RESEARCH PAPER ON ASSET

MISAPPROPRIATION

BY
CA SHIV KUMAR CHOUDHARY
 Presented By CA S.K.Choudhary
ASSET MISAPPROPRIATION

Introduction

The term fraud compromises any willful act deception which causes harm or gain to individual. Fraud has
been existence since introduction commerce in human race. Deception and camouflage are traits which
are god gifted to human beings and to great extend in animals, but human beings are only capable of
financial frauds. According to CPA Australia defines frauds “Fraud is behavior that is deceptive,
dishonest, corrupt or unethical. For fraud to exist there needs to be an offender, a victim and an absence
of control or safeguards.”

As per Duffield & Grabosky explains human physiology in fraud depends on three factors that is
motivation, opportunity and guardianship. Although there are various other reasons such situational or
entertainment or challenge are some other reason for frauds to take place, hence till date behavioral
scientists have been unable to identify a psychological characteristic that serves as a valid and reliable
marker of the propensity of an individual to commit fraud.

Organizations of all types and sizes are exposed to frauds. On a number of occasions over the past few
decades, major public companies have experienced in financial reporting fraud and corrupt practices,
resulting in turmoil in the capital markets, a loss of shareholder value, loss of goodwill, loss of assets, loss
of goods and eventually leading into closer of many supporting business to loss of employment.

Although there are various kinds of frauds according to Association of Certified Fraud Examiners
(ACFE) occupational frauds are classified into three categories which are corruption, fraudulent
statements and asset misappropriation.

Assets Misappropriation has received great attention from various stakeholders such regulatory body,
government, investors, public, media, corporates and financial committees. In India in past decade we
have come across various scandals and frauds on assets misappropriation, corruptions, fraudulent
financial statements incases India such as 2G Scam, Coalgate, Shardha Scam, Kingfisher Airlines,
Satyam Computers, MCX Commodities, Harsad Mehta etc.

Across the globe we have come across frauds by Enron, World Com, HIH Insurance, Baring Corporation,
Leheman Brothers & Maddoff scandal.

Frauds have great deep impact on all business and its stakeholders. Frauds have cascading impacts on
regulators, rules, economic, business, markets and public at large. Across the globe new rules and laws
have been introduced when frauds are detected. People who commit frauds are driven by greedy and
supremacy and often forget to differentiate between their smartness, talent compared to deception.
To understand ASSET MISAPPROPRIATION, first we need to understand FRAUD, FRAUD
TRIANGLE and FRAUD TREE

FRAUD

Fraud is a type of criminal activity, defined as:

'Abuse of position, or false representation, or prejudicing someone's rights for personal gain'.

Under common law, four general elements must be present for a fraud to exist:

1. A material false statement

2. Knowledge that the statement was false when it was uttered
3. Reliance of the victim on the false statement
4. Damages resulting from the victim’s reliance on the false statement

FRAUD TRIANGLE

The fraud triangle, developed by Donald Cressey, is a model for explaining the factors that cause
someone to commit occupational fraud. The Fraud triangle is a framework designed to explain the
reasoning behind a worker’s decision to commit workplace fraud. In order for fraud to occur, all three
elements have to be present:

Opportunity

Pressure Rationalization

The Opportunity to commit fraud: In this stage the worker sees a clear course of action by which they can
abuse their position to solve the perceived unshareable financial problem in a way that – again, perceived
by them – is unlikely to be discovered.
The pressure on individual:  Is the motivation behind the crime and can be either personal financial
pressure, such as debt problems, or workplace debt problems, such as a shortfall in revenue.

Rationalize: This is a cognitive stage and requires the fraudster to be able to justify the crime in a way
that is acceptable to his or her internal moral compass.

FRAUD TREE
ACFE has defined Occupational Fraud under three branches:

Corruption Asset Misappropriation Financial Statement Fraud

The Certified Fraud Examiners have divided the corruption section of the fraud tree into four parts:

A. CORRUPTION

B. FINANCIAL STATEMENTS FRAUDS

Financial Statement can be divided into two parts:

 C. ASSET MISSAPROPRIATION

Asset misappropriation occurs when employee steals company’s cash or non-cash assets for the
employee’s own personal use. According to Majid (2010), the definition of asset misappropriation is
broader than simple theft as it also includes abuse of assets. When employee of any level from CEO to
daily hired contractor access company assets for personal or misuse company’s any kind of assets or
resources. Assets of the company include everything from office stationary, office furniture to expensive
items in inventory being used for non-company use. Use of company car, laptops, phones for personal use
or making company pay for services which are personal in nature.

Asset Misappropriation occurs in relative small and immaterial amounts which makes it difficult to detect
but is often accompanied by falsification of documents and behavior of perpetrators. Usually Asset
misappropriation is more concealed and difficult to detect when is involves management due to their
position or power. It is simple theft or minor misuse but often perpetrator to conceal them leads them in to
greater financial fraud or fraudulent financial statements or corruption. (Soltani,2007; Elder et al., 2010;
Jones, 2011)
According to CPA, Australia some of the most common examples of employee fraud include:

 Accepting gifts, favors, kickbacks and bribes from suppliers or contractors

 Staff providing services to the business at clients at cheap or lower rates
 Inflated/bogus reimbursement claims
 Manipulation of performance to receive performance based bonuses
 Faking time sheets& attendance records
 Claiming false sick leaves
 Private personal expenses through business accounts/business credit cards
 Providing discounted or free goods or services to friends and associates.

As per research undertaken by Association of Certified Fraud Examiners (ACFE), 2014 most common
among all the frauds is asset misappropriation which comprised of 85% of total frauds reported in year
2014 but which is least costly and where as 9% are frauds are of financial statements but has greatest
financial losses . The analysis of KPMG in 2013 has shown that 46% of economic crime is under asset
misappropriation schemes whereby corruption cases are reported at 31% and financial statement crimes at
13%. AssetsMisappropriation has least median losses when compared with losses caused by fraudulent
financial statements and corruption. As per ACFE Fraud Tree Asset misappropriation can be further
classified into various categories such as (1) Cash (2) Inventory & All other Assets.

Asset Misappropriation
I) CASH: Cash is the focal point of most accounting entries. Cash, both on deposit in banks and on
hand as petty cash, can be misappropriated through many different schemes. These schemes can be either
on-book or off-book, depending on where they occur.

Cash receipts schemes fall into two categories, skimming and larceny. The difference in the two types of
fraud depends completely on when the cash is stolen. Cash larceny is the theft of money that has already
appeared on a victim organisation’s books, while skimming is the theft of cash that has not yet been
recorded in the accounting system. The way in which an employee extracts the cash may be exactly the
same for a cash larceny or skimming scheme.

Skimming: Skimming is the removal of cash from a victim entity prior to its entry in an accounting
system. Employees who skim from their companies steal sales or receivables before they are recorded in
the company books. Skimming schemes are known as “off-book” frauds, meaning money is stolen before
it is recorded in the victim organisation’s accounts. This aspect of skimming schemes means they leave
no direct audit trail. Because the stolen funds are never recorded, the victim organisation may not be
aware that the cash was ever received. Consequently, it may be very difficult to detect that the money has
been stolen. This is the prime advantage of a skimming scheme to the fraudster.

Sales Skimming

The most basic skimming scheme occurs when an employee sells goods or services to a customer,
collects the customer’s payment, but makes no record of the sale. The employee simply pockets the
money received from the customer instead of turning it over to his employer. In Government
Departments, sales may refer to fees and other collections from customers and clients charged by the
Department for services provided:
This can be of two types:
1. Unrecorded Sales
2. Understated Sales

Unrecorded Sales: The Unrecorded Sales can be of the following types:

a) Register Manipulation: Some employees might ring a “no sale” or other non-cash transaction to
mask the theft of sales. The false transaction is entered on the register so that it appears a sale is
being rung up. The perpetrator opens the register drawer and pretends to place the cash he has just
received in the drawer, but in reality he pockets the cash. To the casual observer it looks as
though the sale is being properly recorded.
b) Skimming During Non-business Hours: Another way to skim unrecorded sales is to conduct
sales during non-business hours. For instance, some employees will open stores on weekends or
after hours without the knowledge of the owners. They can pocket the proceeds of all sales made
during these times because the owners have no idea that their stores are even open for business.
c) Skimming of Off-Site Sales: Several industries rely on remote salespersons to generate revenue.
The fact that these employees are largely unsupervised puts them in a good position to skim
revenues.
d) Poor Collection Procedures: Poor collection and recording procedures can make it easy for an
employee to skim sales or receivables.

Understated Sales: Understated sales work differently because the transaction in question is posted to
the books, but for a lower amount than what the perpetrator actually collected. One way employees
commit understated sales schemes is by altering receipts or preparing false receipts that misstate the
amount of sales or by giving false discount to the customers. In a false discount skimming scheme, an
employee accepts full payment for an item, but records the transaction as if the customer had been given a
discount.

Skimming Receivables: It is generally more difficult to conceal the skimming of receivables than the
skimming of sales because receivables payments are expected. The victim organisation knows the
customer owes money and it is waiting for the payment to arrive. When unrecorded sales are skimmed, it
is as though the sale never existed. But when receivables are skimmed, the absence of the payment
appears on the books as a delinquent account. In order to conceal a skimmed receivable, a perpetrator
must somehow account for the payment that was due to the company but never received.

This can be of three types:

1. Writing Off
2. Lapping Schemes
 3. Unconcealed

1. Writing off account balances: Some employees cover their skimming by posting entries to
contra revenue accounts such as “discounts and allowances.” If, for instance, an employee
intercepts Rs.10000 payment, he would create Rs.10000 “discount” on the account to compensate
for the missing money. Another account that might be used in this type of concealment is the bad
debts expense account.
2. Lapping: Lapping customer payments is one of the most common methods of concealing
receivables skimming. Lapping is the crediting of one account through the abstraction of money
from another account. It is the fraudster’s version of “robbing Peter to pay Paul.”

Fraudulent Disbursements: In fraudulent disbursement schemes, an employee makes a distribution of

company funds for a dishonest purpose. Examples of fraudulent disbursements include forging company
cheques, the submission of false invoices, doctoring timecards, and so forth. On their face, the fraudulent
disbursements do not appear any different from valid disbursements of cash. For instance, when an
employee runs a bogus invoice through the accounts payable system, the victim organisation cuts a
cheque for the bad invoice right along with all the legitimate payments it makes.

Register Disbursement Schemes: Fraudulent disbursements at the cash register are different from the
other schemes that often take place at the register, such as skimming and cash larceny. When cash is
stolen as part of a register disbursement scheme, the removal of the cash is recorded on the register tape.
A false transaction is entered so it appears that the disbursement of money was legitimate. There are two
basic register disbursements schemes: false refunds and false voids.

a) False Refunds: A refund is processed at the register when a customer returns an item of
merchandise that was purchased from the store. The transaction that is entered on the register
indicates the merchandise is being replaced in the store’s inventory and the purchase price is
being returned to the customer. In other words, a refund shows cash being disbursed from the
register to the customer.
b) False Voids: Fictitious voids are similar to refund schemes in that they make fraudulent
disbursements from the register appear to be legitimate. When a sale is voided on a register, a
copy of the customer’s receipt is usually attached to a void slip, along with the signature or
initials of a manager indicating that the transaction has been approved

Cheque Tampering Schemes: Cheque tampering is unique among the fraudulent disbursement schemes
because it is the one group in which the perpetrator physically prepares the fraudulent cheque. In most
fraudulent disbursement schemes, the culprit generates a payment to himself by submitting some false
document to the victim organisation such as an invoice or a timecard. The false document represents a
claim for payment and causes the victim organisation to issue a cheque that the perpetrator can convert.
Following are the cheque tampering schemes:

a) Forged Maker Schemes: A forged maker scheme may be defined as a cheque tampering scheme
in which an employee misappropriates a cheque and fraudulently affixes the signature of an
authorised maker thereon.
b) Forged Endorsement Schemes: Forged endorsements are those cheque tampering schemes in
which an employee intercepts a company cheque intended to pay a third party and converts the
cheque by endorsing it in the third party’s name. In some cases the employee also signs his own
name as a second endorser.
c) Altered Payee Scheme: The second type of intercepted cheque scheme is the altered payee
scheme. This is a form of cheque tampering in which an employee intercepts a company cheque
intended for a third party and alters the payee designation so that the cheque can be converted by
the employee or an accomplice. The employee inserts his own name, the name of an accomplice,
or the name of a fictitious entity on the payee line of the cheque. The alteration essentially makes
the cheque payable to the employee (or an accomplice), so there is no need to forge an
endorsement and no need to obtain false identification.
d) Authorised Maker Schemes: The final cheque tampering scheme, the authorised maker scheme,
may be the most difficult to defend against. An authorised maker scheme occurs when an
employee with signature authority on a company account writes fraudulent cheques for his own
benefit and signs his own name as the maker.

Billing Schemes: The asset misappropriation schemes discussed up to this point—skimming, larceny,
register schemes, and cheque tampering—all requires the perpetrator of the scheme to physically take
cash or cheques from his employer. The next three sections will cover a different kind of asset
misappropriation scheme, one which allows the perpetrator to misappropriate company funds without
ever actually handling cash or cheques while at work. These succeed by making a false claim for payment
upon the victim organisation.

a) Shell Company: Shell companies are fictitious entities created for the purpose of committing
fraud. They may be nothing more than a fabricated name and a post office box that an employee
uses to collect disbursements from false billings. However, since the cheques received will be
made out in the name of the shell company, the perpetrator will normally also set up a bank
account in his new company’s name, so he can deposit and cash the fraudulent cheques
b) Invoicing Via Non-accomplice Vendors: Instead of using shell companies in their overbilling
schemes, some employees generate fraudulent disbursements by using the invoices of legitimate
third-party vendors who are not a part of the fraud scheme. In pay-and-return schemes, employees
 intentionally mishandle payments which are owed to legitimate vendors One way to do this is to
purposely double-pay an invoice. For instance, a clerk might intentionally pay an invoice twice, then
call the vendor and request that one of the cheques be returned. The clerk then intercepts the returned
cheque.
c) Personal Purchases on Credit Cards or Other Company Accounts: Instead of running false
invoices through accounts payable, some employees make personal purchases on company credit
cards or on running accounts with vendors. As with invoicing schemes, the key to getting away with a
false credit card purchase is avoiding detection. Unlike invoicing schemes, however, prior approval
for these purchases is not required. An employee with a company credit card can buy an item merely
by signing his name (or forging someone else’s) at the time of purchase. Later review of the credit
card statement, however, may detect the fraudulent purchase. Unfortunately, many high-level
employees approve their own credit card expenses, making it very easy to carry out a purchasing
scheme.

Payroll Fraud Schemes: Payroll schemes are similar to billing schemes. The perpetrators of these frauds
produce false documents, which cause the victim company to unknowingly make a fraudulent
disbursement.. In payroll schemes, the perpetrator typically falsifies a timecard or alters information in
the payroll records. The major difference between payroll schemes and billing schemes is that payroll
frauds involve disbursements to employees rather than to external parties. The most common payroll
frauds are ghost employee schemes, falsified hours and salary schemes, and commission schemes.

a) Ghost Employees: The term ghost employee refers to someone on the payroll who does not
actually work for the victim company. Through the falsification of personnel or payroll records a
fraudster causes paycheques to be generated to a ghost. The fraudster or an accomplice then
converts these paycheques. The ghost employee may be a fictitious person or a real individual
who simply does not work for the victim employer. When the ghost is a real person, it is often a
friend or relative of the perpetrator.

In order for a ghost employee scheme to work, four things must happen:

(1) The ghost must be added to the payroll, (2) timekeeping and wage rate information must be
collected, (3) a paycheque must be issued to the ghost, and (4) the cheque must be delivered to the
perpetrator or an accomplice.

b) Falsified Hours and Salary: The most common method of misappropriating funds from the
payroll is the overpayment of wages. For hourly employees, the size of a paycheque is based on two
factors: the number of hours worked and the rate of pay. It is therefore obvious that for an hourly
employee to fraudulently increase the size of his paycheque, he must either falsify the number of
hours he has worked or change his wage rate. Since salaried employees do not receive compensation
 based on their time at work, in most cases these employees generate fraudulent wages by increasing
their rates of pay.

c) Commission Schemes: Commission is a form of compensation calculated as a percentage of the

amount of transactions a salesperson or other employee generates. It is a unique form of
compensation that is not based on hours worked or a set yearly salary, but rather on an employee’s
revenue output. A commissioned employee’s wages are based on two factors, the amount of sales he
generates and the percentage of those sales he is paid. In other words, there are two ways an
employee on commission can fraudulently increase his pay: (1) falsify the amount of sales made, or
(2) increase his rate of commission

Expense Reimbursement Schemes: Employees can manipulate an organisation’s expense

reimbursement procedures to generate fraudulent disbursements. Expense reimbursements are usually
paid by the company in the following manner. An employee submits a report detailing an expense
incurred for a business purpose, such as a business lunch with a client, airfare, hotel bills associated with
business travel, and so forth. In preparing an expense report, an employee is usually required to explain
the business purpose for the expense, as well as the time, date, and location in which it was incurred.
Support documentation for the expense, typically a receipt, should be attached to the report. In some cases
cancelled cheques written by the employee or copies of a personal credit card statement showing the
expense are allowed in lieu of receipts. The report must usually be authorised by a supervisor in order for
the expense to be reimbursed.

The four most common types of expense reimbursement schemes are:

a) Mischaracterised Expense Reimbursements: Most companies only reimburse certain expenses

of their employees. Which expenses a company will pay for depends to an extent upon policy, but
in general, business-related travel, lodging, and meals are reimbursed. One of the most basic
expense reimbursement schemes is perpetrated by simply requesting reimbursement for a
personal expense by claiming that the expense is business related.
b) Overstated Expense Reimbursements: Instead of seeking reimbursement for personal
expenses, some employees overstate the cost of actual business expenses.
c) Fictitious Expense Reimbursements: Employees sometimes seek reimbursement for wholly
fictitious expenses. Instead of overstating a real business expense or seeking reimbursement for a
personal expense, an employee just invents an expense and requests that it be reimbursed
d) Multiple Reimbursements: The least common of the expense reimbursement schemes is the
multiple reimbursements. This type of fraud involves the submission of a single expense several
times. The most frequent example of a multiple reimbursement scheme is the submission of
several types of support for the same expense.
II) INVENTORY AND OTHER ASSETS: Employees target inventory, equipment, supplies, and
other non-cash assets for theft in a number of ways. These schemes can range from stealing a box of pens
to the theft of millions of dollars worth of company equipment. The term inventory and other assets is
meant to encompass the misappropriation schemes involving any assets held by a company other than
cash.

There are basically two ways a person can misappropriate a company asset. The asset can be misused or it
can be stolen. Simple misuse is obviously the less egregious of the two.

a) Misuse: Assets that are misused but not stolen typically include company vehicles, company
supplies, computers, and other office equipment.
b) Theft of Inventory and Other Assets: While the misuse of company property might be a
problem, the theft of company property is obviously of greater concern. Losses resulting from
larceny of company assets can run into the millions of dollars. Most schemes where inventory
and other non-cash assets are stolen fall into one of four categories: larceny schemes, asset
requisition and transfer schemes, purchasing and receiving schemes, and false shipment schemes.

Larceny: The term larceny is meant to refer to the most basic type of inventory theft, the schemes in
which an employee simply takes inventory from the company premises without attempting to conceal the
theft in the books and records.

a) The False Sale: In many cases, corrupt employees utilise outside accomplices to help steal
inventory. The fake sale is one method that depends upon an accomplice. Like most inventory
thefts, the fake sale is not complicated. The accomplice of the employee-fraudster pretends to buy
merchandise, but the employee does not ring up the sale. The accomplice takes the merchandise
without paying for it. To a casual observer, it will appear that the transaction is a normal sale. The
employee bags the merchandise, and may act as though a transaction is being entered on the
register, but in fact, the “sale” is not recorded. The accomplice may even pass a nominal amount
of money to the employee to complete the illusion. A related scheme occurs when an employee
sells merchandise to an accomplice at an unauthorized discount.

b) Asset Requisitions and Transfers: Asset requisitions and other documents that allow non-cash
assets to be moved from one location in a company to another can be used to facilitate the theft of
those assets. Employees use internal transfer paperwork to gain access to merchandise which they
otherwise might not be able to handle without raising suspicion. These documents do not account
for missing merchandise the way false sales do, but they allow a person to move the assets from
one location to another. In the process of this movement, the thief steals the merchandise.
c) Purchasing and Receiving Schemes: Dishonest employees can also manipulate the purchasing
and receiving functions of a company to facilitate the theft of inventory and other assets. It might
seem that any purchasing scheme should fall under the heading of false billings, which were
discussed earlier. There is, however, a distinction between the purchasing schemes that are
classified as false billings and those that are classified as non-cash misappropriations.

d) Concealing Inventory Shrinkage: When inventory is stolen, the key concealment issue for the
perpetrator is shrinkage. Inventory shrinkage is the unaccounted-for reduction in the company’s
inventory that results from theft. For instance, assume a computer retailer has 1,000 computers in
stock. After work one day, an employee loads ten computers into a truck and takes them home.
Now the company only has 990 computers, but since there is no record that the employee took
ten computers, the inventory records still show 1,000 units on hand. The company has
experienced inventory shrinkage in the amount of 10 computers.

Case Study on Asset Misappropriation

In case of Enron asset misappropriation occurred when top executives were aware of actual financial
position and company shell position. 29 of Enron’s top executives and board members sold 20.7
million of their Enron shares, for a gross proceed of $1.1 billion which works out to be $ 41 million in
pay and bonus among 29 executives. When company was made aware that two of its employees have
over traders and caused millions of dollars’ worth of loss to company and have also diverted funds
into their own account instead of disciplining them Chairman of the Company advise them to
continue business as normal. Further executives and management used company assets for personal
fame. Amongst the most is example was when Enron was about to collapse and CEO Jeff Skilling
was under great stress of keeping all the fraudulent activities away from public, company chairman
Kenneth Lay was busy asking Jeff’s help in selecting the fabric of interior of his corporate jet. Further
executives were very well aware of their fraudulent activities hence they tied up relationships with
politician by giving generous donations from company funds to protect their wrong doing and with
intent to seeking support in judiciary matter. According to McLean and Elkind (2003), “between 1989
and 2001 Enron and its executives contributed nearly $6 million to political parties and candidates.
Further CFO of the company Andy Fastow had interest in various SPE to which various transactions
were entered by Enron skimming company cash.

Tyco arose a corporate scandal. In 2002, CEO Dennis Kozlowski, CFO Mark Swartz, and general
counsel Mark Belnick were 16 charged of fraud and conspiracy. Hundreds of millions of dollars that
they had paid themselves in unauthorized bonuses and compensation since 1992. In total,
approximately $170 million had been taken by the three. Although Tyco did have an employee loan
program in place at the time, these personal loans were never approved and were kept off the
financial statements of the company. Therefore, they were not considered an asset on the company’s
balance sheet. Combined, Kozlowski and Swartz had also sold $430 million worth of company stock
without informing investors. Kozlowski, especially, was known for his lavish lifestyle and habit of
spending corporate funds. He reportedly held a $2 million birthday party in Italy for his wife using
company funds. There were also rumors of a $10,000 shower curtain he had purchased with company
funds.

In case of Berni Madoff report byLauricella (2009), suggest that firms invested investor money to
Madoff Securities, “likely took in at least $790 million in fees over the years On its main Madoff
channel, the Fairfield Sentry fund, the firm for many years took as a management fee 20% of profits
earned by investors. In October 2004, it also began collecting a 1% fee on assets under management”
(Lauricella 2009).

Conclusion

In conclusion, asset misappropriation is a very expensive problem for organizations. Unfortunately,

few organizations proactively address this problem, which creates a reoccurring cycle of theft within
many organizations. By creating a proactive asset misappropriation policy, organizations can
effectively assign responsibility and greatly reduce their susceptibility to these schemes. Asset
misappropriation could provide a fertile area of research for practitioners, academics, governmental
entities, and others. While the last 50 years have greatly enhanced our overall understanding of asset
misappropriation, we still lack knowledge of some of its basic characteristics. Specific areas of
interest include asset misappropriation in international organizations, the effects of culture on this
type of fraud, and proactive detection and prevention procedures. Finally, future research into asset
misappropriation must include longitudinal studies that help us better understand how an
organization’s susceptibility to asset misappropriation schemes varies depending on the state of the
economy, the lifecycle of the organization, the organizational culture, and the organization’s industry.

It is our hope that the next few years will bring greater knowledge and understanding to the problem
of asset misappropriation. As with all types of fraud, education and research is the key to its
deterrence. When the fraud examination community fully understands the nature of asset
misappropriation, we will be able to better design programs, tools, and methods to minimize its
occurrence within organizations.

Reference

HRZONE
http://definitions.uslegal.com/i/illegal-gratuity/

Wikipedia

http://www.competitionbureau.gc.ca/eic/site/cb-bc.nsf/eng/03152.html

Dr. Joseph T. Wells. Corporate Fraud Handbook, Fourth Edition