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Anti-Fraud Controls by Region
                 We also examined the frequency with which the 18 anti-fraud controls were implemented based on the region of
                 the victim organizations. This revealed a few interesting regional variations and trends in organizations’ approaches
                 to fighting fraud. For example, internal audit departments tend to be less common in the United States and Canada
                 than in all other regions. In contrast, employee support programs are much more common in the United States
                 and Canada than in all other regions, and the percentage of victim organizations in Eastern Europe and Western/
                 Central Asia that had employee support programs in place was remarkably low. Fewer victim organizations in
                 Western Europe had job rotation and mandatory vacation policies than their counterparts in other regions. In
                 addition, the proportion of victim organizations in Southern Asia that had formal management review processes,
                 surprise audits and management certification of financial statements was notably greater than in other regions, and
                 nearly half the organizations in Sub-Saharan Africa had a dedicated fraud department, function or team.


                  Figure 28: Frequency of Anti-Fraud Controls — United States


                                                Control                                  Percent of Cases
                  Code of Conduct                                                                    72.8%
                  External Audit of Financial Statements                                             72.5%
                  Employee Support Programs                                                          65.6%
                  Management Certification of Financial Statements                                   63.4%
                  External Audit of Internal Controls over Financial Reporting                       59.2%
                  Internal Audit Department                                                          58.8%
                  Management Review                                                                  55.5%
                  Independent Audit Committee                                                        53.3%
                  Hotline                                                                            51.5%
                  Fraud Training for Managers/Executives                                             50.3%
                  Fraud Training for Employees                                                       48.4%
                  Anti-Fraud Policy                                                                  42.0%
                  Proactive Data Monitoring/Analysis                                                 36.1%
                  Dedicated Fraud Department, Function or Team                                       34.8%
                  Formal Fraud Risk Assessments                                                      34.5%
                  Surprise Audits                                                                    28.7%
                  Job Rotation/Mandatory Vacation                                                    17.8%
                  Rewards for Whistleblowers                                                         12.0%































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