Internal Controls: As A Major Way of Increasing Difficulty of Committing Fraud
Internal controls are processes and procedures implemented by management to reasonably ensure that data is processed correctly, assets are safeguarded, information is protected, and laws are followed. The objectives of internal controls are to safeguard assets, maintain accurate records, provide reliable information, prepare proper financial reports, promote operational efficiency, encourage adherence to policies, and ensure compliance with laws. However, internal controls cannot provide absolute assurance due to limitations like fraud, errors, collusion, and management override. Internal controls perform preventive, detective, and corrective functions. Control environment, risk assessment, control activities, information and communication, and monitoring are the key components of an effective system of internal controls.
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Internal Controls: As A Major Way of Increasing Difficulty of Committing Fraud
Internal controls are processes and procedures implemented by management to reasonably ensure that data is processed correctly, assets are safeguarded, information is protected, and laws are followed. The objectives of internal controls are to safeguard assets, maintain accurate records, provide reliable information, prepare proper financial reports, promote operational efficiency, encourage adherence to policies, and ensure compliance with laws. However, internal controls cannot provide absolute assurance due to limitations like fraud, errors, collusion, and management override. Internal controls perform preventive, detective, and corrective functions. Control environment, risk assessment, control activities, information and communication, and monitoring are the key components of an effective system of internal controls.
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INTERNAL CONTROLS
AS A MAJOR WAY OF INCREASING DIFFICULTY OF COMMITTING FRAUD
INTERNAL CONTROLS- DEFINITION & OBJECTIVES Internal controls are the processes and procedures implemented by management to provide reasonable assurance that data is processed correctly, assets and information are safeguarded, and applicable laws are followed. Internal controls aim to achieve the following objectives:- 1. Safeguard assets- prevent or detect unauthorised acquisition, use or disposal 2. Maintain records in sufficient detail or report company assets accurately and fairly 3. Provide accurate and reliable information 4. Prepare financial reports in accordance with established criteria 5. Promote & improve operational efficiency i.e. minimize wastefulness 6. Encourage adherence to prescribed managerial policies 7. Comply with applicable laws. However internal controls provide reasonable assurance but complete assurance is difficult to achieve and prohibitively expensive. INTERNAL CONTROLS- LIMITATIONS Internal controls are designed by management to meet several objectives. However, no matter how hard an organisation tries to implement the best controls ever, there are limitations of internal controls. This means internal controls can never be 100% due to the following limitations:- 1. Fraud- human beings can be tempted and there fraud cannot be eradicated 100 % but can be minimised 2. Errors – these arise when employees exercise poor judgement or have a breakdown in their attention to the job. Poor judgment produces bad decisions and results from poor training, lack of experience or lack of knowledge. Breakdowns in attention arise from carelessness, which may be due to fatigue, outside interruptions or overwork. Even well trained employees may make errors. 3. Collusion – it occurs when two or more employees conspire to commit a theft from their employer 4. Management override- Managers in organisations have more authority than juniors. This is when a manager overrides his own control procedures. 5. Cost benefit analysis –The concept of reasonable assurance implies that the costs of implementing controls should not exceed the benefits derived. Any controls whose costs to implement exceed the benefits would not be implemented as the company can go bust. FUNCTIONS PERFORMED BY INTERNAL CONTROLS • Internal controls perform three important functions: 1. Preventive controls – these deter problems before they arise. Examples hiring qualified staff , segregation of employee duties and controlling physical access to assets 2. Detective Controls – these discover problems that are not prevented. Duplicate checking of calculations, preparing bank reconciliations and monthly trial balances. 3. Corrective controls – identify and correct problems as well as correct and recover from the resulting errors. Examples maintaining back -up copies of files, correcting data entry errors.
Internal controls are often put into two categories:
4. General Controls:- these make sure an organisation’s control environment is stable and well managed. E.g. Security, IT infrastructure, software acquisition, development and maintenance controls. 5. Application controls – prevent, detect and correct transactions errors and fraud in application programs. They are concerned with accuracy, completeness, validity and authorisation of data captured, entered, processed, stored, transmitted to other systems and reported. COMPONENTS OF INTERNAL CONTROLS Internal controls are classified into five components • Control environment or internal environment • Risk assessment • Control activities • Information and communication • Monitoring & evaluation Control/Internal Environment This is the foundation of all the other components. It sets the tone of the organisation. The control/internal environment is influenced by the history and culture of the organisation. The following factors affect/impact the control /internal environment. 1. Board of Directors & Audit Committee Participation • Directors are not employed by the organisation in another capacity • An audit committee consists of several of these outside directors • If audit committee is active in overseeing policies and procedures the internal control system is effective so organisation’s objectives can be achieved. • Audit committee can alert the entire board of issues before they become serious • An active board with appropriate technical expertise and management knowledge is critical for effective internal control. • The board should have enough outsiders that is able to question management’s activities. • The board should act in the event of management wrong doing. Control/Internal Environment 2. Commitment to Competence • Competence means employees have the knowledge and skills they need to perform their tasks. • Management decides how well these tasks are performed. • Management must evaluate the cost of hiring people with necessary skills. • When management is committed to competence the system of internal control is more likely to work. • Organisations that lack a climate of competence, both errors and irregularities are likely to occur. Control/Internal Environment 3. Organisational Structure • The organisational structure provides an overall framework for management functions i.e. planning, executing, controlling and monitoring activities performed by management. • Objectives are better achieved if the structure reflects its management functions that assign authority and responsibility. 4. Management Philosophy & Operating Style • These include management’s approach to taking business risks, attitudes toward accuracy of accounting data and emphasis on meeting budget and operating goals. • They have a significant influence on the effectiveness of the organisation’s control activities. Control/Internal Environment 5. Integrity & Ethical Values • Because management creates administers and monitors the system of internal controls, its effectiveness is limited by management attitudes toward integrity and ethical values. The ethical climate is affected by the guidance that management communicates both formally and informally to employees. A strong ethical climate in the organisation is also affected by incentives and temptations that management provides. • Official policies specify what management wants to happen, but organisational culture determines what actually happens, which rules are followed, bent or ignored. • If employees see top management engaging in unethical behaviour they are more likely to commit irregularities themselves. Therefore management must walk the talk. Control/Internal Environment 6. Assignment of Authority & Responsibility • Management assigns authority and responsibility for operating activities and establishes reporting relationships and methods of authorisation. • In decentralised environments management must align authority with accountability. The control environment is influenced by the extent to which employees recognise that they will be held accountable. Control/Internal Environment 7. Human Resources Policies & Practices • Human resources policies and practices send messages to employees about what the organisation expects in the way of integrity, ethical behaviour and competence. • These policies describe how the organisation trains, evaluates, promotes and pays employees. • Hiring practices demonstrate the organisation’s commitment to hiring competent and trustworthy employees. • Training practices communicate the expected levels of performance and behaviour. • Bonus incentives and disciplinary actions send messages about desirable and undesirable behaviour. • The effectiveness of any internal control structure relies on the honesty and the abilities of the employees. • Honest employees are less likely to perpetrate fraud and irregularities. • Competent employees are less likely to make errors. • Adequate human resources policies and practices ensure that the organisation hires competent people, trains them properly, treats them fairly and pays them adequately resulting errors and irregularities less likely to occur. Good Human Resources Policies & Procedures • Training:- Employees who understand their jobs are less likely to make errors. • Recognition for work well done- Encourages employees to prevent errors and irregularities. • “Adequate pay” – Fairly compensated employees are less likely to steal. • Investigate employees before hiring – A potential employee may have a history of dishonesty and carelessness. • Job Rotation – This is when employees rotate their jobs to ensure that an employee cannot continue to hide an error or irregularity that happened in the past. • Required Vacation - Employees should go on leave because an employee standing in for him/her while on vacation may discover an error or irregularity that occurred in the past. • Bonding or Fidelity Guarantee- This is a type of insurance that a company takes to ensure its reimbursed for the loss if an employee commits theft. • Confidentiality agreements- employees must sign and adhere to the requirements of such documents. RISK ASSESSMENT – 2nd COMPONENT • RISK ASSESSMENT This is the second component of internal controls. This involves management’s process of identifying and analysing risks that might prevent the organisation from achieving its objectives. Risks arise from both internal and external factors. • Internal Risks (Endogenous) These relate to specific activities of the organisation and they are within their control. Examples are errors due to untrained or unmotivated employees, disruption of the information system, the result of an ineffective board of directors and audit committee etc. RISK ASSESSMENT – 2nd COMPONENT • External Risks (Exogenous) These affect the organisation as a whole and they are beyond the organisation’s control. These are:- 1. Competition 2. Economic – e.g. inflation 3. Technological changes 4. Statutory or government regulations 5. Natural disasters or catastrophes 6. Change is also a risk that affects all organisations. Economic, industry and regulatory environments change. A system of internal controls that is effective under one set of conditions may not apply under another. As part of risk assessment an organisation needs a process to identify changed conditions that can affect its ability to achieve its objectives. Management must identify risks to the organisation’s objectives, estimate the extent of each risk, assess its likelihood CONTROL ACTIVITIES –3rd COMPONENT • This is the third component of internal controls. These are policies and procedures that management adopts to provide reasonable assurance that management directives are carried out. They help ensure that actions are taken to address the risks to the achievement of the organisation’s objectives. Control activities can be classified into 4 categories: - 1. Procedures for Authorising Transactions Management implements procedures for authorising transactions and states activities for processing them. The proper way to process transactions differs for each class of accounting transactions. Authorisations are often documented by signing, initialising, or entering an authorisation code on a document or record. Computer systems can record a digital signature i.e. electronically signing a document with data that cannot be forged. There are several good procedures for authorising transactions. Control Activities- Procedures for Processing Transactions • Prompt recording- Employees should record transactions immediately as they occur. This decreases opportunities for errors and irregularities in recording transactions. • Visual checking- An employee recording the transaction confirms visually that all data are complete and correct. For example, ensure that a student identity number tallies with the student name when issuing a receipt. • Balancing- The employee determines that total debit entries equal total credit entries for the transaction. • Batch controls- Employees accumulate transactions into batches and total the amount of each batch. In each later processing the total is recalculated. Proper procedures for authorising transactions depend on the kind of transaction. Management authorises transactions in two ways:- • General authorisation – describes conditions under which employees may initiate record and process one kind of transaction. When these conditions are met an employee is authorised to carry out these actions without further consultation with management. An example is a Cashier in a supermarket who charges merchandise from a customer and receives payment for the merchandise. • Specific authorisation:- it applies only to a specific single transaction. Before an employee initiates a transaction of this kind, the employee consults with management and obtains approval specifically for it. Management normally requires specific authorisation for large dollar amounts or those that present a high potential for fraud. Examples are voiding a transaction in a supermarket requires a supervisor, purchasing a new factory building requires board approval. Control Activities – Security for Assets & records 2 . Security for Assets & Records This is the second category of control activities where management should implement adequate safeguards to protect assets and records. Safeguards include two types:- • Physical security- Management implements procedures to provide physical security for inventory, cash, property, plant & equipment and for the records of these assets. Many organisations attach a non-removable label to each item of equipment with an identifying number which is entered in an asset register. Physical security is effective when management fixes responsibility for it with specific individuals. • Fixed Responsibility- this is when management assigns responsibility for specific assets and records to specific job positions. If an error or irregularity occurs, management holds the individual in that job position responsible. Internal control is best when management summarises and communicates responsibilities in writing and this encourages employees to do their jobs accurately and honestly. Control Activities- Segregation of Duties 3. This is the third category of control activities. Good internal controls do not permit a single employee too much responsibility over business transactions and processes as this may lead to committing and concealing fraud. Segregations of duties is in two categories i.e. segregation of accounting duties and segregation of system duties. • Segregation of Accounting Duties:- Effective segregation of accounting duties is achieved when the following functions are separated: • Authorisation –approving transactions and decisions • Recording- preparing source documents, inputting data into computer systems, maintaining journals, ledgers, files or databases and preparing reconciliations and preparing performance reports. • Custody- handling cash, tools, inventory or fixed assets, receiving incoming customer cheques, writing cheques. Control Activities- Segregation of Duties • If one person performs two of these functions problems can arise. Where there is effective separation of duties it is difficult for an employee to successfully perpetrate fraud. However if two or more people are in collusion to override controls it is more difficult as fraud is committed and concealed. • Employees can collude with other employees, customers or vendors. • Examples of most common employee/vendor collusions includes billing at inflated prices, performing substandard work and receiving full payment, payment for non-performance, duplicate billings or improperly purchasing more goods from a colluding company. • Examples of most common employee/customer collusions includes unauthorised loans, writing off amounts owed and unauthorised of extension of due dates. • Segregating of Systems Duties- where a person has unrestricted access to the computer, its programs and live data fraud can be perpetrated and concealed. Authority and responsibility should be divided clearly among the following functions:- Segregation of Systems Duties 1. Systems administration- Systems administrators ensure all information system components operate smoothly and efficiently. 2. Network management- Network managers ensure that devices are linked to the organisation’s internal and external networks and that the networks operate properly. 3. Security management- ensures systems are secure and protected from internal and external threats. 4. Change management- it is a process of ensuring changes are made smoothly and efficiently so that they do not negatively affect reliability, security, confidentiality, integrity and availability. 5. Users- records transactions authorise data to be processed and use the system output. 6. System analysis- help users to determine their information needs and design system to meet those needs. 7. Programming- programmers take the analysts’ design and develop, code and test computer programmes. Segregation of Systems Duties 8. Computer operations- operators run the software on the company’s computers ensuring that data are input properly, processed correctly and that needed output is produced. 9. Information system library- the information system librarian maintains custody of corporate databases, files and programmes in a separate storage. 10. Data control – ensures that source data has been properly approved, monitors flow of work through the computer, reconciles input and output, maintains a record of input errors to ensure correction and resubmission and distributes output. Allowing one person to do two or more of these jobs exposes the company to fraud. Control Activities-Safeguarding Assets, Records & Data This is the fourth category of control activities. The proper design and use of electronic and paper documents and records help ensure the accurate & complete recording of all relevant transaction data. Their form and content should be as simple as possible, minimize errors and facilitate reviews and verification. Documents that initiate a transaction should contain space for authorisations. • Those that transfer assets need a space for receiving party’s signature. Documents should be sequentially pre-numbered so each can be accounted for. An audit trail facilitates tracing individual transactions through the system, correcting errors and verifying system output. INFORMATION & COMMUNICATION – 4th COMPONENT • This is the fourth component of internal controls dealing with information at all levels for making operating decisions, for financial reporting and for compliance. It is identified, captured, processed and reported by information systems. • Communication is part of it and also includes policy manuals, accounting manuals and memoranda and notices. Information systems communicate both internal and external information. The following features in accounting help prevent and detect errors and irregularities: - • Debit & Credit Analysis • The double entry system where transactions are entered in two or more accounts helps detect many errors and detects or prevents many irregularities. It doubles the chance of detection. INFORMATION & COMMUNICATIPN – Chart of Accounts The chart of accounts is a list of all the accounts names and account codes used by the organisation. An employee may use only those accounts listed when making debit and credit entries. This restricts the opportunity for an employee to make errors or commit irregularities when recording transactions. A properly designed chart of accounts also minimizes errors and it should have some of the following characteristics: - Characteristics of A Well Designed Chart Of Accounts 1. Responds to organisation’s needs. Accounts included in a chart of accounts should meet management’s needs for control of operations and financial accounting requirements for external reporting. 2. Facilitates report preparation. Accounts in the chart of accounts should be listed in their order of appearance in the financial statements and should be compatible with the organizational structure. 3. Provides adequate description. A description of each account and its contents should be provided. This guidance to the accounting staff enables consistent use of the accounts. 4. Account titles provide clear distinctions. Account titles should be chosen to minimise ambiguities concerning the contents of an account. 5. Control accounts. The chart of accounts should incorporate control accounts. INFORMATION & COMMUNICATION – Trial Balance & Control Accounts Trial Balance • A trial balance is prepared as one step in the accounting cycle. For manual accounts an inequality is evidence of an error. Some of the common errors include misfooting and transposition. A trial balance is reviewed for abnormal account balances and an abnormal balance may indicate errors in posting or during debit credit analysis. Asset and expense accounts normally have debit balances and liability, capital/equity and revenue accounts credit balances. If a different balance is noted investigations are carried out to determine the cause. Control Accounts • A control account in the general ledger summarizes the contents of many accounts in the subsidiary ledger. If the total of the individual accounts in the subsidiary ledger is different from the control account in the ledger it alerts the accountant of a recoding error. The ideal is the control accounts must be reconciled every month. Examples of control accounts are the payroll, accounts receivables and payables, inventory and fixed assets. MONITORING & EVALUATION – 5th (Final) COMPONENT It is a process that assesses the quality of internal control performance over time. Organisations change and the ways in which controls are applied in them evolve. Monitoring and evaluation helps management determine what modifications to the system are needed as conditions and operating environment change. It involves assessing the design and operation of controls and taking corrective actions.
Monitoring performance can be done through various methods
MONITORING & EVALUATION - METHODS Internal Control Evaluation • Can use a formal or self assessment evaluation by a special team selected to carry out the evaluation • Evaluation can be done by internal audit Ensure Effective Supervision • Training & assisting employees as a continuous process • Monitoring employees’ performance • Correcting errors Supervision very important if there is no responsibility reporting & no adequate segregation of duties MONITORING & EVALUATION - METHODS Implement Responsibility Accounting Systems • Note that it is difficult to apply in unstable environments • Relates to budgets, targets, quality standards, comparing actual against planned performance • Includes procedures for investigating and correcting significant variances . Conduct Periodic Audits • Includes external & internal & network security audits to monitor risks and detect fraud and errors MONITORING & EVALUATION - METHODS • Auditors to test system controls regularly • Internal audit function to assess reliability of financial & operating information. • Internal audit also to assess internal control effectiveness & employee compliance with management policies & procedures. • Internal audit to assess compliance with applicable laws & regulations in each specific environment Monitor System Activities • Implement risk analysis & management software to review computer & network security, detect illegal access & test for weaknesses MONITORING & EVALUATION - METHODS • Reasonableness checks can be done after setting parameters of acceptable levels/thresholds • System also monitors and address virus issues • System to record all transactions & activities in a log that says who accessed what data, when and from which device Employ Computer Security Officer & Compliance Officer • These should be independent of system functions • Their roles are to test and evaluate security procedures & computer systems. • Can outsource these functions to computer consultants MONITORING & EVALUATION - METHODS Engage Forensic Specialists • Forensic accountants to assist in specialized investigations • Computer forensic specialists also have specialized knowledge to investigate fraud, sabotage, retrieving erased data etc. Install Fraud Detection Software • Assist organization in detecting fraud Implement a Fraud Hotline • Helps reporting fraud witnessed by people to minimize whistleblowers being persecuted CONCLUSION The five components of internal controls are the control environment, risk assessment, control activities, information and communication and monitoring. Management creates internal controls in order to ensure that the organisation’s goals are met.
COSO Internal Control - Integrated Framework: Executive Summary, Framework and Appendices, and Illustrative Tools for Assessing Effectiveness of a System of Internal Control (3 volume set) | Publications | AICPA & CIMA
The Leadership & Managerial Habits of Highly Effective Chief Audit Executives - Inspiring Excellence in Leading and Managing the Internal Audit Function