Fraud Risk Management Program

Developing a Fraud Risk
Management Program
Erick O. Bell
Priyanka Jhang
Deloitte Financial Advisory Services LLP

September 11, 2013
Copyright 2013 Deloitte Development LLC. All rights reserved.
Developing a Fraud Risk Management Program
Agenda
Making the case for a Fraud Risk Management Program

A COSO-consistent Process for Fraud Risk Management
Roles of Key Parties in Managing Fraud Risk
Control Environment and Fraud Risk Assessments
Anti-Fraud Control Activities
Sharing Information and Communication
Monitoring Activities
Making the case for a Fraud

Risk Management Program
Fraud: Defined
Any illegal acts characterized by deceit, concealment, or violation
of trust. These acts are not dependent upon the application of
threat of violence or of physical force. Frauds are perpetuated by
individuals and organizations to obtain money, property, or
services; to avoid payment or loss of services; or to secure personal
or business advantage.
Source: The Institute of Internal Auditors International Standards for the Professional Practice of Internal Auditing
www.the.iia.org
Occupational Fraud: Defined

The use of ones occupation for personal enrichment through the
deliberate misuse or misapplication of the employing
organizations resources or assets.
Source: 2006 Association of Certified Fraud Examiners Report to the Nation on Occupational Fraud & Abuse
Errors Do Not Constitute Fraud
ACFE Fraud Statistics
Losses = 5 percent of revenue

$140,000 per case
18-month duration
Highest impact to small businesses
Higher positions = higher loss
81% of fraudsters displayed one or more
red flags
Living beyond means
Financial difficulties
Unusually close association with vendors or
customers
Excessive control issues
Detection of Fraud
Size of Victim Organizations
Types of Occupational Fraud & Abuse
Percent of cases exceeds 100 percent due to cases spanning several categories.
10
Why Organizations Should Manage Fraud Risk
Duty of care to shareholders/stakeholders

Manage impact of fraud on profitability/available funding
Statutory/regulatory requirements (Sarbanes-Oxley, SEC, FCPA,
Federal Sentencing Guidelines, funding agency requirements)
Employee morale
Stakeholder confidence
11
Statutory and Regulatory Guidance/Requirements for

Fraud Risk Management
SarbanesOxley
Act
Foreign
Corrupt
Practices
Act
IIA
Practice
Advisories
SEC
Enforcement
Policies
Office of
Foreign
Asset
Control
Federal
Sentencing
Guidelines
Criteria
PCAOB
Auditing
Standards
Department
of Justice
Prosecution
Policy
AICPA
IIA/AICPA/ACFE
NYSE / NASDAQ
AICPA
Management
AFPC
Guidance
Managing the
Business Risk of
Fraud
Corporate
Governance Listing
Standards
Management
Override (Achilles
Heel)
12
Reasons Why Entities Need to Manage Fraud Risk
Organizational Benefits
Survival
Greater Profitability
Intact or enhanced image
Improved efficiency & increased ability to meet commitments
Enhanced morale attract/retain talent
Individual Benefits
Morale
Reduced stress
Job satisfaction
Greater employment security
13
Questions
?
A COSO-consistent Process
for Fraud Risk Management
COSO An Overview
The Committee of Sponsoring Organizations of the Treadway
Commission (COSO)
Formed specifically to study the causal factors that can lead to
fraud
Private sector initiative established in 1985 by the following

organizations:
American Accounting Association (AAA)

American Institute of Certified Public Accountants (AICPA)
Financial Executives Institute (FEI)
The Institute of Internal Auditors (IIA)
Institute of Management Accountants (IMA)
16
Internal Control Integrated

Framework (the Framework)
In 1992, COSO issued the Internal Control Integrated Framework
Intended to help businesses and other entities assess and enhance their
internal control systems
Underlying principles provide framework for proactively establishing
an environment to manage fraud risk
17
The COSO Internal Control

Integrated Framework
COSO offers an integrated framework that defines internal
control by five interrelated components:
Objectives
Control Environment
Risk Assessment
Control Activities
Information & Communication
Monitoring
Components
The COSO framework helps

clarify the context of internal
control discussions
18
Recognized as an Internal Control Standard

Organizations are continually being held to increased standards
for internal control
Sarbanes Oxley Act of 2002
PCAOB Auditing Standard No. 5
Federal Sentencing Guidelines
COSO Framework is well known and recognized as authoritative

The COSO Framework has served as the internal control
standard for organizations implementing and evaluating internal
control in compliance with the US Sarbanes-Oxley Act of 2002
(SOX) and the US Public Company Accounting Oversight
Board (PCAOB) Standard[s] 2 [and 5] 1
Recognized by executives, board members, regulators, standard
setters, professional organizations, and others as an appropriate
comprehensive framework for internal control
1
New Guidance for Small Businesses to be Released, July 7, 2006, Institute of Internal Auditors
19
20
The New Internal Control Integrated

Framework
Old framework will be superseded in December 2014
Same 5 components
17 principles
8. The organization considers the potential for fraud in
assessing risks to the achievement of objectives.
21
A COSO-Consistent Approach
Tone at the top
Code of
Conduct/Ethics
Whistleblower
Hotline
ICFR
Creating
a Control
Environment
Performing
Fraud Risk
Assessments
Monitoring
Activities
Identify fraud risk

factors, fraud risks
and fraud
schemes
AFPC
Monitoring
effectiveness
of antifraud
programs and
controls
Sharing
Information and
Communication
Designing and
Implementing
Antifraud
Control
Activities
Link or map
identified fraud
risks to control
activities
Effective
communication of
antifraud programs
and controls
5 Elements Source: Committee of Sponsoring Organizations of the Treadway
Commission, Internal Control Integrated Framework
22
Questions
?
Roles of Key Parties in

Managing Fraud Risk
3: Key Parties Involved with Managing Fraud Risk
Those Charged
with Governance
Board of Directors
Audit Committee
Management
(CEO, CFO, COO, CCO)
Employees
(all levels and functions)
Internal Audit
25
Roles & Responsibilities Board of Directors

Board of Directors
Audit Committee
Management
Employees
Internal Audit
Ensure that management designs effective fraud risk management documentation to encourage
ethical behavior
Understand fraud risks (both generally and those affecting the organization)
Establish and communicate an appropriate level of risk tolerance for the organization
Maintain oversight of the fraud risk assessment
Monitor managements reports on fraud risks, policies, and control activities
Ability to retain outside experts where needed
Assure that external auditors understand the Boards active involvement in fraud risk management
26
Roles & Responsibilities Audit Committee

Board of Directors
Audit Committee
Management
Internal Audit
Employees
Active role in the oversight of the fraud risk assessment

Addressing the risk of management override of controls
Uses internal audit, or other designated personnel, to monitor fraud risks throughout the
organization
Meet separately with appropriate individuals (e.g., internal audit, external auditors)
Maintain awareness of the external auditors responsibilities pertaining to fraud
Seek advice of counsel when dealing with allegations of fraud
Provide specific consideration to reputation risk when reviewing work of management, internal
audit, external auditors
27
Roles & Responsibilities Management

Board of Directors
Audit Committee
Management
Employees
Internal Audit
Design and implementation of a fraud risk management program

Implementing and documenting a fraud risk assessment process
Maintaining adequate documentation of design of antifraud programs and controls
Evaluating design and operating effectiveness of antifraud programs and controls
Reporting to the Board on actions that have been taken to manage fraud risks and the
effectiveness of the fraud risk management program
Educating the organization on areas of potential compliance violations
Enforcing Code of Ethics
28
Roles & Responsibilities Internal Audit

Board of Directors
Audit Committee
Management
Employees
Internal Audit
Provide assurance to the Board and to management that existing controls are appropriate given the
risk tolerance established by the Board
Review the comprehensiveness and adequacy of the risks identified by management, especially
regarding management override risks
Support managements education of the organization regarding areas of potential fraud and
compliance violations
Consider fraud risks when developing annual audit plan and spend time to evaluate the design and
operation of antifraud controls
Support the audit committee in performing detective activities around the risk of management
override of controls
29
Roles & Responsibilities Employees

Board of Directors
Audit Committee
Management
Employees
Internal Audit
Basic understanding of fraud and awareness of red flags

Understand their roles within the internal control framework, specifically how their procedures are
designed to manage fraud risk
Read and understand policies and procedures (e.g., fraud policy, code of conduct, whistleblower
policy)
Participating in the process of creating a strong control environment
Report suspicions or incidences of fraud and corruption
Cooperate with investigations
30
Questions
?
Control Environment and

Fraud Risk Assessments
COSO Overview: Control Environment
Creating a
Control
Environment
Monitoring
Activities
Sharing
Information and
Communication
Performing
Fraud Risk
Assessments
Control Environment
Control consciousness of an organization; it is
the environment in which people conduct
business activities and fulfill their control
obligations.
The control environment includes both
intangible and tangible elements:
Integrity and ethical values
o Incentives
o Communicating moral values
Commitment to competence
Governance and organization structure
Managements philosophy and operating
style
Assignment of authority and responsibility
Human resource policies and practices
Designing and
Implementing
Antifraud
Control
Activities
33
COSO Overview: Control Environment
Creating a
Control
Environment
Monitoring
Activities
Sharing
Information and
Communication
Some of the components of the control

environment in which management may focus
its efforts include:
Performing
Fraud Risk
Assessments
Designing and
Implementing
Antifraud
Control
Activities
34
Audit Committee
Management Accountability
Fraud control policy/strategy
Tone at the Top
Code of Conduct and Ethics
Hiring and Promotion Procedures
Hotlines/helplines
Investigation and corrective action
What is a Fraud Risk Assessment?

Fraud risk assessment is an
integral part of an antifraud
program that is based on the
COSO framework
A crucial part of an entitys
broader risk assessment process, a
fraud risk assessment considers the
ways that fraud and misconduct
can occur by and against the entity
Creating
a Control
Environment
Performing
Fraud Risk
Assessments
Monitoring
Activities
AFPC
Sharing
Information and
Communication
Designing and
Implementing
Antifraud
Control
Activities
Committee of Sponsoring Organizations of the Treadway Commission,

Internal Control Integrated Framework
35
Benefits of A Fraud Risk Assessment

Help in meeting regulatory requirements
Assist in providing structure to tackling the potential of fraud in
a proactive manner
Reduce exposure from fraud risk, with potential impact on
bottom line
Supplement the internal controls environment in helping to
prevent, detect and deter fraud
Help address areas of exposure in an organization where the
internal controls environment may have limitations, such as
collusion
36
Managements Fraud Risk

Assessment Overview
1
Identify fraud risk factors
Schedule of fraud risk factors

Sound knowledge of fraud risk environment
Identify fraud risks

Identify specific fraud schemes
Identify account balances and potential
errors related to each fraud risk
Pervasive & specific fraud risks

Catalog of fraud schemes
Identify & Evaluate Fraud

Risk Factors
Identify Possible Fraud

Schemes & Scenarios
Analyze Fraud Risks &

Evaluate Control Design
& Implementation
Evaluate Fraud Risk

Assessment Results &
Prioritize Residual Fraud
Risks
Output
Approach
Step
Risk Treatment
Analyze the likelihood and significance of

possible fraud schemes
Link fraud schemes to mitigating controls &
evaluate control design and implementation
Inherent Risk Rating (IRR) of entity

Catalog of existing controls
Fraud Control Risk Rating
Fraud Risk Related Control Gap Analysis
Evaluate the results of fraud risk analysis

against established criteria and prioritize
risks for treatment
Residual Risk Rating (RRR)

Identification of fraud risks requiring further
treatment
Fraud risks prioritized
Prepare Fraud Risk Action Plan

Implement Plan
Fraud Risk Action Plan

Fraud Risks Treated
37
Where do Fraud Risk Assessments

Typically Fall Down?
Appropriate personnel are not involved in the process
Assessment consists of an identification of risk factors only, and
does not include an identification of schemes & scenarios
Potential perpetrators are not identified (which can lead to
insufficient consideration of management override)
Does not consider collusive fraud and management override of
controls
Lack of monitoring by the Audit Committee/Board
Lack of follow up after identification of fraud risks and linkage
to mitigating controls
38
Questions
?
Anti-Fraud Control Activities
Design and Implement Control Activities

Management may focus on
several considerations when
designing and implementing
antifraud control activities,
including:
Creating a
Control
Environment
Preventive Controls
Detective Controls
Monitoring
Activities
Management may identify

preventive controls, detective
controls, or a combination of
both, as adequately addressing
financial reporting risks. (SEC
ICFR guidance)
41
Sharing
Information and
Communication
Performing
Fraud Risk
Assessments
Designing and
Implementing
Antifraud
Control
Activities
Antifraud Control Activities

Prevent, Detect, & Deter
Fraud Risk Mitigation

Preventive Controls
Detective Controls
Designed to mitigate the

opportunity for an individual to
perpetrate a fraud
Limited effectiveness when
management may be involved in the
fraud
Serve as a deterrent by creating an
additional obstacle to carrying out a
fraud
Designed to identify indicators of a

fraud, if committed
May be used as a monitoring
activity to assess effectiveness of
other antifraud controls
Serves as a deterrent by heightening
the perceived likelihood of being
caught
Source: Managing the Business Risk of Fraud: A Practical Guide
42
Antifraud Objectives for Control

Activities: Mitigate
Control activities designed to mitigate fraud are not always the
same as the organizations internal control activities designed to
identify errors.
Antifraud control activities represent actions taken by
management to mitigate the specific fraud risks identified in the
risk assessment process.
These are more specialized in both their design and application.
Source: Managing the Business Risk of Fraud: A Practical Guide
43
Risk-Based Approach
Begins with the fraud risk assessment
Design control activities to address most likely & significant
inherent and residual fraud risk
Overall risk tolerance - established by the board of directors or
similar governance
Board should ensure management has implemented the proper
level of controls based upon established risk tolerance level
Controls identified as antifraud controls should be evaluated for
operating effectiveness and executed by competent and
objective individuals
44
Effective Fraud Controls

Fraud risk management often uses two types of controls:
Entity-level controls, such as:
o Tone at the top
o Code of conduct and ethics
o Hiring and promotion procedures
o Whistleblower hotline
Process-level controls, such as:
o Disbursement approvals
o Journal entry approvals
o Management or supervisor reviews
o Computer system access controls
45
Fraud Prevention
Awareness is key to prevention
Policies Corporate governance
Procedures Design of antifraud programs and controls
Training, Communication, and Affirmation
Human Resources may also play an integral role in fraud

prevention
Conducting background investigations

Hiring the competent people
Evaluating performance and compensation programs
Conducting exit interviews
Aligning individual responsibilities with the level of ones

authority
Transaction level procedures (e.g., reviews, financial reporting
and internal control competencies)
Continuous monitoring
46
Characteristics of Fraud Detection

Occurs in the ordinary course of business
Draws on external information to corroborate internally
generated information
Formally and automatically communicates identified deficiencies
and exceptions to appropriate organizational leadership
Uses results to enhance and modify other controls
47
Fraud Detection
Three primary ways fraud is detected:
Anonymous Reporting (Hotline Tip)
o Most likely means of detecting fraud
o Employees should not fear retaliation
Process Related Controls
o Reconciliations/Authorization levels
o Physical counts/Inspections
o Segregation of duties
Internal Auditing
* Appearance of strong detection controls in place can provide most significant
deterrent to fraud.
48
Proactive Fraud Detection

Detective control activities are based on risk assessment and
fraud attributes
Detect anomalies, trends, risk indicators
Continuous auditing (monitoring)
Data analytics
* Appearance of strong detection controls in place can provide most significant deterrent to fraud.
49
Questions
?
Sharing Information and

Communication
Sharing Information and Communication

The manner and frequency with which
management communicates the purpose
and existence of its fraud controls can
greatly impact the effectiveness of those
controls
Creating a
Control
Environment
Monitoring
Activities
Sharing
Information and
Communication
52
Performing
Fraud Risk
Assessments
Designing and
Implementing
Antifraud
Control
Activities

Communication: Objective
As it relates to fraud risk management, what are some key objectives
of sharing information and communication?
Objectives of sharing information and communication:
Convey a clear message about the corporate culture
Set expectations about ethical employee behavior
Remind employees about their roles and responsibilities for
maintaining an ethical work environment
Maintain awareness of reporting mechanisms available to employees
Reinforce the ramifications of improper or unacceptable behavior in
order to deter others from similar actions
53

Communication: Tone at the Top
Management has a responsibility to clearly communicate the tone at
the top
Communication of the tone at the top includes sharing managements
expectations for ethical behavior by all employees
Mechanisms include:
Setting an example (Walking the Talk)

Code of conduct
Intranet site providing information on ethics and AFPC
Broadcast emails and/or voicemails
Corporate newsletters addressing ethics and AFPC
CEO speeches or message on the importance of ethics and integrity
54

Communication: Information Flow
Effective communication must flow top down and bottom up
There should be:
Open channels of communication
A clear-cut willingness to listen
Mechanisms include:
Normal reporting channel
Separate lines of communication (e.g., a channel directly to a senior
officer, chief internal auditor, or legal counsel)
Whistle-blower hotline/ombuds office/ethics office/compliance
office
Broadcast emails/voicemails
Organization wide meetings, newsletters, web cast
Intranet site
55

Communication: External Parties
An organization should maintain open channels of
communication with customers, suppliers, and other external
parties
Mechanisms include:
Providing customers, suppliers, and other external parties with copies
of your ethics guidelines
Providing outside parties with a whistle-blower phone number or
email address to facilitate feedback
Surveying outside parties (customers, vendors) on their perception of
the integrity and ethical values of company personnel by company
personnel independent of the main customer/vendor contact
Meeting with the external auditor or regulator upon the completion of
their examination to discuss findings and propose resolutions
Collaboration between internal audit departments of major customers
and vendors
56

Communication: Training
Management may assess whether its training programs include:
Training for new employees about matters of fraud and the entitys
code of conduct and ethics
Periodic training for existing employees addressing changes in the
business environment
Training that is tailored to the roles and responsibilities of employees
Education about when and how to utilize the whistle-blower system;
encourage proper reporting
57
Sample Email Ethics awareness
Sometimes, it either is, or it isnt.

You either sank the putt, or you didnt. No two ways about
it. And in business, some ethics issues are just like that.
Whats right or wrong is clear, obvious, and unarguable. But
other times, its far less clear. So stay alert. Pay attention to
shades of gray. Tune in to your intuition
If you feel somethings not quite right in an ethical sense,
call a halt to play. Consult with peers and colleagues you
respect. Research the rules
And remember, the Integrity Helpline is always there. You
can ask a question or file a report, via the Web or phone
(888-XXX-XXXX), 24-hours-a-day, every day of the year,
from anywhere in the world
These days, ethics has to be a hole in one. Every time.
For further information about Ethics and Compliance, go
to the Companys intranet site (provide link)
58
Sample Email Ethics awareness
Sometimes, its pretty hard to be uncertain.

You have the winning hand, or you dont. Its very clear to
everyone. In business, some ethics issues can be just like
that. Clear, obvious, and unarguable
But other times, its far less apparent. So stay alert. Pay
attention to shades of gray. Listen to your intuition
And if something feels wrong, dont play your cards too
close to your vest. Stop play. Revisit the rules. Consult with
peers and colleagues whose opinions you respect
If you have questions, the Integrity Helpline is always there.
You can ask a question or file a report, via the Web or phone
(+1 888 XXX XXXX), 24-hours-a-day, every day of the
year, from anywhere in the world
Today, the winning hand in business is doing whats ethically
rightfor our colleagues, our professions and our clients.
For further information about Ethics and Compliance, go
to the Companys intranet site (provide link)
59
Delivering Training Cost Effectively

What are best practices for delivering training cost effectively?
Consider the audience
Consider the mode:
o Lecture
o Text
o Simulation
Consider the medium:
o In person
o Paper based
o Electronic\Web Based
Consider the:
o Timing
o Duration
o Frequency
60
Questions
?
COSO Overview: Monitoring
Creating a
Control
Environment
Monitoring
Activities
Sharing
Information and
Communication
Monitoring
activities support:
Performing
Fraud Risk
Assessments
Ongoing periodic monitoring of AFPCs are
vital to managements ability to react to the
changing business environment and related
impact on fraud risks.
Designing and
Implementing
Antifraud
Control
Activities
Management
Ensures that controls are operating effectively
Those charged
with governance
Provides assurance that management is executing its internal

control responsibilities effectively
63
Creating a
Control
Environment
Monitoring: Two Fundamental

Components
Assess operating
effectiveness
Performing
Fraud Risk
Assessments
Monitoring
Activities
Sharing
Information and
Communication
Designing and
Implementing
Antifraud
Control
Activities
Monitoring should be designed to assess the operating effectiveness of internal

control components
Internal control performance should be assessed over time through ongoing
monitoring of operations and separate periodic evaluations
Scope and frequency of monitoring activities depend on significance of risks
being controlled and the importance of controls in reducing risks
Monitoring activities should be built into normal, recurring operating activities of
an organization
Monitoring activities may include 1:
Controls to monitor results of operations
Controls to monitor other controls, including activities of the internal audit
function, the audit committee, and self-assessment programs
Identify and report

deficiencies
Deficiencies in internal control should be identified and communicated in a

timely fashion to those parties responsible for taking corrective action
Organizations should have:
A defined escalation path for reporting and follow-up
Accountability for corrective action to address the root cause of the control
weakness
SEC 404 Guidance, Commission Guidance Regarding Managements Report on Internal Control Over Financial Reporting Under Section 13(a) or 15(d)
of the Securities and Exchange Act of 1934
64
Creating a
Control
Environment
Examples of Monitoring Activities
Monitoring
Activities
Sharing
Information and
Communication
Periodic Evaluations
Frequent and timely account reconciliations

Compliance testing by internal audit
Confirmation of information with external parties
Periodic confirmation from employees (code of conduct compliance)
Anomaly detection programs
Review of operating units financial reports by higher levels of management
Continuous
Monitoring
Anomaly detection using software (e.g., ACL)

Journal entry testing
65
Performing
Fraud Risk
Assessments
Designing and
Implementing
Antifraud
Control
Activities
Using technology for effective

monitoring
Automated controls can play a significant role in enhancing the
effectiveness, efficiency, and timeliness of monitoring 1
Monitoring tools typically focus on one or more of the
following:
Transaction data
Conditions
Changes
Processing integrity
Error management
COSO Guidance on Monitoring Internal Control Systems, September 2007, Discussion Document, Pages 23-24
66
Contact Information
Erick O. Bell
erbell@deloitte.com
(415) 783 6694
Priyanka Jhang
pjhang@deloitte.com
(213) 593 3753
DISCLAIMER
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Developing a Fraud Risk

Deloitte Financial Advisory Services LLP

Developing a Fraud Risk Management Program

Making the case for a Fraud Risk Management Program

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Making the case for a Fraud

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Occupational Fraud: Defined

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Errors Do Not Constitute Fraud

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

ACFE Fraud Statistics

Losses = 5 percent of revenue

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Size of Victim Organizations

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Types of Occupational Fraud & Abuse

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Developing a Fraud Risk Management Program

Why Organizations Should Manage Fraud Risk

Duty of care to shareholders/stakeholders

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Statutory and Regulatory Guidance/Requirements for

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Reasons Why Entities Need to Manage Fraud Risk

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Developing a Fraud Risk Management Program

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Private sector initiative established in 1985 by the following

American Accounting Association (AAA)

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Internal Control Integrated

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

The COSO Internal Control

The COSO framework helps

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Developing a Fraud Risk Management Program

Recognized as an Internal Control Standard

COSO Framework is well known and recognized as authoritative

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

Copyright 2013 Deloitte Development LLC. All rights reserved.

Developing a Fraud Risk Management Program

The New Internal Control Integrated