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Anti-Fraud Controls at Small Businesses
                 The limited financial and human resources at most small organizations make them uniquely susceptible to fraud;
                 they often lack the means to enact sophisticated anti-fraud controls, and they can be particularly devastated by
                 the fallout from any fraud that does occur. As noted in Figure 20 on page 25, the median loss per fraud scheme at
                 small businesses is $154,000 — an amount that represents a significant portion of many small businesses’ budgets.
                 In Figure 27, we compared the frequency of anti-fraud controls at entities with fewer than 100 employees to the
                 frequency of those controls at their larger counterparts. Across the board, the larger organizations had a substan-
                 tially greater implementation rate than did the small businesses. Although some of the controls analyzed require a
                 significant investment and likely are not feasible for many small businesses to implement, many of the controls —
                 such as a code of conduct, an anti-fraud policy, management review procedures and anti-fraud training programs
                 — can be enacted with relatively little cost and could greatly enhance small businesses’ ability to protect their
                 resources from fraud.



                  Figure 27: Frequency of Anti-Fraud Controls by Size of Victim Organization


                              External Audit of F/S                    55.6%             91.5%
                                 Code of Conduct                   48.0%
                                                                                       88.2%
                           Internal Audit Department       29.9%                       86.7%
                       Management Certification of F/S          41.3%
                                                                                    80.7%
                            External Audit of ICOFR         33.6%
                                                                                  77.6%
                        Independent Audit Committee      26.7%
                                                                                 75.8%
                              Management Review              33.6%              73.8%

                                       Hotline       18.4% 24.7%             67.8%
                   ANTI-FRAUD CONTROL  Fraud Training for Employees  21.8%  57.7% 62.4%
                         Employee Support Programs
                                Fraud Training for
                             Managers/Executives
                                                                        58.0%
                                                       21.8%
                                Anti-Fraud Policy
                         Dedicated Fraud Department,  11.7%  18.5%     55.6%
                                Function or Team                    48.3%
                     Proactive Data Monitoring/Analysis  15.8%
                                                                41.9%
                       Formal Fraud Risk Assessments  10.8%
                                                                41.6%
                                 Surprise Audits    16.4%      39.6%                             <100
                      Job Rotation/Mandatory Vacation  9.6%  23.9%                               Employees

                         Rewards for Whistleblowers  4.6%  12.6%                                 100+
                                                                                                 Employees
                                           0%       20%       40%       60%       80%      100%
                                                              PERCENT OF CASES









       32           REPORT TO THE NATIONS ON OCCUPATIONAL FRAUD AND ABUSE
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