kpmg
The Fourth Asian Roundtable on Corporate Governance
Shareholder Rights and the Equitable Treatment of Shareholders
Deepankar Sanwalka
KPMG
“Tools and Rules to Combat
Fraud”
Mumbai, India
11-12 November 2002
The views expressed in this paper are those of the author and do not necessarily represent the
opinions of the OECD or its Member countries, the ADB or the World Bank
kpmg
Contents
Fraud
Combating Fraud
Internal controls
Fraud diagnostic review
Fraud control planning
Keys to preventing fraud
kpmg
What is Fraud?
“A practically conclusive test as to the fraudulent
character of a deception for criminal purposes is this:
Did the author of the deceit derive any advantage from
it which he could not have had if the truth had been
known?”
-Stephen’s “History of the Criminal Law of England”
kpmg
isadeliberatedeceitwhichisplannedandexecuted
todepriveanindividualofproperty,moneyorany
othervaluablesecurity.Fraudmustbecommitted
with intentand includesactionsof
misrepresentationsand/oractsofomission
Fraud
kpmg
Combating Fraud
Controls structure to minimise fraud risk
Fraud riskmanagement
Identification of red flags
Disaster recovery plans
Managing the risk of fraud is essentially no different to
managing any other type of business risk
kpmg
Internal Control
An effective control system within the organisation is the
first deterrent to the occurrence of Fraud within the
organisation
Key principles:
Segregation of duties
Transparency in operations
Appropriate authosrisation procedures
Effective management supervision procedures
Safeguarding of Assets
kpmg
Fraud risk management
Principles of fraud risk management
Risk Assessment
Fraud control planning
Awareness training
Open channels of communication
kpmg
Diagnostic Review
Identify the specific andinherent fraud risks
Determine the overallrisk rating for each
inherent risk
Assess the effectivenessof internal controls
Develop measuresto counter the risk
Risk is an integral part of business. But how do you
effectively manage the risk of loss due to fraud?
kpmg
Fraud control planning
Definition of
Fraud / Statement
of attitude
FRAUD
CONTROL
PLAN
Reporting
protocols
Fraud prevention/
Internal control
training
Fraud Control
Responsibilities
Fraud risk
assessment
Internal audit
strategy
Documented
policy
and procedures
Pro-active fraud
detection by line
management
kpmg
Red Flags
Classification
Financial
Documents
Lifestyle &
Personality
Organisational
Structure
Accountability
and Controls
Ineffective/no
communication
channels
Inadequate
authorisation
procedures
Weak internal
controls
Tendency
towards crisis
management
Missing
documents/
alterations
Excessive
number of void
documents
No numerical
controls
Questionable
handwriting/
authorisation
Unusual billing
address/
arrangements
Lack of
separation of
duties
Lack of
physical
security and/
or key control
Weak links in
chain of
controls and
accountability
Missing
independent
checks on
performance
Dissatisfied
worker
No vacations
or sick time
off
Close
customer/
vendor
relationships
Excessive
overtime
kpmg
You’ve Been Defrauded!
Ten Steps to Consider
1.Shut the door
2.Safeguard the evidence
3.Notify your insurer
4.Do not confront a suspect without consulting an advisor who
has fraud investigation experience
5.Decide on your objectives
6.If you are considering prosecution, contact the police
7.Consider suspending the suspect employee
8.Determine whether external or internal resources will be used
to investigate the fraud
9.Determine who should be interviewed
10.Consider prevention measures to prevent future occurrences