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

PART THREE Completing the Anti-Fraud Program: The Ceiling, the Roof, and Routine Maintenance

NOW THAT THE WALLS ARE UP, we need to put a ceiling on the structure. As soon as the ceiling is in place, we can put the roof over the structure and be done.

In our building metaphor, the ceiling is represented by the program documentation element and the company fraud training program element. These elements are so important in providing strength and security to the design structure. Without the proper documentation of the program, we have nothing to follow, no assurance or security that the program can even last. It would resemble a house with walls, but no ceiling to connect them and tie them all together. If we do have proper program documentation but no plan to communicate the program to our workforce, there is no strength to the program. Again, if the employees know nothing about the program, it has no strength.

Finally, the structure needs a roof. A roof protects a structure from outside influences. Because of its importance to the structure, routine maintenance is necessary. We must maintain the program. The monitoring and routine maintenance element of program design provides the maintenance necessary to protect the program by keeping it current and relevant. Just as your business grows and changes, so should your program.

The chapters in this part present a methodology for properly documenting the contents of the anti-fraud program, along with the training program necessary ...