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More About This Title Internal Control/Anti-Fraud Program Design for theSmall Business: A Guide for Companies NOT Subject to the Sarbanes-Oxley Act
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Internal Control/Anti-Fraud Program Design for the Small Business is a practical guide to protection for businesses NOT subject to the Sarbanes-Oxley Act. Written by an expert with three decades of forensic investigation experience, this book is geared specifically toward private, non-public small businesses and their unique needs in the realm of fraud protection. Covering all elements of an internal control structure applicable to the small business community, this guide provides a step-by-step roadmap for designing and implementing an effective, efficient internal control structure/anti-fraud program tailored to your business's particular needs. Case studies are used throughout to illustrate internal control weaknesses and the fraud that can result, and follow-up analysis describes the controls that would have reduced the probability of fraud had they been in place. You'll learn how to analyze your company's internal control issues, and implement a robust system for fraud prevention.
Guidance toward Sarbanes-Oxley compliance is readily available, but there is little information available for the many businesses not subject to the act —until now. This book is the step-by-step guide for instituting an internal control program tailored to your small business.
- Understand the five elements of internal control
- Avoid gaps in protection with relevant controls
- Design the ultimate anti-fraud program
- Implement internal control tailored to your needs
The majority of small business owners simply do not know the elements of or implementation process involved in internal control, and Sarbanes-Oxley guidelines don't necessarily scale down. Internal Control/Anti-Fraud Program Design for the Small Business helps you design and install the internal control/anti-fraud protection your business needs.
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STEVE DAWSON, CPA,CFE, is president and founder of Dawson Forensic Group, a firm devoted to the investigation of fraud and the education of the small business community in internal control/anti-fraud program design and implementation. For the past thirty years, he has performed forensic investigations and related forensic services for various businesses and agencies. He is a nationally recognized speaker in fraud detection, prevention, and internal control design methodologies. He is a graduate of Texas Tech University with a Bachelor's of Science degree in Accounting and holds a certified public accountant certificate in Texas as well as a certificate as a certified fraud examiner.
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Preface: Maybe It’s Time We Get Back to the Basics xi
Acknowledgments xvii
PART I: THE ANTI‐FRAUD ENVIRONMENT: THE BLUEPRINTS, THE FOUNDATION, THE GROUND FLOOR
Chapter 1: The Architect’s Blueprint: Establishing the Framework 3
The Elements of Anti‐Fraud Program Design 3
Anti‐Fraud Environment 4
Fraud Risk Assessment 4
Control Activities 5
Information: Program Documentation 6
Communication: The Company Fraud Training Program 6
Monitoring and Routine Maintenance 7
Chapter 2: Foundational Policies: The Fraud Policy 9
Foundational Policies 10
The Fraud Policy: The Essential Elements of an Effective Fraud Policy 10
Case Presentation 17
Chapter 3: Foundational Policies: The Fraud Reporting Policy 19
The Essential Elements of an Effective Fraud Reporting Policy 20
Chapter 4: Foundational Policies: The Expense Reimbursement Policy 29
Case: “No Questions Asked” 29
Case: “It Will Never Be Missed” 30
Case: Larry the Chief Financial Offi cer 31
The Elements of an Effective Expense Reimbursement Policy 32
Appendix 4A: Expense Report Form 39
Appendix 4B: Supplemental Business Meal and Entertainment Charges Form 40
Chapter 5: The Ground Floor: The Fraud Risk Assessment Process 41
Ground Rules for Fraud Risk Assessment 42
An Example of Risk Assessment 43
Procedural Steps for Performing a Fraud Risk Assessment 44
Cash in Bank 48
Case: The Trail Is Gone 50
Case: Friends in Low Places 51
Asset Misappropriation 52
Corruption 53
Financial Statement Fraud 53
PART II: ANTI‐FRAUD CONTROL ACTIVITIES: RAISING THE WALLS
Chapter 6: Control Activities: The Absolutes 57
Critical Principles of Control Activity Design 57
Foundational Control Activities 59
Case: The Mail Drop in Las Vegas 64
Appendix 6A: Confl ict of Interest Form 67
Appendix 6B: New Vendor Establishment Form 68
Chapter 7: Control Activities: The Segregation of Duties Dilemma 69
But I Only Have Two Employees 69
Prevention versus Detection Controls 70
The Necessary Review Processes 72
Chapter 8: Control Activities: General Processes 75
Two Operational Questions 75
Common Control Activities 81
Case: The Cell Phone Reimbursement 91
Chapter 9: Control Activities: Specific Control Areas 95
Financial Statement Line Item Control Activities 95
PART III: COMPLETING THE ANTI‐FRAUD PROGRAM: THE CEILING, THE ROOF, AND ROUTINE MAINTENANCE
Chapter 10: The Ceiling: Documenting the Anti‐Fraud Program 103
Information 103
Documentation—Keeping It Simple 104
The Elements of High‐Quality Documentation 104
Chapter 11: The Ceiling: The Company Fraud Training Program 111
The Elements of Effective Communication 112
The Company Fraud Training Program 114
Chapter 12: The Roof: Monitoring and Routine Maintenance 119
Monitoring and Routine Maintenance Defi ned 120
The Monitoring and Routine Maintenance Structure 120
Chapter 13: The Sample Anti‐Fraud Program 129
Appendix 13A: Fraud Risk Assessment Framework Form 137
Appendix 13B: Control Activities Form 138
Appendix 13C: Documentation of Control Activities 139
Appendix 13D: Compliance Audit Programs and Related Compliance Audit Working Papers 154
Appendix A: The Fraud Policy 171
Appendix B: The Fraud Reporting Policy 175
Appendix C: The Expense Reimbursement Policy 179
Appendix D: Forms 185
About the Author 193
Index 195
