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Under the Surface
         viewpoints
        The Shifting Fraud Landscape
 c lt re   dit
 i  pr ctice   It’s esse ti l th t i ter  l   ditors  eep  p with the l test fr  d tre ds   d tools.

 Many valuable insights can be gleaned
 from this culture audit example. For
 instance, this internal audit function has   Wh t  re so e   fewer people were writing  checks like the old days.
 a strong culture, formal authority, and   c rre t fr  d   checks, it wasn’t antici-  Why is it happening?
 level 1:  level 2: espoused   level 3: underlying   seems to value perceived objectivity   tre ds?  pated we were going to   Maybe fraudsters think
 artifacts  values  assumptions  and independence over relationships   Organizations are see-  see this reemergence.   financial institutions

 Dress Code  Mission Statement, Core Values  How to Work Together  with stakeholders. Perceptions may   ing a lot of fraud today.   It’s plaguing quite a   aren’t paying attention to
 Formal  Created 10 years   Follow the chain of   matter more than substance, and   Especially in the finan-  few organizations.  checks as much as they
 ago, not updated.  command only.  rigor and process more than critical   cial industry, we’re see-  And it comes in all   used to. They don’t have
 Language    Holly Ray                      forms: altered checks,   the appropriate controls
 Technical, profes sional,   Charter  Behaviors That Lead to   thinking or innovation. A risk is that   Senior Manager, Fraud and   ing the reemergence of
 internal audit jargon.  Unfettered access.  Success or Failure  the department may not be seen as   Financial Crime Technology   check fraud. Given there  washed checks, forged   in place, probably.
             Consulting, EY
 Come in early   a trusted advisor and may become   was a big digital shift   checks, and then just   We’re also seeing a lot
 Talent Management Docs
 Technology  (appraisal, development, competency)  and stay late.  ineffective, as evidenced by:   during COVID- where   straight-up counterfeit   of digital identity fraud,
 Pen and paper.  Annual appraisal   • A culture that reacts to change slowly
 Safety
 Stories & Myths  process matches with   Never challenge the boss.  and poorly, possibly rendering it
 Internal audit is all   the organization.  ineffective.
 about the “gotcha!”  Blanket raises for   Don’t rock the boat.  • Disincentives to work efficiently:
 the department.  Perceptions of Power
 Visible Traditions  Presenteeism or “being there” is valued
 Formal opening and   Procedures, Training Guides  Chain of command only.  highly, and there is a lack of merit pay.
 closing meetings.  Outdated procedures.  How Decisions Are Made  • Cross-departmental relationships
 No attendance at   Reporting Structure  Follow last year’s   that are formal and potentially
 company events.  Audit committee.  workpapers.  confrontational, which can lead to a
 lack of trust and stakeholders who
 withhold information.
 • A chain of command and a “we have
 always done it this way” mentality that
 can ultimately dampen critical thinking,
 audit quality, and stakeholder value.
                                                                                                            viewpoints
                                                 Internal Auditor  79  June 2024
 Internal Auditor  55  June 2024  where fraudsters are   Who is co  itti    he or she will sell it on   test the bank’s response   testing, control enhance-
    creating synthetic IDs.   fr  d?      social media for ‰Š     and thresholds, using             ment recommenda-
    They’re taking bits and   Depending on the type   each, and many differ-  small-dollar amounts,   tions, and ongoing mon-
    pieces of information   of fraud, there are indi-  ent kinds of people will   and they’ll go back and   itoring. Internal audit,
    from real individuals and  viduals who are just   buy that playbook and   refine the fraud. They   compliance, and other
    pulling these together to   reacting out of oppor-  commit those frauds in   test it on a small scale,   groups often work hand
    create a completely new   tunity. But there also   small-dollar amounts.  and then they reorganize   in hand to tackle fraud
    identity that doesn’t exist.  are very large, organized   In a known network, a  themselves to do it on a   Holly Tucker  risk management across
    With that, they’re able   networks. Maybe it’s a   group of organized indi-  very large scale.   Partner, Deloitte Financial   the enterprise.
    to establish credit, open   known network or an   viduals comes together      Advisory Services LLP
    accounts, and ultimately  unknown network.  specifically to com-  Wh t  re the                  Wh t fr  d
    defraud institutions as   In an unknown net-  mit a fraud. If it’s a data   bi  est ch lle  es   Wh t is i ter  l   co trols  re ofte
    well as individuals. Keep  work, for example, an   breach, the target could   i  c tchi   fr  d?    dit’s role i    overloo	ed?
    in mind, it’s not just   insider who knows the   be any type of busi-  Fraud is one of those   fi hti   or   -  Some organizations rely
    affecting banks, because   ins and outs of how an   ness. If it’s in the finan-  exciting spaces to work   i
 tio  l fr  d?  solely on controls stem-
    to establish an identity   institution works puts   cial sector, maybe they   in because it’s always   Internal audit’s role in   ming from the U.S.
    and credit line, fraudsters  together a step-by-step   are focusing on a par-  changing. Today it’s   preventing, detecting,   Sarbanes-Oxley Act of
    have to hit all the differ-  playbook on how to   ticular type of payment,   checks; tomorrow it   and monitoring fraud has      for their fraud pre-
    ent areas like retail stores  defraud the company   check, or wire. They   might be wires. Or it’s   evolved over the years,   vention and detection
    and healthcare.    or an individual. Then   will work together to   synthetic IDs. So, one of   and internal audit teams   efforts, but fraud is bigger
                                                             the biggest challenges   are now often deeply   than that. Controls that
                                                             is knowing what you’re   involved in — and some-  are often overlooked are
                                                             looking for, knowing   times leading — an orga-  operational in nature. For
                                                             how the fraud scheme   nization’s fraud risk   example, the geographies
    Fraud is one of those exciting spaces to                 is being perpetrated —   assessment process.   in which a company
    work in because it’s always changing.                    but then also having the   We increasingly see   has operations can pose
   Today it’s checks; tomorrow it might                      tools in place to help   internal auditors lever-  fraud risks. Certain prod-
                                                                                 age fraud risk assess-
                                                             identify those things.
                                                                                                    ucts may have unique
    be wires. Or it’s synthetic IDs. So, one                 You have to continually   ment results, prior inves-  fraud risks. Changes
                                                             refine your processes,
                                                                                 tigations, case informa-
                                                                                                    within the organiza-
    of the biggest challenges is knowing                     workforce, and tools and   tion from whistleblower   tion, such as an acquisi-
    what you’re looking for, knowing how                     make sure you’re keep-  hotlines, and other   tion, divesture, or exec-
                                                                                 internal data to drive
                                                                                                    utive management turn-
                                                             ing up with evolving
    the fraud scheme is being perpetrated.                   fraud trends.       insights in fraud control   over, also can increase
         INTERNAL AUDIT TODAY                                                                               66
                                                Internal Auditor  80  June 2024
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