One Year Reflection as LogicGate’s CISO
Nicholas Kathmann reflects on one year as LogicGate CISO
Fraud is a growing problem, affecting every business, industry, and region of operation. The Association of Certified Fraud Examiners’ (ACFE) estimates that organizations lose 5% of their revenue to fraud each year. Worse, about half of that loss is entirely preventable and can be traced back to either a lack of internal controls or an override of existing ones.
And it’s not just businesses that are being harmed by fraud: their customers ultimately pay the price, too. The Federal Trade Commission reports that consumers lost $2.6 billion to business imposters – scam artists who falsely claim affiliations with well-known companies — in 2022.
So, how can companies protect themselves — and their customers — from the growing risk of fraud? Through a process known as fraud risk assessment.
Fraud risk assessment evaluates the probability and impact of fraud risks and identifies the ways bad actors might try to sidestep your existing organizational controls, so your company can implement more effective controls and other preventive measures. Conducting comprehensive fraud assessments can help businesses better identify vulnerabilities, detect fraud earlier, and strengthen their overall risk posture.
This article explores why fraud risk assessment is essential, describes the different types of fraud risks your organization might face, details techniques for handling fraud risk, and offers step-by-step guidance on conducting fraud risk assessments.
Fraud risk assessment is critical to an organization's governance, risk, and compliance (GRC) strategy. Fraud risk assessment benefits organizations by helping them:
Like other types of risk, fraud risks can be either internal or external. Internal fraud occurs when an internal party, such as an employee, contractor, or vendor, exploits vulnerabilities in a company’s policies, procedures, or controls. External fraud occurs when someone outside the organization – customers, clients, competitors, hackers, scammers, or other bad actors – engages in fraudulent activity that targets your organization.
Here are some of the most common types of fraud risks that organizations should be aware of:
Financial reporting fraud occurs when an internal party intentionally manipulates or misrepresents a company's financial performance, position, or cash flows. This can include engaging in revenue recognition fraud, improperly valuing assets, creating fictitious transactions, and making intentional misstatements in financial reports. Financial reporting fraud not only deceives stakeholders but can also attract regulatory scrutiny, financial penalties, and legal consequences.
Similar to financial reporting fraud, non-financial information fraud risk involves falsifying or misrepresenting non-financial data, such as operational metrics, customer information, or compliance records. This can lead to inaccurate decision-making, compromised customer trust, and regulatory non-compliance.
Misappropriation of assets occurs when an internal party steals or misuses company resources, including inventory, cash, intellectual property, or equipment. This type of risk can be internal or, in some cases, involve an external party. Common examples include embezzlement, theft, payroll fraud, and fraudulent expense reimbursements. Misappropriation of assets can incur significant financial losses and hinder an organization's overall performance.
Illicit acts refer to fraudulent activities that violate laws and regulations. Like the misappropriation of assets, it involves both internal and external parties. Illicit acts include bribery, corruption, money laundering, insider trading, and kickbacks. Organizations that fail to detect and prevent them can face legal and financial consequences and damage their reputation.
Regulatory compliance fraud risks arise from intentional non-compliance with industry-specific regulations, such as anti-money laundering (AML) requirements, data privacy regulations, or healthcare compliance standards. Failure to address regulatory compliance risks can lead to penalties, legal action, and reputational damage.
To effectively manage fraud risks, companies should take a preventative approach. Consider the following when identifying potential fraud risks within your company’s operations:
Certain areas within an organization are more susceptible to fraud risks. These may include procurement and purchasing, payroll and compensation, financial reporting, internal controls, and third-party relationships. Identifying these common fraud risk areas enables organizations to focus their efforts and target preventive measures.
The well-known fraud triangle theory designates factors that commonly contribute to fraudulent behaviors: opportunity, incentive, and rationalization. In many cases, all three components converge, leading individuals to engage in fraudulent activities.
Opportunity refers to the specific circumstances, such as weak internal controls or inadequate accounting policies, that allow fraud to occur. Incentive refers to what an individual will gain, such as a financial bonus or meeting investor expectations. Finally, rationalization is how an employee justifies their actions, such as corporate culture or payback.
Understanding individuals’ possible motives, opportunities, and justifications can help companies effectively identify and mitigate fraud risks.
A report by the Association of Certified Fraud Examiners shows that, in cases when fraud occurs, the presence of anti-fraud controls results in lower fraud losses and quicker fraud detection. Allocating dedicated fraud resources and combining them with data monitoring and auditing techniques have proven to be particularly effective in reducing fraud risk. Consider the following techniques and tools for fraud risk assessment:
Dedicated fraud resources: Tasking professionals with establishing fraud policy, undertaking regular fraud risk assessments, and monitoring for fraud is important to creating a culture of fraud deterrence. As shown in the chart below, the Association of Certified Fraud Examiners found fraud reporting hotlines to be the most frequent method by which fraud gets reported.
Data analysis: Advanced analytics techniques can analyze large volumes of data to identify patterns, anomalies, and suspicious activities that indicate potential fraud risks.
Background checks: Conducting thorough background checks on employees, vendors, and partners can help identify individuals with a history of fraudulent activities or unethical behavior.
Internal audits: Regular internal audits evaluate the effectiveness of internal controls and identify any potential weaknesses or vulnerabilities that may be exploited for fraud.
External audits: Regular external audits of financial statements and external audits of internal controls over financial reporting can identify irregularities.
Codes of conduct: Establishing a code of conduct, including anti-fraud policies and fraud training, supports a firmwide risk culture and keeps fraud prevention in mind for all employees.
Companies use fraud risk assessment to identify and understand the threat fraud poses to business operations and any weaknesses in controls that increase the possibility of experiencing fraud events. Once a fraud risk is identified, you’ll want to develop a risk mitigation plan, put in place controls or procedures, and assign individuals to monitor the risk.
Make it clear who is responsible. Create a governance structure to oversee fraud risk management activities. This structure should include assigning roles and responsibilities, establishing policies and procedures, and ensuring clear communication and accountability.
Evaluate your organization's operations, processes, and systems to identify potential fraud risks. Leverage the fraud triangle discussed above to determine which roles and departments are most likely to commit fraud and identify the methods they may use. Gather data, conduct interviews, and leverage industry-specific knowledge to identify areas particularly vulnerable to fraud.
Know where to focus your efforts by taking a risk-based approach. This means quantifying the potential impact and likelihood of identified fraud risks to deploy resources effectively.
Consider your current controls and procedures when assessing the likelihood of fraud. Determine whether the likelihood of the fraud occurring is low (once every ten years), medium (once every three or more years), or high (annually or even more frequently). Oftentimes, resources are allocated to deter fraud events with a high likelihood, but that may not be the most efficient way to deploy limited resources. Taking the additional step of determining the potential financial and reputational cost of a fraud event and evaluating it against likelihood can help you prioritize the risks and allocate resources where they can most effectively mitigate risks. Using risk quantification methods can help you tie your fraud risks to their potential business impact.
Based on the results of your risk assessment, develop and implement control measures to mitigate the identified fraud risks. This may include strengthening internal controls, enhancing monitoring systems, conducting regular fraud awareness training, or other mitigation techniques.
Continuously monitor and review the effectiveness of implemented fraud risk mitigation strategies. Regularly assess the changing risk landscape and your evolving operations to update controls as needed and ensure ongoing compliance with fraud prevention measures.
Fraud risks vary across industries due to specific regulations, operating characteristics, and inherent vulnerabilities. Here's a brief overview of fraud risks in different sectors and where they are most vulnerable:
Within the broader financial services sector, which includes banking, fintech, insurance, and investment services, common fraud risks include money laundering, identity theft, insider trading, and fraudulent loan applications. Organizations must have robust and dynamic anti-fraud controls in order to comply with evolving regulations, implement strong authentication and verification processes, know their customers, and stay on the right side of the law.
Retail businesses face fraud risks such as point-of-sale (POS) fraud, online payment fraud, shoplifting, and return fraud. Putting in place secure payment systems, customer authentication measures, and robust inventory controls can help mitigate these risks.
Healthcare and pharmaceutical companies are susceptible to fraud risks such as billing fraud, prescription fraud, and healthcare identity theft. Having stringent compliance programs, conducting thorough background checks on employees and vendors, and establishing effective monitoring systems are essential in this industry.
Government agencies and contractors face fraud risks related to procurement, contract mismanagement, and corruption. Transparent procurement processes, anti-fraud controls, and regular audits are crucial to mitigating fraud risk in the public sector.
To effectively manage fraud risks, every organization should consider the following strategies:
Regular training and awareness programs educate employees about fraud risks, red flags, and ethical behavior. Promoting a strong anti-fraud culture encourages employees to report suspicious activity and helps prevent fraud.
Developing comprehensive fraud policies and procedures will provide clear guidelines for employees on acceptable behavior, reporting mechanisms, and consequences of fraudulent activities.
Implementing ongoing monitoring and review processes helps detect and prevent fraud. This can include continuous data monitoring, internal audits, and periodic risk assessments.
Creating a culture that prioritizes integrity, ethics, and compliance is vital to fraud prevention. Organizations should foster a work environment where employees feel empowered to raise concerns and report potentially fraudulent activities.
Conducting a thorough fraud risk assessment is essential to risk management best practices and building a risk-aware and fraud-free organization. By understanding the different types of fraud risks, identifying vulnerabilities, and implementing preventive measures, businesses can protect their assets, preserve their reputation, and ensure compliance with regulatory requirements.
A comprehensive, modern GRC platform, like as LogicGate’s Risk Cloud, integrates fraud risk assessment into your holistic risk management program. By offering continuous monitoring, scalability, and integrated risk management, you can stay one step ahead of fraudsters and safeguard your company’s long-term success.
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Nicholas Kathmann reflects on one year as LogicGate CISO
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