identify signs of fraud hidden deep within company databases, and strategic guidance demonstrates how to build data interrogation search routines into your fraud risk assessment to locate red flags and fraudulent transactions. These methodologies require no advanced software skills, and are easily implemented and integrated into any existing audit program. Professional standards now require all audits to include data analytics, and this informative guide shows you how to leverage this critical tool for recognizing fraud in today's core business systems. Fraud cannot be detected through audit unless the sample contains a fraudulent transaction. This book explores methodologies that allow you to locate transactions that should undergo audit testing. * Locate hidden signs of fraud * Build a holistic fraud data analytic plan * Identify red flags that lead to fraudulent transactions * Build efficient data interrogation into your audit plan Incorporating data analytics into your audit program is not about reinventing the wheel. A good auditor must make use of every tool available, and recent advances in analytics have made it accessible to everyone, at any level of IT proficiency. When the old methods are no longer sufficient, new tools are often the boost that brings exceptional results. Fraud Data Analytics Methodology gets you up to speed, with a brand new tool box for fraud detection.

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Table of Contents

Cover

Title Page

Copyright

Dedication

Preface

Acknowledgments

Chapter 1: Introduction to Fraud Data Analytics

What Is Fraud Data Analytics?

Fraud Data Analytics Methodology

The Fraud Scenario Approach

Skills Necessary for Fraud Data Analytics

Summary

Chapter 2: Fraud Scenario Identification

Fraud Risk Structure

How to Define the Fraud Scope: Primary and Secondary Categories of Fraud

Understanding the Inherent Scheme Structure

The Fraud Circle

The Five Categories of Fraud Scenarios

What a Fraud Scenario Is Not

How to Write a Fraud Scenario

Understanding Entity Permutations Associated with the Entity Structure

Practical Examples of a Properly Written Fraud Scenario

Style versus Content of a Fraud Scenario

How the Fraud Scenario Links to the Fraud Data Analytics

Summary

Appendix 1

Appendix 2

Chapter 3: Data Analytics Strategies for Fraud Detection

Understanding How Fraud Concealment Affects Your Data Analytics Plan

Low Sophistication

Medium Sophistication

High Sophistication

Shrinking the Population through the Sophistication Factor

Building the Fraud Scenario Data Profile

Fraud Data Analytic Strategies

Internal Control Avoidance

Data Interpretation Strategy

Number Anomaly Strategy

Pattern Recognition and Frequency Analysis

Strategies for Transaction Data File

Summary

Chapter 4: How to Build a Fraud Data Analytics Plan

Plan Question One: What Is the Scope of the Fraud Data Analysis Plan?

Plan Question Two: How Will the Fraud Risk Assessment Impact the Fraud Data Analytics Plan?

Plan Question Three: Which Data‐Mining Strategy Is Appropriate for the Scope of the Fraud Audit?

Plan Question Four: What Decisions Will the Plan Need to Make Regarding the Availability, Reliability, and Usability of the Data?

Plan Question Five: Do You Understand the Data?

Plan Question Six: What Are the Steps to Designing a Fraud Data Analytics Search Routine?

Plan Question Seven: What Filtering Techniques Are Necessary to Refine the Sample Selection Process?

Plan Question Eight: What Is the Basis of the Sample Selection Process?

Plan Question Nine: What Is the Plan for Resolving False Positives?

Plan Question Ten: What Is the Design of the Fraud Audit Test for the Selected Sample?

Summary

Appendix: Standard Naming Table List for Shell Company Audit Program

Chapter 5: Data Analytics in the Fraud Audit

How Fraud Auditing Integrates with the Fraud Scenario Approach

How to Use Fraud Data Analytics in the Fraud Audit

Fraud Data Analytics for Financial Reporting, Asset Misappropriation, and Corruption

Impact of Fraud Materiality on the Sampling Strategy

How Fraud Concealment Affects the Sampling Strategy

Predictability of Perpetrators' Impact on the Sampling Strategy

Impact of Data Availability and Data Reliability on the Sampling Strategy

Change, Delete, Void, Override, and Manual Transactions Are a Must on the Sampling Strategy

Planning Reports for Fraud Data Analytics

How to Document the Planning Considerations

Key Workpapers in Fraud Data Analytics

Summary

Chapter 6: Fraud Data Analytics for Shell Companies

What Is a Shell Company?

What Is a Conflict‐of‐Interest Company?

What Is a Real Company?

Fraud Data Analytics Plan for Shell Companies

Fraud Data Analytics for the Traditional Shell Company

Fraud Data Analytics for the Assumed Entity Shell Company

Fraud Data Analytics for the Hidden Entity Shell Company

Fraud Data Analytics for the Limited‐Use Shell Company

Linkage of Identified Entities to Transactional Data File

Fraud Data Analytics Scoring Sheet

Impact of Fraud Concealment Sophistication Shell Companies

Building the Fraud Data Profile for a Shell Company

Fraud Audit Procedures to Identify the Shell Corporation

Summary

Chapter 7: Fraud Data Analytics for Fraudulent Disbursements

Inherent Fraud Schemes in Fraudulent Disbursements

Identifying the Key Data: Purchase Order, Invoice, Payment, and Receipt

Documents and Fraud Data Analytics

FDA Planning Reports for Disbursement Fraud

FDA for Shell Company False Billing Schemes

Understanding How Pass‐Through Schemes Operate

Identify Purchase Orders with Changes

False Administration through the Invoice File

Summary

Chapter 8: Fraud Data Analytics for Payroll Fraud

Inherent Fraud Schemes for Payroll

Planning Reports for Payroll Fraud

FDA for Ghost Employee Schemes

FDA for Overtime Fraud

FDA for Payroll Adjustments Schemes

FDA for Manual Payroll Disbursements

FDA for Performance Compensation

FDA for Theft of Payroll Payments

Summary

Chapter 9: Fraud Data Analytics for Company Credit Cards

Abuse versus Asset Misappropriation versus Corruption

Inherent Fraud Scheme Structure

Real Vendor Scenarios Where the Vendor Is Not Complicit

Real Vendor Scenarios Where the Vendor Is Complicit

False Vendor Scenario

Impact of Scheme versus Concealment

Fraud Data Analytic Strategies

Linking Human Resources to Credit Card Information

Planning for the Fraud Data Analytics Plan

Fraud Data Analytics Plan Approaches

File Layout Description for Credit Card Purchases

FDA for Procurement Card Scenarios

Summary

Chapter 10: Fraud Data Analytics for Theft of Revenue and Cash Receipts

Inherent Scheme for Theft of Revenue

Identifying the Key Data and Documents

Theft of Revenue Before Recording the Sales Transaction

Theft of Revenue after Recording the Sales Transaction

Pass‐through Customer Fraud Scenario

False Adjustment and Return Scenarios

Theft of Customer Credit Scenarios

Lapping Scenarios

Illustration of Lapping in the Banking Industry with Term Loans

Currency Conversion Scenarios or Theft of Sales Paid in Currency

Theft of Scrap Income or Equipment Sales

Theft of Inventory for Resale

Bribery Scenarios for Preferential Pricing, Discounts, or Terms

Summary

Chapter 11: Fraud Data Analytics for Corruption Occurring in the Procurement Process

What Is Corruption?

Inherent Fraud Schemes for the Procurement Function

Identifying the Key Documents and Associated Data

Overall Fraud Approach for Corruption in the Procurement Function

Fraud Audit Approach for Corruption

What Data Are Needed for Fraud Data Analytics Plan?

Fraud Data Analytics: The Overall Approach for Corruption in the Procurement Function

Linking the Fraud Action Statement to the Fraud Data Analytics

Bid Avoidance: Fraud Data Analytics Plan

Favoritism in the Award of Purchase Orders: Fraud Data Analytics Plan

Summary

Chapter 12: Corruption Committed by the Company

Fraud Scenario Concept Applied to Bribery Provisions

Creating the Framework for the Scope of the Fraud Data Analytics Plan

Planning Reports

Planning the Understanding of the Authoritative Sources

FDA for Compliance with Company Policies

FDA Based on Prior Enforcement Actions Using Transactional Issues

FDA Based on the Internal Control Attributes of DOJ Opinion Release 04‐02 or the UK Bribery Act: Guidance on Internal Controls

Building the Fraud Data Analytics Routines to Search for Questionable Payments

FDA for Questionable Payments That Are Recorded on the Books

FDA for Funds That Are Removed from the Books to Allow for Questionable Payments

Overall Strategy for the Record‐Keeping Provisions

FDA for Questionable Payments That Fail the Record‐Keeping Provision as to Proper Recording in the General Ledger

FDA for Questionable Payments That Have a False Description of the Business Purpose

Summary

Chapter 13: Fraud Data Analytics for Financial Statements

What Is an Error?

What Is Earnings Management?

What Is Financial Statement Fraud?

How Does an Error Differ from Fraud?

Inherent Fraud Schemes and Financial Statement Fraud Scenarios

Additional Guidance in Creating the Fraud Action Statement

How Does the Inherent Fraud Scheme Structure Apply to the Financial Statement Assertions?

Do I Understand the Data?

What Is a Fraud Data Analytics Plan for Financial Statements?

What Are the Accounting Policies for Assets, Liabilities, Equity, Revenue, and Expense Accounts?

Summary

Chapter 14: Fraud Data Analytics for Revenue and Accounts Receivable Misstatement

What Is Revenue Recognition Fraud?

Inherent Fraud Risk Schemes in Revenue Recognition

Inherent Fraud Schemes and Creating the Revenue Fraud Scenarios

Identifying Key Data on Key Documents

Fraud Brainstorming for Revenue

FDA for False Revenue Scenarios

False Revenue for False Customers through Accounts Receivable Analysis

Fraud Concealment Strategies for False Revenue Fraud Scenarios

Fraud Data Analytics for Percentage of Completion Revenue Recognition

Summary

Chapter 15: Fraud Data Analytics for Journal Entries

Fraud Scenario Concept Applied to Journal Entry Testing

The

Why

Question

The

When

Question

Understanding the Language of Journal Entries

Overall Approach to Journal Entry Selection

Fraud Data Analytics for Selecting Journal Entries

Summary

Appendix A: Data Mining Audit Program for Shell Companies

About the Author

Index

End User License Agreement

List of Illustrations

Chapter 1

Figure 1.1 Improving Your Odds of Selecting One Fraudulent Transaction

Figure 1.2 Circular View of Data Profile

Chapter 2

Figure 2.1 The Fraud Risk Structure

Figure 2.2 The Fraud Circle

Figure 2.3 The Fraud Scenario

Chapter 3

Figure 3.1 Fraud Concealment Tendencies

Figure 3.2 Fraud Concealment Strategies

Figure 3.3 Illustration Bank Account Number

Figure 3.4 Improving Your Odds of Selecting One Fraudulent Transaction

Figure 3.5 Maximum, Minimum, and Average Report Produced from IDEA Software

Chapter 4

Figure 4.1 Audit Procedure Design to Detect Fraud

Chapter 5

Figure 5.1 The Fraud Scenario

Chapter 6

Figure 6.1 Categories of Shell Companies

Figure 6.2 Address Field

Chapter 7

Figure 7.1 Pass‐Through Entity: Internal Person

Figure 7.2 Pass‐Through Entity: External Salesperson

Guide

Cover

Table of Contents

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Fraud Data Analytics Methodology

The Fraud Scenario Approach to Uncovering Fraud in Core Business Systems

 

LEONARD W. VONA

 

 

 

 

 

Copyright © 2017 by John Wiley & Sons, Inc. All rights reserved.

Published by John Wiley & Sons, Inc., Hoboken, New Jersey.

Published simultaneously in Canada.

No part of this publication may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, electronic, mechanical, photocopying, recording, scanning, or otherwise, except as permitted under Section 107 or 108 of the 1976 United States Copyright Act, without either the prior written permission of the Publisher, or authorization through payment of the appropriate per-copy fee to the Copyright Clearance Center, Inc., 222 Rosewood Drive, Danvers, MA 01923, (978) 750-8400, fax (978) 646-8600, or on the Web at www.copyright.com. Requests to the Publisher for permission should be addressed to the Permissions Department, John Wiley & Sons, Inc., 111 River Street, Hoboken, NJ 07030, (201) 748-6011, fax (201) 748-6008, or online at http://www.wiley.com/go/permissions.

Limit of Liability/Disclaimer of Warranty: While the publisher and author have used their best efforts in preparing this book, they make no representations or warranties with respect to the accuracy or completeness of the contents of this book and specifically disclaim any implied warranties of merchantability or fitness for a particular purpose. No warranty may be created or extended by sales representatives or written sales materials. The advice and strategies contained herein may not be suitable for your situation. You should consult with a professional where appropriate. Neither the publisher nor author shall be liable for any loss of profit or any other commercial damages, including but not limited to special, incidental, consequential, or other damages.

For general information on our other products and services or for technical support, please contact our Customer Care Department within the United States at (800) 762-2974, outside the United States at (317) 572-3993 or fax (317) 572-4002.

Wiley publishes in a variety of print and electronic formats and by print-on-demand. Some material included with standard print versions of this book may not be included in e-books or in print-on-demand. If this book refers to media such as a CD or DVD that is not included in the version you purchased, you may download this material at http://booksupport.wiley.com. For more information about Wiley products, visit www.wiley.com.

Library of Congress Cataloging-in-Publication Data:

Names: Vona, Leonard W., 1955- author.

Title: Fraud data analytics methodology : the fraud scenario approach to uncovering fraud in core business systems / Leonard W. Vona.

Description: Hoboken, New Jersey : John Wiley & Sons, [2017] | Includes index.

Identifiers: LCCN 2016036161 | ISBN 9781119186793 (cloth) | ISBN 9781119270348 (ePDF) | ISBN 9781119270355 (epub)

Subjects: LCSH: Auditing. | Forensic accounting. | Fraud—Prevention. | Auditing, Internal.

Classification: LCC HF5667 .V659 2017 | DDC 658.4/73—dc23

LC record available at https://lccn.loc.gov/2016036161

Cover design: Wiley

Cover image: © kentoh/Shutterstock

This book is dedicated to my family, Patricia, Amy, David, and Jeffrey, for supporting me in my quest to explain fraud auditing. In the memory of my dad, who told me to go to college, and the memory of the women who shaped my life.

Preface

Even the world's best auditor using the world's best audit program cannot detect fraud unless their sample includes a fraudulent transaction. That is why fraud data analytics is so essential to the auditing profession.

Fraud auditing is a methodology tool used to respond to the risk of fraud in core business systems. The methodology must start with the fraud risk identification. Fraud data analytics is about searching for a fraud scenario versus a data anomaly. I have often referred to fraud data analytics as code breaking. The fraud auditor is studying millions of transactions in the attempt to find the needle in the haystack, called the fraud scenario. It is my hope that my years of professional experience in using fraud data analytics will move the auditing profession to become the number‐one reason for fraud detection.

This book is about the science of fraud data analytics. It is a systematic study of fraud scenarios and their relationship to data. Like all scientific principles, the continual study of the science and the practical application of the science are both necessary for success in the discovery of fraud scenarios that are hiding in all core business systems.

The methodology described in the book is intended to provide a step‐by‐step process for building the fraud data analytics plan for your company. The first five chapters explain each phase of the process. Later chapters illustrate how to implement the methodology in asset misappropriation schemes, corruption schemes, and financial reporting schemes.

The practitioner will learn that fraud data analytics is both a science and an art. In baseball, there is a science to hitting a baseball. The mechanics of swinging a bat is taught to players of all ages. However, you can read all the books in the world about swinging a bat, but unless you actually stand in the batting box and swing the bat, you will never truly learn the art of hitting a baseball. Likewise, the fraud auditor needs to learn to analyze data and to employ the tools to do so in order to be able to find fraud scenarios hiding in your data systems.

Acknowledgments

To my friends at Audimation Services: Carolyn Newman, Jill Davies, and Carol Ursell. It is because of working with you that I developed the art of fraud data analytics.

To Sheck Cho (Executive Editor), who encouraged me to write my books, and to the editors at Wiley, without you I could not have written this book.

To Nicki Hindes, who keeps my office going while I travel the world.

To all those people who have inspired me. Thank you!

Chapter 1Introduction to Fraud Data Analytics

The world's best auditor using the world's best audit program cannot detect fraud unless their sample includes a fraudulent transaction. This is why fraud data analytics (FDA) is so critical to the auditing profession.

How we use fraud data analytics largely depends on the purpose of the audit project. If the fraud data analytics is used in a whistle blower allegation, then the fraud data analytics plan is designed to refute or corroborate the allegation. If the fraud data analytics plan is used in a control audit, then the fraud data analytics would search for internal control compliance or internal control avoidance. If the fraud data analytics is used for fraud testing, then the fraud data analytics is used to search for a specific fraud scenario that is hidden in your database. This book is written for fraud auditors who want to integrate fraud testing into their audit program. The concepts are the same for fraud investigation and internal control avoidance—what changes is the scope and context of the audit project.

Interestingly, two of the most common questions heard in the profession are, “Which fraud data analytic routines should I use in my audit?” and, “What are the three fraud data analytics tests I should use in payroll or disbursements?” In one sense, there really is no way to answer these questions because they assume the fraud auditor knows what fraud scenario someone might be committing. In reality, we search for patterns commonly associated with a fraud scenario or we search for all the logical fraud scenario permutations associated with the applicable business system. In truth, real fraud data analytics is exhausting work.

I have always referred to fraud data analytics as code breaking. It is the auditor's job to search the database using a comprehensive approach consistent with the audit scope. So, the common question of which fraud data analytics routines should I use can only be answered when you have defined your audit objective and audit scope. A key element of the book is the concept that while the fraud auditor might not know what fraud scenario a perpetrator is committing, the fraud auditor can identify and search for all the fraud scenario permutations. Therefore, the perpetrator will not escape the long arm of the fraud data analytics plan.

Once again, the question arises as to which fraud data analytic routines I should use in my next audit. Using the fraud risk assessment approach, the fraud data analytics plan could focus on those fraud risks with a high residual rating. The auditor could select those fraud risks that are often associated with the particular industry or with fraud scenarios previously uncovered within the organization—or the auditor might simply limit the scope to three fraud scenarios. Within this text, we plan to explain the methodology for building your fraud data analytics plan; readers will need to determine how comprehensive to make their plan.

What Is Fraud Data Analytics?

Fraud data analytics is the process of using data mining to analyze data for red flags that correlate to a specific fraud scenario. The process starts with a fraud data analytics plan and concludes with the audit examination of documents, internal controls, and interviews to determine if the transaction has red flags of a specific fraud scenario or if the transaction simply contains data errors.

Fraud data analytics is not about identifying fraud but rather, identifying red flags in transactions that require an auditor to examine and formulate a decision. The distinction between identifying transactions and examining the transaction is important to understand. Fraud data analytics is about creating a sample; the audit program is about gathering evidence to support a conclusion regarding the transaction. The final questions in the fraud audit process: Is there credible evidence that a fraud scenario is occurring? Should we perform an investigation?

It is critical to understand that fraud data analytics is driven by the fraud scenario versus the mining of data errors. Based on the scenario, it might be one red flag or a combination of red flags. Yes, some red flags are so overpowering that the likelihood of fraud is higher. Yes, some red flags simply correlate to errors. The process still needs the auditor to examine the documents and formulate a conclusion regarding the need for a fraud investigation. It is important to understand the end product of data analytics is a sample of transactions that have a higher probability of containing one fraudulent transaction versus a random sample of transactions used to test control effectiveness. One could argue that fraud data analytics has an element of Las Vegas. Gamblers try to improve their odds of winning. Auditors try to improve their odds of detecting fraud. Figure 1.1 illustrates the concept of improving your odds by reducing the size of the population for sample selection.

Figure 1.1 Improving Your Odds of Selecting One Fraudulent Transaction

Within most literature, a vendor with no street address is a red flag fraud. But a red flag of what? Is a blank street address field indicative of a shell company? How many vendors have no address in the accounts payable file because all payments are EFT? If a vendor receives payment through the EFT process, then is the absence of a street address in your database a red flag? Should a street address be considered a red flag of a shell company? Is the street address linked to a mailbox service company? What are the indicators of a mailbox service company? Do real companies use mailbox service companies? Fraud examiners understand that locating and identifying fraudulent transactions is a matter of sorting out all these questions. A properly developed fraud data‐mining plan is the tool for sorting out the locating question.

To start your journey of building your fraud data analytics plan, we will need to explain a few concepts that will be used through the book.

What Is Fraud Auditing?

Fraud auditing is a methodology to respond to the risk of fraud in core business systems. It is a combination of risk assessment, data mining, and audit procedures designed to locate and identify fraud scenarios. It is based on the theory of fraud that recognizes that fraud is committed with intent to conceal the truth. It incorporates into the audit process the concept of red flags linked to the fraud scenario concealment strategy associated with data, documents, internal controls, and behavior.

It may be integrated into audit of internal controls or the entire audit may focus on detecting fraud. It may also be performed because of an allegation or the desire to detect fraudulent activity in core business systems. For our discussion purposes, this book will focus on the detection of fraud when there is no specific allegation of fraud.

Fraud auditing is the application of audit procedures designed to increase the chances of detecting fraud in core business systems. The four steps of the fraud audit process are:

Fraud risk identification

. The process starts with identifying the inherent fraud schemes and customizing the inherent fraud scheme into a fraud scenario. Fraud scenarios in this context will be discussed in

Chapter 2

.

Fraud risk assessment

. In the traditional audit methodology the fraud risk assessment is the process of linking of internal controls to the fraud scenario to determine the extent of residual risk. In this book, fraud data analytics is used as an assessment tool through the use of data‐mining search routines to determine if transactions exist that are consistent with the fraud scenario data profile.

Fraud audit procedure

. The audit procedure focuses on gathering audit evidence that is outside the point of the fraud opportunity (person committing the fraud scenario). The general standard is to gather evidence that is externally created and externally stored from the fraud opportunity point.

Fraud conclusion

. The conclusion is an either/or outcome, either requiring the transaction to be referred to investigation or leading to the determination that no relevant red flags exist.

Chapters 6

through

15

contain relevant discussion of fraud data analytics in the core business systems.

What Is a Fraud Scenario?

A fraud scenario is a statement as to how an inherent scheme will occur in a business system. The concept of an inherent fraud scheme and the fraud risk structure is discussed in Chapter 2. A properly written fraud scenario becomes the basis for developing the fraud data analytics plan for each fraud scenario within the audit scope. Each fraud scenario needs to identify the person committing the scenario, type of entity, and the fraudulent action to develop a fraud data analytics plan. The auditing standards also suggest identifying the impact the fraud scenario has on the company.

While all fraud scenarios have the same components, we can group the fraud scenarios into five categories. The groupings are important to help develop our audit scope. The groupings also create context for the fraud scenario. Is the fraud scenario common to all businesses or is the fraud scenario unique to our industry or our company? There are five categories of fraud scenarios:

The common fraud scenario

. Every business system has the same listing of common fraud scenarios. I do not need to understand your business process, conduct interviews of management, or prepare a flow chart to identify the common fraud scenarios.

The company‐specific fraud scenario

. The company‐specific fraud scenario in a business cycle because of business practices, design of a business system, and control environment issues. I do need to understand your business process, conduct interviews of management, or prepare a flow chart to identify the common fraud scenarios.

The industry‐specific fraud scenario

. The industry specific fraud scenarios are similar to the common fraud scenario, except the fraud scenario only relates to an industry. To illustrate the concept, mortgage fraud is an issue for the banking industry. This category of fraud scenarios requires the fraud auditor to be knowledgeable regarding their industry. However, using the methodology in

Chapter 2

, a nonindustry person could create a credible list of fraud scenarios.

The unauthorized fraud scenario

. The unauthorized fraud scenario occurs when an individual, either internal or external to the company, commits an act by overriding company access procedures.

The internal control inhibitor fraud scenario

. The concept of internal control inhibitor is to identify those acts or practices that inhibit the internal control procedures from operating as designed by management. The common internal control inhibitors are collusion and management override.

Chapter 2 will explain the concept of the fraud risk structure and how to write a fraud scenario that drives the entire fraud audit program. Chapter 2 will also cover the concept of fraud nomenclature. In the professional literature, we use various fraud words interchangeably, which I believe creates confusion within the profession. Words like fraud risk statement, fraud risk, and inherent fraud schemes, fraud scenario, fraud schemes, and inherent fraud risk are used to describe how fraud occurs for the purpose of building a fraud risk assessment or fraud audit program. Within this book, I will use the phrase fraud scenario as the words that drive our fraud data analytic plan.

What Is Fraud Concealment?

Fraud concealment is the general or specific conditions that hide the true nature of a fraudulent transaction. A general condition is the sheer size of database, whereas a specific condition is something that the perpetrator does knowingly or unknowingly to cause the business transaction to be processed in the business system and hide the true nature of the business transaction.

To illustrate the concept, all vendors need an address or a bank account to receive payment. On a simple basis, the perpetrator uses his or her home address in the master file. On a more sophisticated level, the perpetrator uses an address for which the linkage to the perpetrator is not visible within the data—for example, a post office box in a city, state, or country that is different from where the perpetrator resides. The fraud data analytics plan must be calibrated to the level of fraud sophistication that correlates to the specific condition of the person committing the fraud scenario. In Chapter 3, the sophistication model will describe the concepts of low, medium, and high fraud concealment strategies. The calibration concept of low, medium, and high defines whether the fraud scenario can be detected through the master file or the transaction file. It also is a key concept of defining the audit scope.

It is important to distinguish between a fraud scenario and the associated concealment strategies. Simply stated, the fraud scenario is the fraudulent act and concealment is how the fraudulent act is hidden. From an investigation process, concealment is referred to as the intent factor. From a fraud audit process, the concealment is referred to as the fraud concealment sophistication factor.

What Is a Red Flag?

A red flag is an observable condition within the audit process that links to the concealment strategy that is associated with a specific fraud scenario. A red flag exists in data, documents, internal controls, behavior, and public records. Fraud data analytics is the search for red flags that exist in data that links to documents, public records, persons, and eventually to a fraud scenario.

The red flag is the inverse of the concealment strategy. The concealment strategy is associated with the person committing the fraud scenario and the red flag is how the fraud auditor observes the fraud scenario.

The red flag theory becomes the basis of developing the fraud data profile, which is the starting point of developing the fraud data analytics plan. The red flags directly link to the fraud concealment strategy. The guidelines for using the red flag theory are discussed in Chapter 3.

What Is a False Positive?

A false positive is a transaction that matches the red flags identified in the fraud data profile but the transaction is not a fraudulent transaction. It is neither bad nor good. It simply is what it is. What is important is that the fraud data analytics plan has identified a strategy for addressing false positives. Fundamentally, the plan has two strategies: Attempt to reduce the number of false positives through the fraud data analytics plan or allow the fraud auditor to resolve the false positive through audit procedure. There may be no correct answer to the question; however, ignoring the question is a major mistake in building your plan.

What Is a False Negative?

A false negative is a transaction that does not match the red flags in the fraud data profile but the transaction is a fraudulent transaction. From a fraud data analytics perspective, false negatives occur due to not understanding the sophistication of concealment as it related to building your fraud data analytics plan. Other common reasons for a false negative are: data integrity issues, poorly designed data interrogation procedures, the lack of data, and the list goes on.

While false positives create unnecessary audit work for the fraud auditor, false negatives are the real critical issue facing the audit profession because the fraud scenario was not detected.

The false positive conundrum: Refine the fraud data analytics or resolve the false positive through audit work.

There is no real correct answer to the question. The fraud data analytics should attempt to provide the fraud auditor with transactions that have a higher probability of a person committing a fraud scenario. The fraud data interrogation routines should be designed to find a specific fraud scenario. That is the purpose of fraud data analytics. However, by the nature of data and fraud, false positives will occur. Deal with it. The real question is how to minimize the number of false positives consistent with the fraud data analytics strategy selected for the fraud audit.

Remember, fraud data analytics is designed to identify transactions that are consistent with a fraud data profile that links to a specific fraud scenario. There needs to be a methodology in designing the data interrogation routines. The methodology needs to be based on a set of rules and an understanding of the impact the strategy will have on the number of false positives and the success of fraud scenario identification.

The reality of fraud data analytics is the process will have false positives; said another way, there are transactions that will have all the attributes of a fraud scenario, but turn out to be valid business transactions. That is the reality of the red flag theory. Unfortunately, the reality of fraud data analytics is that there will also be false negatives based on the strategy selected. This is why before the data interrogation process starts, there must be a defined plan that documents the auditor judgment. Senior audit management must understand what the plan is designed to accomplish and why the plan is designed to fail. Yes, based on the correlation of audit strategy and sophistication of fraud concealment, you can design a plan to fail to detect a fraud scenario. At this point in the book, do not read this as a bad or good; Chapter 3 will explain how to calibrate your data interrogation routines consistent with the sophistication of concealment.

To provide a real‐life example, in one project involving a large vendor database, our fraud data analytics identified 200 vendors meeting the profile of a shell company. At the conclusion, we referred five vendors for fraud investigation. In one sense, the project was a success; in another sense, we had 195 false positives.

If I could provide one suggestion based on my personal experience, the person using the software and the fraud auditor need to be in the same room at the same time. As reports are created, someone needs to look at the report and refine the report based on the reality of the data in your database. Fraud data analytics is a defined process and with a set of rules. However, the process is not like the equation 1 + 1 = 2. It is an evolving process of inclusion and exclusion based on a methodology and fraud audit experience. So, do not worry about the false positive, which simply creates unnecessary audit work. Worry about the false negative.

Fraud Data Analytics Methodology

I commonly hear auditors talk about the need to play with the data. This is one approach to fraud detection. The problem with the approach is that it relies on the experience of the auditor rather than on a defined methodology. I am not discounting audit experience, I would suggest that auditor experience is enhanced with a methodology designed to search for fraud scenarios. In fact, the data interpretation strategy explained in Chapter 3 is a combination of professional experience and methodology.

The fraud data analytics methodology is a circular approach to analyzing data to select transactions for audit examination (Figure 1.2).

Figure 1.2 Circular View of Data Profile

Fraud scenario

. The starting point for building a fraud data analytics plan is to understand how the fraud risk structure links to the audit scope. The process of identifying the fraud scenarios within the fraud risk structure and how to write the fraud scenario is discussed in

Chapter 2

.

Strategy

. The strategy used to write data interrogation routines needs to be linked to the level of sophistication of concealment. For purposes of this book there are four general strategies, which are explained in

Chapter 3

.

Sophistication of concealment impacts the success of locating fraudulent transactions

. A common data interrogation strategy for searching for shell companies is to match the addresses of employees to the address of vendors. While a great data analytics step, the procedure is not effective when the perpetrator is smart enough to use an address other than a home address. So, at this level of concealment, we need to change our strategy. A complete discussion of fraud concealment impact on fraud data analytics is in

Chapter 3

.

Building the fraud data profile is the process of identifying the red flags that correlates to entity and transaction

. All fraud scenarios have a data profile that links to the entity structure (i.e., name, address, etc.) and the transaction file (i.e., vendor invoice). The specific red flags will be discussed in

Chapters 6

through

15

.

The plan starts with linking the fraud scenario to the fraud data profile

. Then it uses the software to build the data interrogation routines to identify the red flags and overcome the concealment strategies.

In reality, the search process is seldom one‐dimensional

. It is a circular process of analyzing data and continually refining the search process as we learn more about the data and the existence of a fraud scenario in the core business system.

Assumptions in Fraud Data Analytics

The certainty principle

. The degree of certainty concerning the finding of fraud will depend on the level of concealment sophistication and the on/off access to books and records. When the fraud is an on‐the‐book scheme and has a low level of sophistication, the auditor will be able to obtain a high degree of certainty that a fraud scenario has occurred. Consequently, with an off‐the‐book fraud scenario and high level of sophistication, the auditor will not achieve the same degree of certainty that a fraud scenario has occurred. Therefore, the auditor must recognize the degree of certainty differences when developing the fraud audit program.

The difficulty in ascertaining the degree of certainty directly influences the quality and quantity of evidence needed. If an auditor assumes a low level of certainty with regard to a fraud scenario occurring, then the auditor may not incorporate the gathering of credible evidence at all. However, if an auditor is well versed in fraud scenario theory and, therefore, establishes some degree of certainty that a scenario has occurred, the audit plan needs to incorporate the obtaining of the appropriate amount and quality of evidence to justify that degree of certainty.

Specifically, as part of the fraud audit plan, it should first be determined what elements of proof will be necessary to recommend an investigation. Then a decision is needed to determine if the chosen elements are attainable in the context of a fraud audit based on the specific scenario, concealment sophistication, and access to books and records.

The linkage factor

. The term

link

is used extensively throughout the entire book as it aptly highlights the relationship between the various fraud audit program components and objectives. For example, the fraud audit program is built by linking the data mining, audit testing procedures, and audit evidence considerations to a given fraud scenario found in the risk assessment. At its core, the concept of linkage is a simple one; however, with the traditional audit program as a frame of reference, many auditors have difficulty grasping the idea that fraud audit procedures should be designed, and therefore, linked to a specific fraud scenario. The entire book is based on the linkage factor. All fraud data analytic routines must be linked to a fraud scenario or all fraud scenarios must be linked to a fraud data analytics routine.

Cumulative principle

. Seldom is one red flag sufficient to identify a fraud scenario within a database. It is the totality of the red flags that are indicative of a fraud scenario. The process should incorporate a summary report of the tests to score each entity or transaction. When we search for fictitious employee, commonly referred to as a ghost employee, a duplicate bank test will identify false positives because two or more employees are family members. However, when one of the employees is a budget owner and the second employee has a different last name, address, no voluntary deductions, postal box address, and no contact telephone number, it is the totality of the red flags versus anyone red flag. This is an important concept to incorporate into the fraud data analytics plan.

Basis for selection for testing

. Fraud data analytics is all about selecting transactions for fraud audit testing. The basis for selection must be defined and understood by the entire team.

The Fraud Scenario Approach

The approach is simple. In essence, you develop an audit program for each fraud scenario. The starting point is to identify all the fraud scenarios within your audit scope. Within the audit project this is the process of developing your fraud risk assessment. The final step in the fraud risk assessment is the concept of residual risk. The dilemma facing the profession is how the concept of residual risk should impact the decision of when to search for fraud in core business systems. The question cannot be ignored, but there is no perfect answer to the question. It is what I call the likelihood conundrum.

The Likelihood Conundrum: Internal Control Assessment or Fraud Data Analytics

Does the auditor rely on internal controls or does the auditor perform fraud data analytics? There is no simple answer to the question; I suspect one answer could be derived from the professional standards that the auditor follows in the conduct of an audit. In my years of teaching audit professionals the concept of fraud auditing, I have seen the struggle on the auditors' faces. The reason for the struggle is that we have been told that a proper set of internal controls should provide reasonable assurance in preventing fraud scenarios from occurring. There are many reasons why an internal control will fail to prevent a fraud scenario from occurring. The easiest fraud concept to understand why internal controls fail to prevent fraud is the concept of internal control inhibitors. We cannot ignore collusion and management override in regard to fraud.

We need to understand that fraud can occur and comply with our internal controls. I suspect this is an area of great disagreement in the profession between the internal control auditors and the fraud auditors. Even if you believe that internal controls and separation of duties will prevent fraud, what is the harm in looking for fraud? So, we give management a confirmation that fraud scenarios are not occurring in the business system. We do the same confirmation with internal controls: Because we see the evidence of an internal control we assume that the control is working. If the auditor is serious about finding fraud in an audit, then the auditor must start looking for fraud. For me, the likelihood conundrum is much ado about nothing. Management, stockholders, and boards of directors all think we are performing tests to uncover fraud.

How the Fraud Scenario Links to the Fraud Data Analytics Plan

With each scenario, the auditor will need to determine which scenarios are applicable to fraud data analytics and which fraud scenarios are not applicable to fraud data analytics. For example: A product substitution scheme can occur when the receiver accepts an inferior product but indicates the product conforms to the product requirements. This fraud scenario does not lend itself to fraud data analytics because the clue is not in the data. However, a vendor that consistently submits invoices exceeding the purchase order within the payment tolerances can be identified. Once the list of scenarios relevant to the plan are identified the next step is to understand how the three critical elements of the scenario impact the plan.

The elements of scenarios that are relevant to creating an effective fraud data analytics plan are: the person who commits the scenario, the type of entity, and the type of action we are looking for.

To illustrate the concept, as a starting point we will consider the “who” as either the budget owner, accounts payable function, or a senior manager. A common test is to search for vendors created in the master file at off‐periods. If the scenario is focusing solely on the budget owner, is the off‐period test relevant to the scope of the project? Now let's change the person committing the scenario to someone in the accounts payable function. Now the off‐period test is relevant to the audit scope.

The second aspect of a scenario is the type of entity. Are we searching for a false vendor or a real vendor? If the vendor is real, then searching for vendors with P.O. boxes is not relevant because real vendors tend to use P.O. boxes, whereas if we are searching for real vendors operating under multiple names, then a duplicate test on the address field is relevant.

The third aspect of a scenario is the fraudulent action. If the vendor is real and the fraud scenario is overbilling based on unit price inflation, then searching for a sequential pattern of invoices is not relevant. The test should focus on changes in unit price or comparisons of unit prices for similar items among common vendors.

The fourth element of a fraud scenario is the impact statement. While critical to the fraud scenario statement, the impact statement is not typically associated with the data analytics plan but is critical to the investigation process. The following two scenarios illustrate the concept:

Senior manager acting alone or in collusion with a direct report/causes a shell company to be set up on the vendor master file/causes the issuance of a purchase order and approves a false invoice for services not received/

causing the diversion of company funds

.

Senior manager acting alone or in collusion with a direct report/causes a shell company to be set up on the vendor master file/causes the issuance of a purchase order and approves a false invoice for services not received/

depositing the funds in an off‐the‐book bank account for the purpose of paying bribes

.

A close examination of the two fraud scenarios reveals that the fraud data analytics plan is exactly the same for both scenarios. In both scenarios, the fraud data analytics is searching for a shell company and a pattern of false invoices.

From a fraud investigation plan, the first scenario is an asset misappropriation scenario while the second scenario is associated with a corruption scheme mostly connected to an FCPA violation.

Skills Necessary for Fraud Data Analytics

Building a fraud data analytics plan requires a defined skill set. The absence of one skill set will diminish the effectiveness of the plan. The audit team needs to ensure all the right skills are contained within the team:

Knowledge of fraud

. Since fraud data analytics is the process of searching for fraudulent transactions, the auditor must have a full understanding of the fraud concepts.

Fraud scenarios

. This skill relates to how to write a fraud statement that correlates to developing a fraud data analytics statement. For an analogy, the scenario approach should be considered the system design aspect of the project and creating the routines is the program aspect of the project, or the scenario creates the questions and the fraud data analytical plan creates the answers.

Information technology knowledge

. Data reside in large, complex database systems. The ability to communicate with the IT function to locate and extract the data is the starting point of the data interrogation phase of the plan.

Audit software knowledge

. Coding software, whether writing scripts or using software functions, is necessary to write the data interrogation routines. The ability of the auditor to clean data, reformat data, combine data, and create reports is an absolutely necessary skill.

Audit knowledge

. Fraud data analytics is just one aspect of conducting an audit. Understanding fraud risk assessment, building audit scopes, designing audit steps, and formulating conclusions based on audit evidence rules is what fraud data analytics is all about. Second, designing fraud test procedures for the selected items is just as important as the fraud data analytics.

Understand data from a real‐world perspective

. In each data column there is information. We need to understand how to use that information. To illustrate the concept, using something as easy as an address field in a vendor database, the information in the field may correlate to a payment address, a physical address, a public mailbox service address, a nonpublic mailbox service address, mail forwarding services, or a bookkeeping service company. Yes, you must understand the data in a data field from a business perspective to develop a data interrogation routine. A vendor invoice number may have several patterns, depending on the industry and size of the business. The patterns are: no invoice number, date format, sequential ascending project number with a progress billing number, numeric or alpha format, and a sequential number linked to a customer number. So, how does the pattern link to the fraud scenario or the fraud concealment?

Summary

As a conclusion to Chapter 1 and throughout the remainder of the book, I would like to offer some of the lessons learned throughout my fraud audit career. First, note the important points to understand about fraud data analytics, and then note some of the common mistakes one can make in fraud data analytics. I hope you find the points useful as you conduct your next fraud data analytics project.

Axioms of Fraud Data Analytics

The world's best audit program and the world's best auditor cannot detect fraud unless their sample includes a fraudulent transaction.

I do not know what a perpetrator will do, but I do know everything the perpetrator can do.

While we do not know how a perpetrator will commit a fraud or how he will conceal the fraud, we can determine the logical permutations.

The better you can describe the fraud scenario, the more likely you will be able to find it.

False positives will occur. You try to resolve false positives either through your fraud data analytics or through an auditor performing audit procedures.

In fraud data analytics, fraud likelihood is based on data versus the effectiveness of internal controls.

We search for transactions that mirror the red flag theory of the fraud scenario.

The better we understand data, the better we can use data to search for a fraudulent transaction.

Errors and fraud have a lot in common.

Red flags correlate to both errors and fraud.

Data are not perfect.

Databases contain data errors, caused either by mistake or with intent.

We can only search data when the data reside in our databases.

Fraud data analytics is both a science and an art.

Common Mistakes in Fraud Data Analytics

No plan. Please do not jump in without a plan.

Starting the fraud data analytics process without a clearly defined fraud scope.

Creating reports that do not link to a specific fraud scenario.

Searching for data exceptions versus the red flags of a fraud scenario.

Assuming that a data integrity issue is an indicator of fraud.

Failure to understand the integrity of the data being examined.

Failure to understand the type of data that reside in a data field.

No effective plan for false positives.

Not worrying about false negatives.

The fraud data analytics strategy is not calibrated for the level of fraud concealment sophistication.

No planned audit procedure for the fraud data analytics report.

Chapters 2 to 5 are intended to provide a methodology for building your fraud data analytics plan. The remaining chapters are intended to describe the common fraud scenarios in a core business system and how to build your fraud data analytics plan to locate the fraud scenario in core business systems.

Chapter 2Fraud Scenario Identification

To start with an old saying, the house is only as strong as the foundation. In this chapter, the fraud data analytics plan is the house and the fraud scenario is the foundation. The purpose of this chapter is to explain the fraud risk structure and how to write a fraud scenario. In one sense, it sounds like an easy task. In another sense, it is a daunting task. If you have read my other books, you will hear a similar reading, but hopefully the methodology is refined based on more years of practical experience.

The purpose of the fraud risk structure is to define the scope of the fraud audit project. The purpose of the fraud scenario is to act as the design plan for the programmer. Using the fraud scenario the programmer creates the search routines of databases for transactions that meet the data profile for each fraud scenario. The red flags associated with each fraud scenario provide the basis of the selection of transactions for audit examination. The programming can only be as good as the fraud scenario statement. The red flags can only be as good as the integrity of the data in the database.

Fraud risk identification requires a methodology and standards to be followed in identifying and writing a fraud scenario. This chapter will focus on the methodology as it is related to fraud data analytics plan. As such, not all aspects of the fraud risk structure will be covered in this book. Only those aspects that are relevant to fraud data analytics are covered in the book.

At the risk of repeating a concept throughout the book, the fraud data analytics is about searching for transactions that are consistent with the fraud data profile associated with a specific fraud scenario. This is my point; the word fraud is too broad to be useful as a search concept. Therefore, we need a way to determine what type of fraud we are searching for within our data analytics project and which fraud scenarios.

Fraud Risk Structure

The fraud risk structure shown in Figure 2.1 is a tool used to establish the scope of the fraud data analytics project. In a sequential manner, it entails the primary classification of fraud, the secondary classification or subclass of the primary category of fraud, the inherent fraud schemes, and lastly, the fraud scenarios.

Figure 2.1 The Fraud Risk Structure

How to Define the Fraud Scope: Primary and Secondary Categories of Fraud

In its simplest of definitions, the fraud risk structure is a comprehensive classification system to identify all the possible fraud scenarios facing an organization. Fraud is complicated, and we want to make its identification as effortless as possible. However, its complexity tends to be caused by layering and overlapping; therefore, we have broken down the schemes into two levels, denoted herein as primary and secondary. Within each secondary category there are inherent schemes that are composed of an entity structure and a fraud action statement. From the inherent scheme structure, the fraud auditor creates the fraud scenarios that become the basis of the fraud data analytics plan.