Administrative Affairs Internal Audit
Fraud Investigations

Fraud encompasses an array of irregularities and illegal acts characterized by intentional deception. It can be perpetrated for the benefit of or to the detriment of the organization and by persons outside as well as inside the organization.

Fraud designed to benefit the organization generally produces such benefit by exploiting an unfair or dishonest advantage that also may deceive an outside party. Perpetrators of such frauds usually benefit indirectly from the fraud, since personal benefit usually accrues when the organization is aided by the act. Some examples include:


Fraud perpetrated to the detriment of the organization generally is for the direct or indirect benefit of an employee, outside individual, or another firm. Some examples are:


Deterrence consists of those actions taken to discourage the perpetration of fraud and limit the exposure if fraud does occur. The principal mechanism for deterring fraud is internal control. Primary responsibility for establishing and maintaining internal controls rests with management. The Internal Audit Department is responsible for assisting in the deterrence of fraud by examining and evaluating the adequacy and the effectiveness of internal controls, commensurate with the extent of potential risk/exposure in the various segments of the entity's operations. In carrying out this responsibility, The Internal Audit Department should, for example, determine whether: (1) the organizational environment fosters control consciousness; (2) realistic organizational goals and objectives are set; (3) written corporate policies (e.g. code of conduct) exist which describe prohibited activities and the action required whenever violations are discovered; (4) appropriate authorization policies for transactions are established and maintained; (5) policies, practices, procedures, reports, and other mechanisms are developed to monitor activities and safeguard assets, particularly in high-risk areas; (6) communication channels provide management with adequate and reliable information; and (7) recommendations need to be made for the establishment or enhancement of cost-effective controls to help deter fraud.

Detection consists of identifying indicators of fraud sufficient to warrant recommending an investigation. These indicators may arise as a result of controls established by management, test conducted by auditors, and other sources both internally and externally.

In conducting auditing assignments, the Internal Auditor's responsibilities for detecting fraud include:


Internal auditors are not expected to have knowledge equivalent to that of a person whose primary responsibility is detecting and investigating fraud. Also, auditing procedures alone, even when carried out with due professional care, do not guarantee fraud will be detected.

Investigation consists of performing the extended procedures necessary to determine whether fraud, as suggested by the indicators, has occurred. It includes gathering sufficient evidential data about the specific details of the suspected fraud. Internal auditors, lawyers, investigators, security personnel, and other specialists from inside or outside the organization are the parties who usually conduct or participate in fraud investigations. When conducting fraud investigations, The Internal Audit Department should:


Once a fraud investigation is concluded, The Internal Audit Department should assess the facts known in order to: (1) determine if controls need to be implemented or strengthened to reduce future vulnerability; (2) design Internal Auditing tests to help disclose the existence of similar frauds in the future; and (3) help meet the Internal Auditor's responsibility to maintain sufficient knowledge of fraud and thereby be able to identify future indicators of fraud.

Reporting consists of various oral or written interim or final communications to management regarding the status and results of fraud investigations. A preliminary or final report is desirable at the conclusion of the detection phase. The report should include the Internal Auditor's conclusion as to whether sufficient information exists to conduct an investigation. It should also summarize findings which serve as the basis for such a decision.

Additional interpretive guidelines on the reporting of fraud are as follows:


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