Fun & Games - Summary of Findings
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To: Howard Green, Chief Legal Officer, Fun & Games Corporation
From: Angela Bundy, Knox LLP
Re:
Fun & Games Corporation, Accounts Payable Fraud Case
Red Flags:
During our investigation, we discovered several red flags. The first of which is that the Game Department's spending increased between 2010, the year Carla was hired and 2011. This was a red flag because Carla was employed as the budget director for the Company's Games department, giving her direct access to influence these forecasts. The second red signal was the existence of invoices to a company called FPI dating back to 2013. That was a warning signal because Carla purchased Flower Patch Incorporated in 2013. According to Fun & Games' invoices, FPI's address is 732 Independence Way, Kensington, MD, which is also the address of the flower company Carla purchased. The final red flag was Carla's lifestyle. Carla's income of $65,000 allowed her to travel regularly,
own a huge home, wear designer bags, fine jewelry, and drive a Lexus SUV, according to her colleagues. Carla became friends with many of the AP department staff, while it is typical for coworkers to know each other, it appears that the majority of her friends worked in Accounts Payable while she worked in Games. This suspicion is supported by her frequent disregard for invoicing protocol, which may not have been reported due to their close friendship.
Potentially Fraudulent Vendors:
Buddy the Elf Toy Store
The cheque flagged by Fun & Games' bank for Buddy the Elf Toy Store is most likely a legitimate transaction. The contract was renegotiated, and the new pay date of November 15th was agreed upon. While investigating the fraud, Buddy the Elf Toy Store validated invoice numbers and payment for all previous purchases. Because Buddy the Elf Toy Store cooperated in
the fraud investigation, they would most likely validate the invoice in question to Fun & Games. The fraud investigation discovered that Carla ordered that all Games Department cheques be returned to her for mailing. This violated policy, but the AP Department saw no reason to be suspicious. Carla was most likely the one who attempted to deposit the cheque, as she requested it back from AP. She could not transfer it into her personal account because the check was issued to Buddy the Elf Toy Store, not her.
FPI
After our initial suspicions about the "FPI" company, we investigated all associated transactions. During our study of the company's transaction ledger, FPI was the only vendor who used acronyms rather than a full company name. As previously stated, Carla's company is called Flower Patch Incorporated, and this was most likely Carla's attempt to conceal the fact that FPI is
her company. We can reasonably conclude that FPI is in reality Flower Patch Incorporated, which throws into question the commercial relevance of a flower company doing business with a
toy company.
Although uncommon, it is possible that Fun & Games required flowers for business considerations. However, this does not explain why FPI transactions were assigned to
cost codes such as magic, electronic, and interactive games. Even if Carla was allowed to conduct business with her own company, the misrepresentation of expenses amounts to financial statement fraud.
Invoice 1434 is out of sequence, assuming that the invoice numbers are in chronological order. Invoice 1424 was dated in the fourth quarter of 2014, whereas invoice 1434 was dated in the third quarter of 2014. FPI repeats invoice # 1232 in September and November of 2013. The AP Department approves payment for both invoices numbered 1232. It's difficult to say which, if either, is authentic, because the September invoice is $13,303.36 and the November invoice is $13,281.43. The total possibly fraudulent amount is $116,829.08, which includes all FPI-related transactions.
Scarlett's Toy Shoppe
There are two names for the same vendor. This appears to be a genuine error, not scam. However, there were a few invoices which triggered a cause for concern. Invoice #13458 was duplicated in both the first and third quarter of 2013. The $15,579 invoice from the third quarter of 2013 is questionable because it is out of sequence and time. Invoice #13A78 is out of the usual; the timing and invoice number format make it suspicious. Invoice #14358 was also handled out of sequence. The invoice date is 10/10/2012, yet the invoice number sequence is higher than in invoices with later dates.
Scarlet's Toy Shoppe's total loss is $46,610, which includes $21,811 in duplicate bills, $4,363 in fraudulent invoices, and $20,436 in out of sequence invoices. On June 1, 2014, Scarlet's Toy Shoppe received a $5,751.96 telephone invoice. Scarlet's Toy Shoppe is a game vendor to Fun & Games rather than a telephone company; hence this was a false invoice.
There was also a vendor named "0" who may have been a result of human error. According to the
cost code G112, it falls under the electric category and could have been for an electricity bill. After additional investigation, we discovered that the address is the same as the previous transactions to Capital Electric. The invoice sequence and date further demonstrated human error
and nothing fraudulent.
Fraud Triangle Analysis:
To properly comprehend the conditions that led to this fraudulent activity, we must examine the components of the fraud triangle. The fraud triangle concept suggests that most cases of fraud have three elements: perceived opportunities, pressures, and rationalizations. Weak internal controls and bad management can create a climate susceptible to fraudulent activities, known as perceived opportunity. However, opportunity does not necessarily imply fraud. Fraudulent
activity is often motivated by perceived financial pressure and rationalizations, creating a perfect storm.
We will analyze Carla Cosgrove, an employee at Fun & Games, and her perceived pressures. Carla, a frequent traveler and new homeowner, drives a Lexus SUV, as mentioned in our initial red flags. She frequently wears high-end jewelry and designer handbags. These observations suggest a perceived pressure to maintain a luxury lifestyle. Employee interviews revealed that Carla purchased a floral business in 2013. Her firm may have underperformed, prompting her to seek alternative revenue, which would be fraudulent.
Second, we must consider what opportunities Carla used to commit the alleged fraud. Carla's contacts with Accounts Payable personnel allowed her to submit invoices after the end-
of-week deadline, circumventing Controller approval. Despite being formally hired as the Budget Director of the Games Department, she was appointed as the authorized signor for invoices by the department head. This delegation gave her the right to prepare, sign, and approve invoices, indicating a lack of separation of functions and potential for fraud.
Finally, we evaluate the various rationalizations created to defend the alleged fraud. Carla worked for the company since 2010 and was terminated in 2015 with a salary of only $65,000. Despite taking on more responsibilities in 2011, her income remained flat. The complaint does not specify if she was rewarded for her new responsibilities. It's possible she felt she deserved more money than she received.
Implement Future Internal Controls:
This fraud investigation identified numerous warning flags, as well as similar characteristics seen
inside the fraud triangle. This includes pressure, reasoning, and the chance to commit fraud. Through the red flags highlighted, a few solutions have been made that the organization should implement into their system to prevent future fraud.
Separation of duties:
The company should establish a separation of duties. Separating jobs promotes responsibility and prevents one person from monitoring multiple responsibilities. Carla, for example, was approving and processing vendor payments; she should not have been able to get the checks back for mailing purposes. To avoid fraud in the future, it would be
prudent to designate someone else as the person in charge of mailing these checks.
Effective internal control system:
The company should implement an effective internal control system, which originates from the tone of top management. This could be accomplished by implementing rigorous risk assessment, control actions, information and communication systems, and monitoring. For example, the AP process said that the authorized signer is often the department head, although this can be delegated, and checks can be returned. To prevent fraud, management should evaluate the signors and all check requests on a periodic basis.
Performing audits regularly:
The company should execute regular audits to identify any weaknesses or red flags in its
accounting process and financials. It will also help detect and prevent future frauds. Employees will be less motivated or have a more difficult time discovering possibilities to commit fraud since they are aware of the regular audits. For fear of getting detected, they will avoid engaging in any fraudulent action.
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References
Beaver, S. (2022, Feb 16).
Oracle NetSuite.
Essential Guide to Accounts Payable Fraud: Types, How to Spot It & Prevention. https://www.netsuite.com/portal/resource/articles/accounting/accounts-payable-
fraud.shtml#How%20Does%20Accounts%20Payable%20Fraud%20Work
?
Fraud Risk Management. (2023, Dec. 22). Financial Crime Academy. Strategies for Fraud Detection: An Overview of Techniques, Policies, and Law Enforcement Involvement. https://financialcrimeacademy.org/strategies-for-fraud-detection/
Moody, M. (2018, May 16). ACFE Insights.
The 6 Most Common Behavioral Red Flags of Fraud. https://www.acfeinsights.com/acfe-insights/6-common-red-flags-fraud
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