Preface: Maybe It's Time We Get Back to the Basics xi Acknowledgments xvii PART I: THE ANTIFRAUD ENVIRONMENT: THE BLUEPRINTS, THE FOUNDATION, THE GROUND FLOOR Chapter 1: The Architect's Blueprint: Establishing the Framework 3 The Elements of AntiFraud Program Design 3 AntiFraud Environment 4 Fraud Risk Assessment 4 Control Activities 5 Information: Program Documentation 6 Communication: The Company Fraud Training Program 6 Monitoring and Routine Maintenance 7 Chapter 2: Foundational Policies: The Fraud Policy 9 Foundational Policies 10 The Fraud Policy: The Essential Elements of an Effective Fraud Policy 10 Case Presentation 17 Chapter 3: Foundational Policies: The Fraud Reporting Policy 19 The Essential Elements of an Effective Fraud Reporting Policy 20 Chapter 4: Foundational Policies: The Expense Reimbursement Policy 29 Case: "No Questions Asked" 29 Case: "It Will Never Be Missed" 30 Case: Larry the Chief Financial Offi cer 31 The Elements of an Effective Expense Reimbursement Policy 32 Appendix 4A: Expense Report Form 39 Appendix 4B: Supplemental Business Meal and Entertainment Charges Form 40 Chapter 5: The Ground Floor: The Fraud Risk Assessment Process 41 Ground Rules for Fraud Risk Assessment 42 An Example of Risk Assessment 43 Procedural Steps for Performing a Fraud Risk Assessment 44 Cash in Bank 48 Case: The Trail Is Gone 50 Case: Friends in Low Places 51 Asset Misappropriation 52 Corruption 53 Financial Statement Fraud 53 PART II: ANTIFRAUD CONTROL ACTIVITIES: RAISING THE WALLS Chapter 6: Control Activities: The Absolutes 57 Critical Principles of Control Activity Design 57 Foundational Control Activities 59 Case: The Mail Drop in Las Vegas 64 Appendix 6A: Confl ict of Interest Form 67 Appendix 6B: New Vendor Establishment Form 68 Chapter 7: Control Activities: The Segregation of Duties Dilemma 69 But I Only Have Two Employees 69 Prevention versus Detection Controls 70 The Necessary Review Processes 72 Chapter 8: Control Activities: General Processes 75 Two Operational Questions 75 Common Control Activities 81 Case: The Cell Phone Reimbursement 91 Chapter 9: Control Activities: Specific Control Areas 95 Financial Statement Line Item Control Activities 95 PART III: COMPLETING THE ANTIFRAUD PROGRAM: THE CEILING, THE ROOF, AND ROUTINE MAINTENANCE Chapter 10: The Ceiling: Documenting the AntiFraud Program 103 Information 103 Documentation--Keeping It Simple 104 The Elements of HighQuality Documentation 104 Chapter 11: The Ceiling: The Company Fraud Training Program 111 The Elements of Effective Communication 112 The Company Fraud Training Program 114 Chapter 12: The Roof: Monitoring and Routine Maintenance 119 Monitoring and Routine Maintenance Defi ned 120 The Monitoring and Routine Maintenance Structure 120 Chapter 13: The Sample AntiFraud Program 129 Appendix 13A: Fraud Risk Assessment Framework Form 137 Appendix 13B: Control Activities Form 138 Appendix 13C: Documentation of Control Activities 139 Appendix 13D: Compliance Audit Programs and Related Compliance Audit Working Papers 154 Appendix A: The Fraud Policy 171 Appendix B: The Fraud Reporting Policy 175 Appendix C: The Expense Reimbursement Policy 179 Appendix D: Forms 185 About the Author 193 Index 195.