Internal Control/Anti-Fraud Program Design for the Small Business: A Guide for Companies NOT Subject to the Sarbanes-Oxley Act

Table of contents

1. Preface: Maybe It’s Time We Get Back to the Basics
   1. ANTI-FRAUD PROGRAM DESIGN FOR THE SMALL BUSINESS
   2. SMALL BUSINESS DEFINED
   3. THE ANTI-FRAUD PROGRAM STRUCTURE
   4. NOTES
2. Acknowledgments
3. PART ONE THE ANTI-FRAUD ENVIRONMENT: THE BLUEPRINTS, THE FOUNDATION, THE GROUND FLOOR
   1. Chapter 1 The Architect’s Blueprint
      1. THE ELEMENTS OF ANTI-FRAUD PROGRAM DESIGN
      2. ANTI-FRAUD ENVIRONMENT
      3. FRAUD RISK ASSESSMENT
      4. CONTROL ACTIVITIES
      5. INFORMATION: PROGRAM DOCUMENTATION
      6. COMMUNICATION: THE COMPANY FRAUD TRAINING PROGRAM
      7. MONITORING AND ROUTINE MAINTENANCE
   2. Chapter 2 Foundational Policies
      1. FOUNDATIONAL POLICIES
      2. THE FRAUD POLICY: THE ESSENTIAL ELEMENTS OF AN EFFECTIVE FRAUD POLICY
      3. CASE PRESENTATION
   3. Chapter 3 Foundational Policies
      1. THE ESSENTIAL ELEMENTS OF AN EFFECTIVE FRAUD REPORTING POLICY
   4. Chapter 4 Foundational Policies
      1. CASE: “NO QUESTIONS ASKED”
      2. CASE: “IT WILL NEVER BE MISSED”
      3. CASE: LARRY THE CHIEF FINANCIAL OFFICER
      4. THE ELEMENTS OF AN EFFECTIVE EXPENSE REIMBURSEMENT POLICY
      5. APPENDIX 4A: EXPENSE REPORT FORM
      6. APPENDIX 4B: SUPPLEMENTAL BUSINESS MEAL AND ENTERTAINMENT CHARGES FORM
   5. Chapter 5 The Ground Floor
      1. GROUND RULES FOR FRAUD RISK ASSESSMENT
      2. AN EXAMPLE OF RISK ASSESSMENT
      3. PROCEDURAL STEPS FOR PERFORMING A FRAUD RISK ASSESSMENT
      4. CASH IN BANK
      5. CASE: THE TRAIL IS GONE
      6. CASE: FRIENDS IN LOW PLACES
      7. ASSET MISAPPROPRIATION
      8. CORRUPTION
      9. FINANCIAL STATEMENT FRAUD
4. PART TWO ANTI-FRAUD CONTROL ACTIVITIES: RAISING THE WALLS
   1. Chapter 6 Control Activities
      1. CRITICAL PRINCIPLES OF CONTROL ACTIVITY DESIGN
      2. FOUNDATIONAL CONTROL ACTIVITIES
      3. CASE: THE MAIL DROP IN LAS VEGAS
      4. APPENDIX 6A: CONFLICT OF INTEREST FORM
      5. APPENDIX 6B: NEW VENDOR ESTABLISHMENT FORM
   2. Chapter 7 Control Activities
      1. BUT I ONLY HAVE TWO EMPLOYEES
      2. PREVENTION VERSUS DETECTION CONTROLS
      3. THE NECESSARY REVIEW PROCESSES
   3. Chapter 8 Control Activities
      1. TWO OPERATIONAL QUESTIONS
      2. COMMON CONTROL ACTIVITIES
      3. CASE: THE CELL PHONE REIMBURSEMENT
   4. Chapter 9 Control Activities
      1. FINANCIAL STATEMENT LINE ITEM CONTROL ACTIVITIES
5. PART THREE COMPLETING THE ANTI-FRAUD PROGRAM: THE CEILING, THE ROOF, AND ROUTINE MAINTENANCE
   1. Chapter 10 The Ceiling
      1. INFORMATION
      2. DOCUMENTATION—KEEPING IT SIMPLE
      3. THE ELEMENTS OF HIGH-QUALITY DOCUMENTATION
   2. Chapter 11 The Ceiling
      1. THE ELEMENTS OF EFFECTIVE COMMUNICATION
      2. THE COMPANY FRAUD TRAINING PROGRAM
   3. Chapter 12 The Roof
      1. MONITORING AND ROUTINE MAINTENANCE DEFINED
      2. THE MONITORING AND ROUTINE MAINTENANCE STRUCTURE
   4. Chapter 13 The Sample Anti-Fraud Program
      1. APPENDIX 13A: FRAUD RISK ASSESSMENT FRAMEWORK FORM
      2. APPENDIX 13B: CONTROL ACTIVITIES FORM
      3. APPENDIX 13C: DOCUMENTATION OF CONTROL ACTIVITIES
      4. APPENDIX 13D: COMPLIANCE AUDIT PROGRAMS AND RELATED COMPLIANCE AUDIT WORKING PAPERS
6. Appendix A The Fraud Policy
   1. SAMPLE FRAUD POLICY
   2. NOTE
7. Appendix B The Fraud Reporting Policy
   1. SAMPLE FRAUD REPORTING POLICY
   2. NOTE
8. Appendix C The Expense Reimbursement Policy
   1. SAMPLE EXPENSE REIMBURSEMENT POLICY
   2. NOTE
9. Appendix D Forms
10. About the Author
11. Index
12. EULA