FAFP Backgroud PDF
FAFP Backgroud PDF
FAFP Backgroud PDF
Contents
1. Introduction to Fraud investigation and Forensic Accounting
2. Fraud and Audit: modern day scenario
3. Areas of opportunities for ICAI members and those involved
in fighting fraud
4. Types of Frauds and financial crimes
5. Familiarization with Red flags in Detection of Frauds.
6. Steps in conducting an investigation
7. Tools and techniques used in fraud detection and
investigation
8. Computer Aided Audit Techniques and Tools (CAATTs)
9. Overview
Appendices
Preamble: After the Enron debacle, auditing all over the world
has come under the scanner. The age old saying that an auditor
is a watchdog and not a blood hound is being re-examined, if not
questioned. Legislation which seeks to lay a greater emphasis on
detection and reporting of fraud by auditors has been introduced
all over the globe. In this context, the article examines an
auditors duty as regards detection and reporting of fraud. It
examines the causative factors that led to Enrons bankruptcy
and some of the subsequent legislation in India and ICAIs
pronouncements affecting an auditors duty and responsibility
towards the issue of fraud. For this purpose, the relevant clauses
in the Companies (Auditors Report) Order, 2003 (CARO), the
Standards of Auditing (SA), and certain observations made in a
recent high court judgment in Maharashtra (Note 3) have been
considered. To get an international flavor, the article also
examines the findings of the OMalley Report (Note 1) on audit
effectiveness. To make this study more interesting, the new
enhanced role of the auditor is examined with the help of a case
study.
Comparison of auditing scenarios before and after the turn
of the millennium.
In the last decade, two things have impacted the auditors role a
great deal: a) The rapidly evolving IT environment and b) the
Enron debacle in 2001. E-commerce and computerization in all
walks of life, for all the conveniences offered, have made
business practices and business models more and more
complex. New business models have sprung up where
commerce transcends not only huge distances, but also time
zones, currencies and countries. Data volumes are huge and
products with incredible technical specifications are introduced
every other day.
Introduction to Fraud Investigation andForensic Accounting 13
Auditors role under the scanner. Panic buttons were pressed all
over the world and new legislation and statutory pronouncements
enhancing the role of auditors were announced. The Sarbanes
Oxley Act came into force in 2002 with revolutionary reporting
and disclosure requirements in audited accounts. For the first
time the CEO and CFO were obligatorily required to attest the
financial statements and also comment on existence of fraud.
World over, questions were raised about the performance of the
auditors. Undoubtedly, the auditors image was severely
impaired. Auditing practices, and auditing standards were all
revisited to make auditors address the issue of fraud and
emphasizing the need for greater audit effectiveness. In order to
understand the auditors role from the point of view of detection
and reporting of fraud, it would be useful to conduct a simple
case study.
Case Study of a Van Sales -business model.
Consider a business model applying the Van Sales method of
selling Fast Moving Consumer Goods (FMCG). This model was
conceived by a company with a view to reach out to
geographically far-flung untapped areas of potential demand. The
model required deployment of a fleet of multiple trailer vans
stacked with FMCGs like soaps, toothpastes, gels, creams,
biscuits, etc. The van crew would consist of a driver and a sales
representative given a specific route, (which could be hundreds
of kilometers long in the country), to find retailers, shops and
other buying entities to sell the products. Both cash and credit
sales were permissible within policy norms. These sales
operations were monitored through palmtop computers and small
portable printers provided to salesmen in the vans. Each palmtop
was linked to the main central server at the head office. The
salesmen made efforts to maximize their sales by approaching
retailers/ shops and buying outlets spotted on along the route.
The sales deliveries, invoices and collection receipts were raised
at the remote locations by the salesmen using the palm top
computers and printers provided. The palmtop sales system had
well designed controls built in to monitor credit limits, sales
Fraud And Audit:Modern Day Scenario 15
generally buy his required quantity on the first visit itself. This led
the auditor to believe that the discounts were not genuine.
However, since the names and addresses of the shoppers were
not available proving any foul play was difficult. This was an ideal
place to try the sting operation or an investigators bluff
technique. He decided to test out the scheme, by planting a
shopper who purchased chocolates worth Rs.2, 500. As
expected, the shopper did not get the discount coupon. He was
given a receipt of Rs.2, 500, numbered 20026. The receipt had
left the spaces relating to information of discount coupon, as well
as the net payment amount blank. At the end of the day, the
cashier reported his total cash sales for the day and a statement
of discount coupons issued, which showed that discount coupon
no 2113 had been issued against the receipt 20026. The auditor
immediately confronted the cashier who confessed that he had
fraudulently retained the discount coupon himself. He explained
how he was cashing such discount coupons as follows:
Step 1: Receipt 20026 was issued to A for Rs. 2,500/-
Step 2: Daily Cash Receipt and Discount coupons statement
would disclose: Coupon 2113 against Receipt 20026 Discount
Coupon 2113 was actually in possession of the cashier.
Step 3: The cashier awaits another customer purchasing
chocolates who does not ask for a receipt. The cashier would
make out a receipt for the value of purchase which was say
Rs.1,500/- and append the discount coupon 2113 for 10 %,
indicating a deduction of Rs.150/- in the discount column.
Step 4: The cashier would pocket Rs.150/- and place Rs. 1,350/-
in the cash box.
In this manner he had siphoned off almost Rs.20,000 per week.
This would never have come to light if the auditor had not applied
a field check, and followed it up with the sting operation. Very
often the audit procedures applied by the auditors do disclose
weakness in controls and anomalies in findings. However, the
audit stops short of discovering or bringing to light the actual
damage done and the nature of deceit or trickery. It is therefore
56 Forensic Accounting and Fraud Detection
macro evaluation is vital. All clues must fit and all facts must be in
harmony. In those assignments where a fraud appears to exist, a
wonderful approach can be adapted from the Mimamsa doctrine
from our sacred vedic scriptures. In simple words this doctrine
launches an inquiry to test the truth of various vedic assertions. It
provides a structured, balanced and equitable method of
conducting an inquiry and reaching a conclusion. It expounds a
logical process of analysis. Mimamsa examines the truth value of
each vedic assertion as follows:
1. Definition of Vishaya Vakya or the subject matter
2. Enumerating doubts of the Vishaya called Samsaya
3. The third step is placing forward arguments against the
doubts called Poorva Paksha
4. The fourth step is to furnish rebuttals to the arguments in 3
above called Uttara Paksha
5. The fifth and final step is to come to the conclusion or the
Nirnaya
A parallelism can be drawn to issues in fraud detection and
forensics. This spiritual philosophy fits into the study of forensics
and assignments of fraud detection like a hand in a glove These
five steps are the most appropriate steps in fraud detection in
situations where fraud is suspected and innocence or guilt has to
be established. The final conclusion should be drawn only after
reviewing all the steps in detail, by applying the science of
reasoning, assessing the strengths and reliability of the evidence
as well as the shortcomings and information available and also
considering information not available. The final conclusion then
reached, would be just and unassailable. The Mimamsa doctrine
thus facilitates structuring an approach for making an inquiry. If
all these above mentioned steps are followed, then, the final
report would certainly be equitable, fair and balanced.
An illustration of how this doctrine could be applied in a case of
an assignment inquiring into allegations of vendor bias against a
purchase manager could be briefly explained as follows: After all
the steps prior to the evaluation of evidence stage are carried
58 Forensic Accounting and Fraud Detection
All the checks stated above were a part of the direct audit
approach, the Assessment of clues approach. This involved an
overview of the entire case which included determination and
establishment of relevant facts, confirmation of chronology of
events and interrelationship of data. Though he did not have any
direct query, there were several anomalies which needed to be
explained or reasoned out. The following observations led him to
believe that the claim was overstated and required an
investigation.
Extraordinary Increase of total Inventory value: The past
physical verification statement of the auditors as well as the
earlier balance sheets of the firm disclosed stocks less than
50% of the value as on the date of fire.
No evidence or documentary support in terms of orders
from customers for abnormal increase: Orders on hand
as on the date of fire did not even add up to 15% of the total
stock.
Deviation from normal purchase procedures: Some of the
purchases during the last few days before the fire were made
without any advance being paid. The payments were made
after the date of fire. By and large purchases were paid f o r
with 50% advance to suppliers in the past.
Suppliers Delivery Notes for the purchases stated above did
not bear the usual godownkeepers signature.
However, none of these observations really were sufficient
enough for him to conclusively prove that stocks were
overstated. He asked the Auditee for explanations to each of
the above anomalies, which were given in respect of each of
the above observations as follows:
The increase in the quantum and value of the stocks was
due to major sales drive which the firm was proposing to
launch shortly.
The firm had been negotiating a bulk order with a new client
which was in the process of finalization. Besides, a lot of
verbal and telephonic orders were on received as on the date
of fire.
Steps in Conductingan Investigation 71
The point that this case study highlights is that fraud detection is
a creative process and is effective only if all the examination and
review procedures are adopted in harmony and objectively
towards the purpose of the assignment. This theory of inverse
logic is an invaluable aid in situations of this sort. In order to
implement this theory dynamically, a special checklist can be
developed and updated from time to time and used anytime for
future reference.
The cashier confessed that the involved trustee had provided him
with a duplicate set of keys and with the store managers help, a
part of the box was emptied before it was taken to the trusts
office. The instructions given were to cream the large value notes
and foreign currencies and leave behind the smaller
denominations.
Such methods provide not only a trap but also a moral check and
can reduce the probability of fraud.
him/herself that all the clues or facts fit properly. This is the place
where the auditors expertise supported by the audit tool can
work miracles in terms of audit results and findings. What should
be done at this stage, is to compile Data Query Models (DQM) to
test the goodness of fit of all the earlier findings with the facts in
the auditee and control environment. Quite simply, such DQMs
are programs or macros built using audit software for specific
queries. These are possible even in simple spreadsheets, as well
as in advanced audit software.
The strategy for preparing DQMs always stems from the auditors
study of the auditees environment, the control environment, and
the regulatory statutes applicable to the auditee. The information
he/she collects provides various audit clues in the form of facts
and conditions that govern the various transactions, operations
and the activities under audit. Based on these clues, the auditor
can build up a DQM that can be applied to test the fulfillment of
conditions or facts that affect the activity. He/she may require the
aid of an IT manager to provide technical assistance, or achieve
the desired reports. This can be more easily understood from the
following examples.
An example
An auditor found that travelling expenses in a certain company
were high (as well as voluminous), and controls were weak.
Management had not insisted on air/train ticket receipts, and had
been remiss in monitoring travel expenditures. In this context, the
auditor wanted to ascertain whether there was a possibility of any
inflated or false travel claims. He made a list of all the metro
cities to which senior employees travel was high. He also
obtained from a travel agent the details of flight and train
connections, and the days on which such flight/train connection
were available from the city in which the company was situated.
He asked his IT manager to create a DQM which would filter the
clients travel expenses, and each of these were further filtered
by city, with details of days and dates of travel. The DQM was
required also to compare the dates of actual travel with the dates
of flight and train connections available, which were obtained
100 Forensic Accounting and Fraud Detection
1 30.1
2 17.6
3 12.4
4 9.6
5 7.9
6 6.6
7 5.7
8 5.1
9 4.6
This table was compiled after sheer hard work on widely
disparate populations such as a days stock quotations, a
tournaments tennis scores, the numbers on the front page of
The New York Times, the populations of towns, electricity bills in
the Solomon Islands, the molecular weights of compounds, the
half-lives of radioactive atoms and much more.
How does this help auditors? The one word answer for this is
phenomenally. The application of this law in auditing can lead to
Tools and Techniques Used in Fraud Detection and Investigation 103
get a place even though there were a large number of tables and
covers. An auditor applied the digital test on cash memo
collections. He was surprised to find that the cash memo
collection amounts for a period beginning with the digit 1, (for
single customers -value Rs 100, or 10 customers per cash
memo- value Rs1,000 or multiples thereof) were only 18%
whereas Benfords Law states that they should have been 30.1
%. The auditor discussed this observation with the manager who
was also surprised. This was because, a large part of their
patronage was from nearby corporate office executives who
came for lunch, mostly alone. They were quite regular and
therefore cash memos for single customer lunches should have
been substantial. Carrying out his analysis further, the auditor
filtered out data relating to single customer cash memos (Rs 100
cash memos) and averaged them for a month. He found that the
average single customer cash memo collection per day did not
exceed Rs 1500, i.e. not more than 15 such single customers
had lunch in a day. However the manager said that this was not
correct because at least 25 such single customers patronized the
restaurant each day. Even the auditor confirmed this when he
personally visited the restaurant the next day at lunch time.
Inspire of the fact that the cash memo system was computerized,
and, a system procedural control that no one was allotted a table
unless he had taken a cash memo printed from the counter cash
income suppression appeared possible. The auditor then decided
to apply a walk through test of the collection system and bought a
lunch cash memo. The cash memo which was issued to him
seemed quite normal. He asked one of his team members to try
out the same thing on a different day. Again, the cash memo
seemed normal. However he saw that the serial number (a six
digit number) was the same as his own cash memo of the earlier
day, though the date was different. This was strange and he felt
that something was wrong with the cash memo. He discussed
the matter with the vendor who had supplied the software and
explained to him this strange anomaly. The vendor took one look
at the cash memo and straight away stated that the cash memos
which the auditor had, were not generated by his software. The
Tools and Techniques Used in Fraud Detection and Investigation 105
CONCLUSION
This illustration does not in any way reduce the importance and
effectiveness of traditional audit procedures. However it
accentuates the need to treat investigation as a science as well
as an art. Nothing should be treated as standard and routine.
The very essence of a professional service is to provide
meaningful results. This is possible only when constant
refinement, improvement and betterment of services are sought.
Revolutionary changes must be brought where useful to
106 Forensic Accounting and Fraud Detection
1. Check Missings
2. Check Duplicates
3. Round Numbers
4. Repetitive Odd-Numbers
5. Classification
6. Stratification
7. Single Transactions
8. Isolated Outliers
1. Check Missing:
Here we basically try to identify the gaps in any workflow that has
serial control mechanism. For example, missing cheques
numbers, insurance policies numbers, and bank fixed deposit
receipts, good received notes, cash receipt numbers, etc.
Depending upon the availability of data viz-a-viz audit objectives,
an appropriate data attribute (data field) may be selected to run
this check. Missing gaps can be filtered for auditees
explanations.
Example:
In one of the Company there were a few missing cheque numbers
that could not be physically traced. Nor were proper explanations
available whether they were factually cancelled or missing. Later
it was revealed that the accountant had pilfered them and in fact
one of the adjacent cheque number was surreptitiously encased
too. In another case, a missing Bank Guarantee document was
misused to help an accomplice qualify for eligibility criteria in a
Government Tender.
Following are some of the examples of areas where controls are
exercise through serial sequence mechanism
Control Documentation : GRNs, Cash Receipts, Cheque
Nos., Gate pass, DCs, Pack-List, Invoice, Coupons, Tickets,
Sale Orders, Agreement Numbers, PO/WO, Trade Nos. -
stock markets, contracts_nos, etc.
Computer Aided Audit Techniquesand Tools (CAATTs) 111
2. Check Duplicates :
This is converse of Check-Missings--- the serial control numbers
which ought not to be repeated are checked for duplicates. Thus
all the documents (that have serial control), mentioned in the
above paragraph can be checked for replication. Duplicated
numbers could throw up serious gaps in the sourcing of these
documents or in case they have been generated using some
computerized system could mean a software bug. All such
duplicated numbers need thorough detailed review to dispel any
wrong doing.
Here auditor can also check duplication of clustered-fields. That
is, say a cluster of vendor code + bill number can be checked for
duplication, presence of which could indicate excess/double
payments to same vendor. This is sometimes referred to as
Same-Same-Different check.
3. Round Numbers :
Basically there is nothing wrong with Round numbers and it is not
unusual to see many round number transactions in any
commercial deals. However, sometimes round numbers are
symptomatic of mysterious deals. Therefore the auditor should
use some judgement to eliminate possible round number cases.
For example, it is quite natural to generally spot round number
transactions in monthly rentals, professional fees, audit
remuneration, etc. - these transactions could be filtered out from
the list of transactions with round numbers.
Example:
112 Forensic Accounting and Fraud Detection
4. Repetitive Odd-Numbers
This is converse of Round-numbers. Unlike the round numbers,
repetition of odd numbers (particularly repetitions at decimals
levels) are very rare coincident. Unless of course there is
apparent reasons say, like for Telco having promotional offer of
Rs 199/- prepaid packs - but in that case, the repetitions will be by
volumes and not a few stray incidences here and there. Repeated
oddnumber transactions can be filtered for detailed verification
and most often these will throw up some irregularities.
Example:
In one MIS report of a public company running a restaurant
business, the tobacco sale of Rs. 10,89,233/- was repeated
consequently for the month of June and July. This was too much
of coincident to catch the attention of the independent director
who was otherwise a reputed investigator in his professional life.
A few probing questions during the audit committee meeting
revealed that the Manager was faking the MIS numbers and the
amount was result of sloppy use of the spreadsheets copy-paste
command. The Manager had been manipulating MIS reports for
quite some time and over the period casual complacent attitude
had set-in. A detailed investigation launched subsequently
exposed other mismanagement.
Computer Aided Audit Techniquesand Tools (CAATTs) 113
5. Classification
Classification is a process of arranging data into homogenous
group or classes according to some common characteristics
present in the data. This analysis aid the Auditor in getting a birds
eye view to see a panoramic whole of how the data is dispersed
or where the concentration lies. Classification can be combined
with other appropriate CAATT checks to enable more penetrative
tests.
Sr Party_Code Count Sum_Amount %Count %Amt
6. Stratification
Stratification is a derivative of classification which involves
grouping of large data into strata. Strata means levels, bands or
groups. Thus it involves dividing or rearranging the data within the
Strata and then overviewing it to decipher the latent configuration
of the database.
For example the purchase data of the above example can be
stratified into various bands of bill values to obtain following
results :
Strata Bill Counts Bill
Value
3283 1,16,83,515.95
7. Single Transaction
116 Forensic Accounting and Fraud Detection
8. Isolated Outliers
An Isolated outlier is an observation in a data set which is far
extreme in value from the others in the data set. It is an unusually
large or an unusually small value compared to the others. Any
database will be vitiated by incongruent records or contaminated
transactions which will stick out as outliers. That happens
because of its inherent nature that impedes its blending with the
others in the group and will be clearly isolated with the
remainders.
A word of caution -- there could outliers that would creep in any
database as deviations which happens in normal course and may
not always mean a fraud or an error. However, as an auditor s/he
will be concerned about these outliers and should review these
transactions as part of audit plan.
There are various ways to spot the Isolated Outliers as discussed
below.
Simple Charting Options : Using a popular spreadsheets, it is
not difficult to plot a chart of the entire database as shown
below. The database contains 3,283 records of 328 vendors.
The vendor codes are plotted against the x-axis and the
amount against the y-axis.
Relevance ofRSF:
Scrutiny of individual parties account is humanly ineffective and
now with most of the data available digitally how does one
scrutinize the ledgers? RSF theory comes in very handy here,
instantly one can calculate RSF and take sample for verification.
This tool finds focus and meaning to the scrutiny. It highlights all
unusual fluctuations which may be stemming from frauds or
errors.
The investigator first ran a check of RSF on the vendor data and
got the following parties where the RSF exceeded 10.
Vendor Max_Val 2nd Max_ RSF >
Val 10
WAP Systems LLC 25,748,906 2,059,912 12.50
Summarised Steps
Step 1 : Extract the maximum value for each vendor and store in
a column of the work sheet - say col. B
Step 2 : Extract the second maximum value for each vendor and
store in another column say col. C
Step 3 : Divide Col. B by C to get RSF Ratio and store result in
Col. D
Step 4 :Filter Col. D for results where RSF is more than say 10.
Step 5 : Filter records from Database for the above results as
audit sample. Detailed Steps
Step 1 : To obtain the largest or maximum value from the data
Use Pivot Table Function to classify the bill-amount field of
data.
The classification criteria will be vendor name
Classification of Bill amount field will be for Max. Value
Step 2 : To obtain the 2nd maximum value from the data
To obtain the 2nd max value, it will be necessary to nullify the
max. values obtained in Step 1 above. This can be done as
follows.
Extract results obtain from the first step to append to the data
with the maximum value for the each respective vendor. This
can be done by using Vlookup Function.
Formula = Vlookup(CriteriaCellRef, DataSource, Offset)
Nullify the effect of the bill amount if the respective bill value
is equal to the Max. value. Using the If function.
Formula = If(BillValueCellRef = MaxValueCellRef, 0,
BillValueCellRef.)
[The above formula will add to the existing database, a field with
bill amount which is not a MAX.Value.]
Repeat The First Step again to obtain the max value from the
field created above. The max value now will be actually the
2nd Max. value.
Computer Aided Audit Techniquesand Tools (CAATTs) 123
All that has been covered hitherto in this course material has been
brilliantly postulated as the thirteen principles of fraud auditing by
G Jack and Bologna and Robert J Lindquist, in their book on
Fraud Auditing and Forensic Accounting, new tools and
techniques, second edition, page as follows:
1. Fraud auditing is unlike financial auditing. It is more a
mindset than a methodology.
2. Fraud auditors are unlike financial auditors. Fraud auditors
focus on exceptions, oddities, accounting irregularities, and
patterns of conduct, not on errors and omissions.
3. Fraud auditing is learned primarily from experience, not from
audit textbooks or last years working papers. Learning to be
a fraud auditor means learning to think like a thief - Where
are the weakest links in this chain of internal controls? 4.
From an audit perspective, fraud is intentionally
misrepresenting financial facts of a material nature. From a
fraud-audit perspective, fraud is an intentional
misrepresentation of financial facts.
5. Frauds are committed for economic, egocentric, ideological
and psychotic reasons. Of the four, the economic motive is
the most common.
6. Fraud tends to encompass a theory structured around
motive, opportunity andbenefit.
7. Fraud in a computerised accounting environment can be
committed at any state
of processing-input, throughput or output. Input frauds (entering
false and fraudulent data) are the most common.
8. The most common fraudulent schemes by lower-level
employees involve disbursements (payables, payroll, and
benefit and expense claims).
Computer Aided Audit Techniquesand Tools (CAATTs) 125
APPENDICES
128 Forensic Accounting and Fraud Detection
APPENDIX A:
The probability of fraud, theft or embezzlement in any work
environment is a product of the personality of the executive and
employees, the working conditions, the controls and the level of
honesty therein
Internal Factors that reduce the probability of fraud, theft and
embezzlement include:
I. Prevention measures
A. Internal accounting controls
1. Separation of duties
2. Rotation of duties
3. Periodic internal audits and surprise inspections
4. Development and documentation of
policies,
procedures, systems, programmes and programme
modifications
B. Computer access control
1. Identification defences
2. Authentication defences
3. Establishment of authorisation by levels of
security
II. Detection measures
A. Logging of exceptions
1. Out of sequence, out of priority and aborted runs and
entries
2. Transactions that are too high, too low, too many, too
unusual (odd times, odd places, odd people)
3. Attempted access beyond authorisation level
4. Repeated improper attempts to gain access (wrong
identification, wrong password)
B. Variance reporting
1. Monitoring operational performance levels for
APPENDICES 129
a) Variations from plans and standards
b) D eviations from accepted or mandated
policies, procedures and practices
c) Deviations from past quantitative relationships,
for
example, industry trends, past performance levels,
normal profit and loss (P&L) and balance sheet ratios
C. Intelligence gathering
Monitoring employee attitudes, values, and job satisfaction
levels
Soliciting feed back from customers, vendors and suppliers for
evidence of employee dissatisfaction, inefficiency,
inconsistency of policies,corruption or dishonesty
APPENDIX B
Internal factors that enhance the probability of fraud, theft and
embezzlement include:
Inadequate rewards
Pay, fringe benefits, recognition, job security, job
responsibilities
II. Inadequate management controls
A. Failure to articulate and communicate minimum
standards of performance and personal conduct
B. Ambiguity in job rules, duties, responsibilities and
areas of accountability
III. Lack of inadequate reinforcement and performance
feedback mechanisms
A. Failure to counsel and take administrative action when
performance levels or personal behaviour falls below
acceptable standards
IV. Inadequate support
A. Lack of adequate resources to meet mandated
standards
V. Inadequate operational reviews
130 Forensic Accounting and Fraud Detection
A. Lack of timely or periodic audits, inspections, and
followthrough to ensure compliance with company
goals, priorities, policies, procedures and
governmental regulations
VI. Lax enforcement of disciplinary rules
A. Ambiguous corporate social values and ethical norms
VII. Fostering hostility
A. P romoting or permitting destructive interpersonal or
interdepartmental competitiveness
VIII. Other motivational issues
A. Inadequate orientation and training on legal, ethical
and security issues.
B. Inadequate company policies with respect to
sanctions for legal, ethical and security breaches
C. Failure to monitor and enforce policies on honesty,
loyalty and fairness
D. General job-related stress or anxiety.
APPENDIX C
A SAMPLE REPORT ON AN INVESTIGATION INTO
ALLEGATIONS OF MISMANAGEMENT BY A WORKS
MANAGER INVOLVING VENDOR CORRUPTION AND
MANIPULATION OF FUNDS.
Executive Summary:
1. Objective:
The objective of the investigation was to determine whether the
allegations made against Mr. xxxx in the various letters
addressed to the company were true or false and, whether we
could collect evidence which would support our findings. The
letters containing allegations that were brought to our notice had
the following allegations:
1. Bribery and corruption allegations made by Abhay
Construction in 1998 in writing
2. Inflation of costs in warehouse construction project
APPENDICES 131
3. Close nexus between the subject and certain vendors
apparent on account of favours in rates, business volumes,
and payments
4. Suppression of income from gate sales
5. Close ties and arrangements with the canteen contractor/bus
contractor
6. Surreptitious payments to union leaders
7. Inflated Horticulture expenses
2. Conclusion and Findings:
Several allegations against the subject appear to have merit.
In order to be fair to the accused the report divides all these
allegations into the following four categories:
Those which are supported by direct evidence
Those which are supported by inference or circumstantial
evidence
Those which are supported by verbal submissions
Those which are not supported
2.1 Those which are supported by direct evidence:
2.1.1. Bribery and corruption allegations made by Abhay
Construction in 1998 in writing. A detailed statement from the
vendor has been obtained which explains the modus operandi of
vendor appointments. The procedure required paying a bribe to
Mr xxxx, , at a specified hotel at a pre determined date and time
where the purchase order would be handed over. There was
similar price payable for getting the cheque later for the material
supplied. The vendor was continuously harassed. With the help
of the vendor a sting operation was set up where in the junior
officer was seen taking a bribe on 12 September 2001 at Marina
Hotel, Trscal room, at 4.15 pm and handing over a cheque of Rs
4,54,000 to Pradeep Construction.. A video recording and an
audio recording is available with us. A confession in writing from
Mr xxxx has been furnished, copy of which is annexed in Docket
A.
2.1.2 Inflated costs in waterproofing of warehouse etc. through
PCC Co and Inns (same owner Mr. Bhatti). We have
132 Forensic Accounting and Fraud Detection
documentary evidence of inflated measurements stated in a bill
from Inns. This has been referred to in one of the objection
memos of the site engineer, Mr. R K Y. Significantly, this
measurement sheet (series 4211), was not available at the
factory. We have obtained this document from inquiries and
investigation made on our own. The measurement sheet proves
that there was indeed inflation in the measurement from 5574 sq.
metres to 7100 square metres and thereby an excess payment
was made.
Those which are strongly supported by circumstantial evidence
Unhealthy practices of corruption with other vendors.
The fact that there was this series 4211 of a measurement sheet,
implies that there could be other measurement sheets as well.
Other projects regarding boundary wall construction,
administration building would all have similar measurement
sheets. Therefore the other measurement sheets must be either
destroyed, missing or concealed. Unfortunately we could lay our
hands only on the one relating to INNs. The allegation is further
supported by other circumstantial evidence which infers that Mr
xxx had close links with several other vendors.
1. Poor credentials of the vendors to whom various job were
entrusted,
2. Revealing photographs of the office at the address stated on
the bills. This party ABC is supposed to have cranes,
equipment and a 3000 square feet office to whom business
worth Rs 2.3 crores has been given in 2000-2001 for
construction and crane hire charges. It is obvious that the
place has een unused for a long time. There is no name plate,
nor even a single office attendant, nor a post box nor any
evidence to indicate that a construction company ever existed
there. Neighbouring residents, (for which audio recordings are
available) also did not know of such a company and have
informed us that the office was locked for the past few years.
3. Further circumstantial evidence is in the form of 13 unsigned
bills paid by the plant, existence of a bill on a different
letterhead from the same party.
APPENDICES 133
4. Advance payments digressing from conventional practice of
paying only 20 % upfront.
All these facts collectively infer that these parties were either
dummy parties providing just a front for billing purposes and the
actual work was done by some one else. The fact that these
parties are fictitious is established and all these parties entered
the company only during the tenure of Mr xxxx. Since all powers
of introducing and approving rested with him and since there is
other direct evidence also against him, these circumstantial
factors seem to provide additional evidence against him in
support of allegations relating to unhealthy links with vendors.
2.2.1. Close nexus between the subject and certain job
workers viz. Alkali Thermoformers Limited (ATL) and Evergreen
Moulders Limited (EML) by way of favours in rates, business
volumes, and payments. (Dockets C and D). In particular we
wish to draw attention to:
Credit of Rs 50 lacs to EML for almost two years for sale of
scrap.
Mould repairs of Rs.4.7 lacs which seem to be unreasonable
and credited to EML almost four years later under dubious
circumstances.
Unexplained methodology of costing of components
processed by EML and ATL, the impact of which may be
detrimental to the company substantially. We also
understand, from verbal submissions, that customized cost
sheets were provided for our audit; and that the original cost
sheets were possibly quite different. Since a response has not
been received to our queries relating to these costs, the onus
of proving the truth and fairness of these customized costs
lies with the subject. Colour cost element in the cost sheet is
worked out in a manner apparently favorable to the party.
The additional burden to EKL on account of this cost
computation, if our contention is correct, could run into lacs of
rupees.
2.2.2. Close nexus between the subject and the new
architect, M/s Artec (Docket A regarding Premier.)
134 Forensic Accounting and Fraud Detection
2.2.3. Favouring M/s Om Construction Ltd. for the warehouse
construction Rs 210 lacs in the bidding and selection
process
(Docket E)
2.2.4. Financial leakage through inflated or double payments,
cheque manipulations and other accounting manipulations
(Docket F)
2.2.5. Loose monitoring of scrap sales by permitting
dispatch of material without insisting upon timely or
advance payments, depositing cheques late etc.
2.3 Those allegations which are supported by verbal
submissions
2.3.1 Gate Sales : Misuse of companys policies of selling B
grade refrigerators to employees, and free sales to statutory
authorities
2.3.2 Autocratic method of dealing with people and
employees. Abuse of authority and power.
2.4 Those allegations which have not been examined, or, for
which there is no documentary evidence
2.4.1. Close ties and arrangements with the canteen
contractor/ bus contractor
2.4.2. Unfair suspension of workers and termination of
employment of certain workers on alleged charges
2.4.3. Payments to union leaders
2.4.4. Horticulture expenses
3. Other issues affecting allegations:
This report also furnishes other findings, which may support the
allegations indirectly, and which in our opinion cannot be
altogether overlooked by the company.
4. Significant data missing.
Missing records are to be expected in every organisation, but
some of the records that are missing here are significant in the
light of the allegations against the subject.
4.1 The subjects own personal (HR) file. Possibly, there
could be some evidence of relationships with any of the
APPENDICES 135
vendors or some reference from the earlier employers
or some other information which might be adverse to
him in the current scenario when an inquiry is in
progress. Ordinarily, a missing record can be replicated
or information can be provided from alternative
sources. However the subject has made no effort
inspite of requests from us, the HR head and perhaps
other senior executives in the company as well.
Similarly, details of telephone bills only of the subject
were missing.
4.2 Mr. R K Yadavs personal (HR) file. Significant because
the site engineers objection memos feature in the
allegation letters. All his objections had been overruled
and huge payments had been cleared to tainted
vendors such as Premier Construction, and
Innovations. He was dismissed on being accused of
having accepted a bribe. Strangely, his resignation
letter that admits accepting a bribe, has been
preserved, but his entire H R file is missing.
4.3 Mr. R K Yadavs boss, Anil Apurvas resignation letter
is missing but his file is available. This is astonishing
because we understand from Anik Raja that three
copies had been given and all three copies are
missing. Strangely, the subject has preserved certain
letters of Anik Raja complaining to the management
about Mr. R K Yadavs inefficiency. (Anik Raja has
since admitted to us that those letters were given under
pressure from the subject). It is possible that some bills
may have been passed after Anil Apurvas departure,
using his approval, and therefore the resignation letters
have been removed.
4.4 Documents and vouchers which are missing are
related to some kind of financial damage to the
company:
4.4.1 Credits given to EML
In April 2001, for Rs 10.68 lacs relating
to missing vouchers of
136 Forensic Accounting and Fraud Detection
FY 1996-97
O riginal debit notes are missing for
credit worth Rs. 4.70 lacs given for
mould repairs. Therefore if they have
also been paid some separately in some
other financial year, to EML, we do not
know.
4.4.2 Write offs of non moving suppliers and
creditors running well over Rs.66 lacs in the
past three years, are not supported
by notes, correspondence or any other documentary trail
to satisfy us that these were genuine and essential
4.4.3 A large number of vouchers and
documents (which are photocopies, where
the original documents are missing) gives
us considerable discomfort.
5. Relatives and other employees who have a close
relationship with the subject.
The report also furnishes a list of other close employees who are
suspect and need to be relocated or kept under close scrutiny.
The subject has also manned his relatives in important
departments such as quality assurance. The relatives have not
disclosed their relationship in the application form for employment
with the company. Even these employees need to be similarly
kept under scrutiny or relocated. [As per information available
with us, Mr. Pajeet Gupta is Mr. xxxxs nephew (son of his wifes
sister Kamla , whose house we visited). The application form
submitted by Rajeev Gupta does not disclose his relationship
with Mr. xxxx even though it is so required to be disclosed.
Moreover the increment letter issued by Mr. xxxxalso proves that
he was aware of Rajeevs appointment and he should have
disclosed this. We have been told that there are 3 other relatives,
(1) kailash Gupta, (2) Ram Vilas Gupta and (3) Mohian Goel]
6. Constraints:
The investigation was to be done under the guise of internal audit
covertly. Therefore we had to depend upon the documents,
APPENDICES 137
papers, details and information given to us. Possibilities of
suppression, concealment, destruction or removal of data and
other evidence are quite high. We have also noted missing files,
papers, records, documents which are significant. Lastly, the
subject was given an opportunity to respond to our queries,
doubts and observations based on the allegations made and
appropriate checks applied by us. Sufficient time has been given
to him to respond to them and the importance of giving a
response has been emphatically communicated by the CEO of
the company as well.
The fact that we have not received a response is itself a
major form of evidence as to the possible truth of various
allegations against him.
138 Forensic Accounting and Fraud Detection
APPENDIX D
MODEL DOCKET PREPARED FOR A CONFRONTATION
INTERVIEW
CDIMS
MR.X, DRILLING SUPERINTENDENT
Contents
1. Employee Details
2. Role And Relevance In The Current Investigation
3. Objectives Of The Interview
4. Act(S) Of Default / Non-Compliance(S)
5. Interview Level - 1 (Collection Of Information)
6. Interview Level - 2 (Confrontation Of Evidence)
Exhibits
1. EMPLOYEE DETAILS
Docket No. 01 (One)
Name of The Employee Mr. X
Employee Code (If Any) A-1254
Located At Vishakhapatnam
Designation Drilling Superintendent
Reporting To Mr. A
Reported By Mr.Y (Drilling Op. Advisor)
Date Of Joining 12.05.84
No. Of Years In Service 17
Level(S) Of Authority
APPENDICES 139
A. GENERAL INFORMATION :
QUESTION Y/N REMARK
2. Work Experience
D id you have any previous work experience for the
post applied? If yes, where.
3. Daily Operations
E xplain in brief what is the nature of work done by
you. A detailed note may be given to us.
W hat were the actual documents / registers required
to be maintained by you?
W hat were the various documents required to be
authorized by you?
What was your level of authority?
O n what basis (documents) you used to sign as
Approval Signature? Please give detailed explanation.
D o you receive a copy of the PO before the work has
to be commenced? Or do you rely on the copy
enclosed along with the bill/invoice?
6. General:
W hether you have cordial relations with all superiors
and colleagues?
Did you come on holidays often or rarely?
D o you have any grievance against any of your
seniors / colleagues?
B. SPECIFIC INFORMATION :
QUESTION Y/N REMARK
APPENDIX E
MS Excel - a CAAT
MS Excel software needs no introduction; its a simple application
which most of us use every day -time-in and out. The versatile
spreadsheet is available almost on all machines and seldomly
one will find an accountant / auditor not using it. While mostly it is
popular for making statements, charts, etc., it can conveniently
be also used as CAAT. This article is to facilitate to make best
use of whatever little is known by user about MSExcel.
Some of the important MSExcel-functions that are useful as
CAAT for audit / investigation are described below.
IF
IF in combination with AND
IF in Combination with AND & OR
CountIF and SUMIF
SUMIFS
VLOOKUP
Pivot Table Function
Formula Auditing
Note : The above list is not exhaustive but is only an illustrative
one. There are many other useful functions and the users may
develop skills once he/she starts practicing them. Also it needs to
be noted that there are several ways in MS Excel to achieve the
same results; therefore this article attempts to only explain a few
of them.
The above functions are explained in detail with its corresponding
application in audit / fraud investigations.
The IF Function
The IF Function along with its derivative usage with AND / OR
can be useful for:
Detecting Gaps
APPENDICES 147
Finding Duplicates
Locating Multiple Records
Flagging Records
Ageing Analysis or Advance Analysis
Extracting Records meeting certain criteria (Combination with
filter commands or with Pivot Table commands)
Example of IF Function :
The given data is list of cheques issued and the objective is to
determine gaps of missing cheque numbers.
148 Forensic Accounting and Fraud Detection
For complex operations, another IF function can be used within
an IF function. This is known as Nested-IF function which is
explained as follows :
The Nested IF functions - that is using IF within IF Function.
Here we use multiple tests (queries/ questions) in serial order and
depending upon the response of preceding test another logical
test follows. The nested-IF function can be explained as follows:
Syntax of Nested IF
= IF (Test1,
if true IF [Test2, if true,if false], if
false IF [Test 3, if true, if false] )
There can be maximum of 64 nested IFs
On filtering the Dbl Pymnt records, we are able to get all the
bills that are paid more than once.
Example of VLOOKUP
Given two databases (i) data of sales (marked with green frame)
and (ii) data of standard rate card prices (marked with yellow
frame). In practice usually the databases are in different
worksheets or workbooks, but here it is shown in same
worksheet for easy understanding. However the principle is
same. The objective is to check whether the correct rates are
invoiced to the customer. Using VLOOKUP function, the rates (in
Col.D) of rate card (B23:D36) is extracted in Col- Q. The formula
156 Forensic Accounting and Fraud Detection
is explained in figure below. The difference between rates
invoiced (Col.M) and rates chargeable (Col-Q extracted as
aforesaid) can be compared.
The Col-R can be filtered for non-zero to list the differences which
is list where the rates are charged higher or lower for further
investigation.
Formula Auditing
Very often some excel sheets are very complicatedly built-up --
there are many variables spread across multiple sheets and
complex formulae make it difficult to audit. Most often such
sheets are verified based on rebuild-and-compare method. This
can sometime take enormous effort and hence may not be viable.
This is where the Formula Auditing options come handy.
APPENDICES 159
This is an in-built tool in MSExcel to quickly spot errors /
omissions by locating inconsistencies in data having regard to
surrounding region. A check run is conducted for:
Cell containing formula that result in error
Inconsistent calculated column in tables
Cell containing years represented as two digits Numbers
formatted as text
Formulae inconsistent with other formulae in the region
Formulae which omitted cells in a region
Unlock cells containing formulae
Formulae referring to empty cells
Data entered in a table is invalid
Also one can use the green-corner sign (see adjacent screen
shot) to spot errors. This is similar to the error checking. In
error checking explanation is given, while in green-corner is
just flagged (this is like the red line shown from wrong
spelling in word file). This can be done by enabling the
configuration settings in the as shown below.