Fraud/White Collar Crime

 

 

https://sm.asisonline.org/Pages/The-Fraudster-Down-the-Hall.aspxThe Fraudster Down the HallGP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a43444652018-08-01T04:00:00Zhttps://adminsm.asisonline.org/pages/mark-tarallo.aspx, Mark Tarallo<p>​Employees are stealing from their own companies, and they are taking much more than just paper clips and Post-it Notes. Occupational fraud—sometimes called internal fraud—is globally costing businesses the equivalent of billions of dollars annually, according to a new global report.</p><p>The methods used by the culprits vary. Some skim cash from the reserves or walk away with inventory. Some alter numbers on payroll checks. And some pull off various embezzlement schemes, such as reporting false expenses or changing financial statements. The one commonality is that it is the organization's own employees who are perpetuating the misdeeds. Sometimes they act in collusion with each other, and sometimes they act alone.  </p><p>The findings come from Report to the Nations, an extensive study issued in April by the Association of Certified Fraud Examiners (ACFE). The study looked at 2,690 cases of fraud spanning 23 industries in 125 countries between January 2016 and October 2017. It is the tenth edition of the report, which ACFE issues every two years. </p><p>All told, the 2,690 cases of fraud resulted in losses that exceeded $7.1 billion. But the "true global cost of fraud is likely magnitudes higher," the report's authors write. ACFE estimates that 5 percent of worldwide business revenue is lost to fraud, which would come out to roughly $4 trillion annually. </p><p>"It's safe to say the problem remains huge," says John Warren, vice president and general counsel of ACFE and one of the authors of the report. </p><p>Given the magnitude of the losses, it's not surprising that another report, this one focused on the United Kingdom and issued last year by Bottomline Technologies, finds that executive concern about internal fraud spiked in just one year's time. </p><p>In the Bottomline report, UK Business Payments Barometer 2017, the percentage of study respondents who cited internal fraud as something they were concerned about jumped from 13 percent in 2016 to 31 percent in 2017, "a staggering 138 percent relative year-on-year increase," the authors write.</p><p>"There appear to be heightened levels of apprehension amongst financial decisionmakers," according to the report. "Equally as concerning is that almost 60 percent of financial decisionmakers simply did not know whether they had been impacted by [internal] fraud or not."</p><p>Occupational fraud, experts say, is an egalitarian crime; the culprit is just as likely to be a top executive as an obscure low-level employee. </p><p>"A fraudster doesn't look like a fraudster," Warren explains. "They look like everybody else. It legitimately could be anyone. It's not the person who looks sketchy. It could be the person who comes over to your house for dinner on the weekend." </p><p>When a fraudster is caught, coworkers are frequently shocked.</p><p>Historically, occupational fraud has been looked at as an accounting problem—numbers that don't add up tip off company leaders that something is wrong, Warren says. But ACFE's report shows otherwise. </p><p>"Part of our message is that it's not really an accounting problem, it's a behavior problem," Warren says. </p><p>In every edition of the report, ACFE has surveyed 17 different "red flag" behavioral indicators that tend to be associated with fraudsters. "What's fascinating is, every time we do the study, the same six rank highest," Warren says. </p><p>Those six red flag behavioral indicators are: living beyond one's means, financial difficulties, unusually close association with a vendor or customer, control issues and an unwillingness to share duties, divorce or other family problems, and a "wheeler-dealer" attitude or cultivated self-image. In at least 85 percent of the cases examined in the report, the fraudster displayed at least one of these red flags; in 50 percent of cases, he or she displayed multiple red flags. </p><p>Both male and female fraudsters exhibit these behavioral indicators, but often in different proportions, experts say. </p><p>"Studies in the past have shown that male perpetrators were more likely to be the wheeler-dealer-living-beyond-their-means type, whereas the women found themselves in some sort of financial distress and decided this was their easiest, or only, path for relief," says Shannon Walker, a fraud expert who is founder and CEO of WhistleBlower Security Inc. </p><p>ACFE's report bears out Walker's view. For female fraudsters, the most common red flag by far is financial difficulties; it occurs in 40 percent of cases, compared with only 24 percent of cases for males. And for males, the wheeler-dealer red flag was present in 16 percent of cases, compared with only 6 percent of cases for females. </p><p>"It does look like there are differences in the reasons why women steal, as opposed to men," Warren says. In addition, on average women commit smaller frauds than men do; losses tend to be 80 to 100 percent greater with men, he adds.  </p><p>Experts also say that security efforts to prevent occupational fraud can benefit from an understanding of the motivations and conditions underlying the crimes. </p><p>"Very few wake up in the morning and decide to rob their organization," Walker says. "Many have pressures to perform at work, pressures at home, or are suffering from various addictions that inform their decisionmaking processes."</p><p>Warren uses the "fraud triangle" model to explain the three conditions that are often present in occupational fraud incidents. </p><p>First, the employee is under financial pressure. Second, he or she is given an opportunity to commit fraud, such as access to company resources. Third, the employee rationalizes the theft to him or herself. </p><p>"They may think, 'I was borrowing it, I was going to pay it back,'" Warren says. Or, employees may feel the company owes them because they deserved a promotion and never received it.  </p><p>And if employees are on the verge of stealing, poor internal controls can help push them over the edge, Walker explains. </p><p>"Certainly, lack of controls or oversight contribute to the opportunity for those at risk to take that first step and steal," she says. "Once that wedge has been crossed, it becomes much easier for the fraudster to escalate."</p><p>In fact, the ACFE study found that nearly half of frauds examined in the report occurred because of internal control weaknesses. </p><p>For organizations that want to strengthen internal controls, Walker recommends maintaining consistent employee background checks before hiring; ensuring that sensitive duties are entrusted to more than one employee; implementing spot audit programs and conducting random audits on particularly vulnerable areas; and training employees about fraud prevention and the red flags they should be aware of.  </p><p>The other key to occupational fraud prevention lies in organizational culture, experts say.</p><p>Here, the tone is set at the top, Warren says. Organizational managers who always act ethically and treat all employees respectfully are leading by example; employees will often follow suit. </p><p>"But if leadership is pushing the boundaries, and wading into that ethical grey area, people will take cues from that," Warren says.</p><p>Walker agrees and says that some organizational leaders are taking steps to preempt bad situations by openly supporting a company code of conduct and ethics. </p><p>"Complacency and lack of a strong tone from the top are two of the most key indicators as to whether you are at risk," she says. "When management is seen as unengaged, unappreciative or apathetic, it creates an opportunity for a fraudster or potential fraudster to strike." ​</p>

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https://sm.asisonline.org/Pages/The-Fraudster-Down-the-Hall.aspx2018-08-01T04:00:00ZThe Fraudster Down the Hall
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https://sm.asisonline.org/Pages/Who’s-Who-in-Retail-Loss-Prevention.aspx2017-06-01T04:00:00ZWho’s Who in Retail Loss Prevention
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https://sm.asisonline.org/Pages/Facebook-Takes-Action-To-Limit-Spread-of-Propaganda.aspx2017-04-28T04:00:00ZFacebook Takes Action To Limit Spread of Propaganda
https://sm.asisonline.org/Pages/Wells-Fargo-To-Pay-$110-Million-To-Settle-Class-Action-Lawsuits.aspx2017-03-29T04:00:00ZWells Fargo To Pay $110 Million To Settle Class Action Lawsuits
https://sm.asisonline.org/Pages/Teller-Trouble.aspx2017-03-01T05:00:00ZTeller Trouble
https://sm.asisonline.org/Pages/Crime-of-Opportunity.aspx2016-12-01T05:00:00ZCrime of Opportunity
https://sm.asisonline.org/Pages/Playing-Clean.aspx2016-12-01T05:00:00ZPlaying Clean
https://sm.asisonline.org/Pages/Book-Review---Anti-Fraud-Program-Design.aspx2016-06-01T04:00:00ZBook Review: Anti-Fraud Program Design
https://sm.asisonline.org/Pages/Book-Review---Fraud-Identification-and-Prevention.aspx2016-06-01T04:00:00ZBook Review: Fraud Identification and Prevention
https://sm.asisonline.org/Pages/Upping-the-Ante-on-Corruption.aspx2016-03-01T05:00:00ZUpping the Ante on Corruption
https://sm.asisonline.org/Pages/Shrink-Expands.aspx2016-02-12T05:00:00ZShrink Expands
https://sm.asisonline.org/Pages/Defense-Corruption.aspx2016-02-03T05:00:00ZDefense Corruption
https://sm.asisonline.org/Pages/DOJ-to-Focus-on-Executives-in-Corporate-Investigations.aspx2015-09-10T04:00:00ZDOJ to Focus on Executives in Corporate Investigations
https://sm.asisonline.org/Pages/Book-Review---White-Collar-Crime.aspx2015-09-01T04:00:00ZBook Review: White Collar Crime

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https://sm.asisonline.org/Pages/Access-Under-Control.aspxAccess Under Control<p>​<span style="line-height:1.5em;">Companies spend significant resources on access control equipment. Estimates of the size of the global market range from about $6 billion to around $22 billion, and a recent ASIS survey indicates that 57 percent of U.S. businesses will be increasing access control spending through 2016. </span></p><p>Upfront costs are just the start. Security professionals take time to determine which doors need to be locked and when.  They decide where to install readers and decide how to pro­cess visitors. Despite the effort spent on the access control equipment layout and maintenance, over time the access control database can become mismanaged. Requests for tweaks to reader groupings and access levels are continuous. One group may want time restrictions for the janitorial crew; another group may need access to one door but want to restrict others. If these accommodations are made without regard for the overall system, over time a complicated tangle of access control levels is created. The next thing you know, security no longer controls access; access control takes charge of the organization’s security, resulting in a chaotic mess.</p><p>BB&T, a large financial services institution headquartered in Winston-Salem, North Carolina, has protocols in place that ensure appropriate and accurate administration of access control systems at its corporate locations. The Fortune 500 company has more than 1,800 financial centers in 12 states.  In addition, it has approximately 120 corporate buildings–data centers, operations centers, call centers, corporate and regional headquarters–that have access control systems. ​</p><h4>Challenges</h4><p>Regulatory developments over the last decade make it necessary to closely maintain access control data. The Health Insurance Portability and Accountability Act of 1996 and Gramm-Leach-Bliley Act of 1999 require health­care and financial organizations, respectively, to keep strict watch over sensitive and personal information. The Sarbanes-Oxley Act of 2002 forced a strengthening of internal controls within corporations. More recently, the Payment Card Industry Data Security Standard requires that companies keep tight control over credit and debit card data. </p><p>These regulations, as well as others that affect specific industries, have brought more scrutiny to the administration of access control data. Most large organizations, especially those in regulated industries, have experienced an increase in audit activity as it relates to physical access controls. This means that regular reviews of access reports are required in many cases. For this reason, it is critical that the data in a company’s access control database be clean and accurate.  </p><p>Numerous challenges can arise from failing to properly maintain an access control system. Maintenance lapses can result in thefts when, for example, terminated employees get into a facility. What good is an access control system if, due to negligence in maintaining the system, people can enter places they shouldn’t? If your access control database has been around for years and has turned into a Byzantine web of access permissions, what steps can be taken to get control over the data? </p><p>Access control database administrators must have an ongoing process of maintaining the accuracy of the data. A standards-based approach must be taken to manage any effective access control program. Standards include defining the types of users in the system–employees, vendors, visitors, temporary card users– and establishing credentials for which each of these user categories will be managed and reviewed. Once the user categories are defined, space definitions and ongoing maintenance procedures must be established. ​</p><h4>Database management</h4><p>BB&T categorizes its cardholders into three groups based on the users’ network login ID. There are employees and contractors with a company network login ID; vendors, tenants, and others without a company network login ID; and temporary users. BB&T uses the network login ID for employers and contractors because the network ID is also used in the IT security database. This allows security to match the IT access records to the physical access records. Human resource data was considered for this match, but the bank determined that many vendors, temporary employees, and contractors who have a BB&T network login ID are not included in its human resource system. Matching the network login ID covers a majority of the organization’s users. If the records do not match, the user’s access is terminated.   </p><p>For cards not involved in the matching process, BB&T identifies a company employee who can serve as a sponsor for each vendor and tenant. The company conducts quarterly reviews of those cards, during which the company sponsor ascertains whether the vendor or tenant employee still works for the third-party company and still needs the BB&T card.</p><p>All temporary cards in the system are assigned to the individuals who have the cards in their possession. The temporary cards may be used by visitors, trainees, vendors, and employees who forgot their badge at home. Information on the cardholder is housed within the access control database. Quarterly reports for all temporary cards are sent to one person who is responsible for ensuring that their temporary cards are accounted for.  ​</p><h4>Space</h4><p>BB&T has established criteria and definitions of the physical space in its environment and categorizes space into three categories: critical, restricted, and general. Criteria are established for each category of space. The critical category is reserved for high-risk, critical infrastructure areas, such as server rooms or HVAC sites. Restricted space is office space for departments that the company deems restricted. All critical and restricted space is assigned a space owner. The space owner is then responsible for approving or denying people’s access to that area. General access areas are common doors and hallways.</p><p>For each category of space, standards are established on how access is governed. For example, the data center standards might state that janitors or nonessential personnel are not granted access without an escort. Standards also dictate who can approve access to that space and how often access reports should be reviewed. For example, critical and restricted space reports are reviewed monthly or quarterly.</p><p>Access devices are grouped together based on the categories of space and the users that access the space. This streamlines the access request process and makes it easier for the requestors to understand what access they are selecting. Grouping as many readers together as possible minimizes the number of possible groupings meaning that there are fewer choices for those requesting access. It also makes it easier to ensure that access reports are accurate, and it simplifies the process of approving access and access report reviews. If all readers for critical space to a building are grouped together, only one approval would be required for critical space and only one report would need to be reviewed.  </p><p>However, in some cases, minimizing groupings may not possible. For example, one group of users may be allowed into the IT area but only a subset of that group has access to the server room that resides within the lab. In this case, groups would be categorized by the users rather than the readers.</p><p>It’s also important to make sure that access levels and device groupings don’t overlap. This can complicate the request process and the report reviews and could cause access reports to reflect an incomplete list of users who have access to a space. For example, in a building with three readers, grouping one may include the front and back doors, and grouping two may include the communications room. If, in addition to these two groupings, there is an overarching grouping three that includes all three readers, this could create a problem since each of the three individual readers belong to two different groupings. In this scenario, if a request is made to determine who has access to the communications room, rather than producing a report of the communications room reader group, an additional report of the group of all three readers would need to be provided. In many organizations, this second step is missed, causing an inaccurate representation of those with access to a specific area. This can be a major issue if discovered during an audit.</p><p>Another way to remedy this issue would be to run reader reports on individual doors, in this example, a reader report on the communications room only. Most access control systems allow for this type of report. However, in companies with a large number of individual card readers, this would require many more reports. The same users often need access to multiple doors, so combining them into groupings that don’t overlap makes more sense than running individual reader reports. As a rule, BB&T does not allow a reader that has been deemed critical or restricted to belong to more than one reader grouping. This ensures that access reports are accurate and complete.  It does, however, require that a user who needs access to a full building, such as a janitor or security officer, request access to each area of the building rather than requesting overarching access to the entire building. This is beneficial, not only for reporting reasons, but also because it requires that space owners approve all users who have access to their space and holds the space owners responsible for knowing who is entering their space. Controls in the report review process can be set up to ensure that a space owner does not remove access for a janitor or security officer. Some systems allow cards to be flagged and would require a higher level of scrutiny before access is removed. Nonetheless, this is a cleaner way to set up access levels and ensures that space owners will review a report of all users that have access to their space, which is what most auditors are looking for.   ​</p><h4>Clean-Up</h4><p>If an access control system has become muddled over time, a database clean-up is recommended. A good place to start is to deactivate all cards that have not been used in a specific timeframe, such as the previous six months. Thus there will be fewer cards to review. Then, security can find a common piece of data with another database in the company that provides a match of current employees. Human resource or information security data is best to determine whether active cardholders in the system still work for the company. Of the remaining cards for nonemployees, visitors, tenants, and contractors, security should research whether the card users can be associated with a manager or employee within the company. Security can work with these internal partners to implement an ongoing review of access cards. ​</p><h4>Maintenance</h4><p>Performing a regular match of human resource or information security data ensures that cards are deactivated for users whose information does not match that on the card. If a user is not captured in the match, that person should be assigned to a sponsor for quarterly review to determine whether any credentials need to be terminated. Access reports should be reviewed for all nongeneral space to ensure that users still need access to the designated areas. Such reviews should take place at regular intervals–not more than quarterly. An important piece of the access request process is to ensure that all necessary information is captured to support the new standards and to support the report review. For example, if the request is for a visitor, security should capture the name of the person who will have that card in their possession during the request.   ​</p><h4>Automation</h4><p>BB&T is working to upgrade the auto­mation of its access control request and audit reporting system by the end of 2015. It is considering software that automates the entire access control database management process from the onboarding human resource system to the access control system. This would include a software interface that would be fully integrated with the information security credentialing system. The ideal software would fully integrate with the access control system where approved access is automatically provisioned with no human intervention.</p><p>Cost is a major factor in implementing such automation. Some companies choose to automate pieces of the process. Some use a simple Web portal form that sends e-mails to approvers and ultimately e-mails the request to the team that provisions access or provides a dashboard for the access control team to view requests. Many companies have integrated with human resource or information security data to update their access control system, which allows for the automatic deactivation of cards for terminated employees, vendors, or contractors. Others have found a way to automate the report reviews. Few access control manufacturers provide these additional software tools in combination with their access control software. Some will work with or direct their customers to third-party solutions, while others are beginning to see the need for automation and are incorporating pieces into their standard software package, such as more robust reporting capabilities.  </p><p>These efforts may seem daunting, but once the standards are set and the database is cleaned up, ongoing maintenance is initiated, and some level of automation is implemented, the system will be under control. It is imperative that security professionals see beyond the equipment and installation and not rely solely on these for protection. A sound maintenance program ensures that, should access control processes be called into question, security can be confident that the company’s program is under control.  </p><p>--</p><p><em><strong>Briggette Jimenez, CPP,</strong> is physical security manager at BB&T where she manages the company’s security command center, security operations, and workplace violence prevention programs.</em></p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465
https://sm.asisonline.org/Pages/Training-Your-Team.aspxTraining Your Team<p>​</p><p>Whether the action is on the battlefield or the basketball court, you can be certain that the winning team owes its success in large measure to extensive training. Recognizing the importance of training to any team’s performance, the Cincinnati Children’s Hospital Medical Center set out to makes its own training program better. </p><p>The existing training program, which the director of protective services felt lacked specificity, consisted of one of the shifts’ veteran officers sitting with the new security employees and covering several department and hospital-specific policies along with administrative topics. Additionally, the new officers would be given several commercially produced security training videotapes to view, after which they were required to complete the associated tests. 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Under the new program, the officers now take a test both before training, to show their baseline knowledge, and after the training, to verify that they have acquired the subject matter knowledge; they must also successfully demonstrate the proper techniques to the instructors.</p><p>Orientation training. The orientation training phase begins with the new employees attending the hospital’s orientation during their first day at the facility. The security department’s training officer then sits down with the new officers beginning on their second day of employment. This training covers all of the basic administrative issues, including what the proper clock-in and clock-out procedures are, when shift-change briefings occur, and how the shift schedules and mandatory overtime procedures function.   </p><p>The training officer also administers a preliminary test to the new officers that covers 12 basic security subjects including legal issues, human and public relations, patrolling, report writing, fire prevention, and emergency situations. New employees who have prior security experience normally score well on the test and do not need to view security training tapes on the subjects. The officers must receive a minimum score of 80 percent to receive credit for this portion of the training. If an officer receives an 80 percent in most topics but is weak in one or two subjects, that officer is required to view just the relevant tapes, followed by associated tests.</p><p>All officers, regardless of the amount of experience, review the healthcare-specific tapes and take the related tests for the specific subjects including use of force and restraint, workplace violence, disaster response, bloodborne pathogens, assertiveness without being rude, and hazardous materials. Also included in the orientation training phase are classes covering subjects such as pepper spray, patient restraint, defensive driving, and the hospital’s protective services policies.</p><p>Site-specific training. During site-specific training, officers learn what is entailed in handling specific security reports. The shift manager, shift officer-in-charge, or the training officer explains each of the reports and has the new employee fill out an example of each. 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These training modules cover life safety, the research desk, the emergency department, exterior patrols, foot and vehicle patrols, and the command center.</p><p>The training council asked officers to participate in the creation of the computer-based training modules. The officers produced the training modules during their respective shifts when it did not interfere with other responsibilities.  </p><p>The group participation paid off. For example, the officers who created the command center and the emergency-department training modules not only spent several hours discussing what information should be included in the modules, but then allowed their creativity to flow by using the software to make these modules interactive. These particular modules include test questions of the material, and the program will respond appropriately to the employees as they answer the questions correctly or incorrectly. The volunteers also created tests for before and after an officer goes through each of the computer modules to track the effectiveness of the training.</p><p>Shift-change training. A major question with ongoing training is how to fit it into the officer’s routine. For most industries using shift work, difficulties arise when trying to carve out enough training time without creating overtime. The training council decided to take advantage of downtime that occurs as officers come to work ready for their shift to begin. They are required to show up six minutes before the shift. This time is now used for training.</p><p>The shift-change training is used to cover specific topics—already covered in some of the training phases—that can be easily encapsulated into a six-minute program. 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There were numerous quantifiable measurements that the council could use to evaluate the new training program, such as tracking the rate of disciplinary actions from the previous year to the current year. However, since the council desired to have a quick assessment of the training program changes, it decided to compare the after-training test scores to the before-training test scores for the computer-based training modules as well as the scores of the six-minute training tests. </p><p>To the council’s surprise, the initial tabulated scores resulted in an average before-training test score of 93 percent and an after-training test score of 95 percent. The council also found in many of the officers’ tests that they missed the same questions on both the before and after tests.</p><p>Based on these results, the council decided to make several changes. First, the test questions were reviewed and tougher questions were added. Based on the preliminary test score, the council felt that the questions were not challenging enough and might not indicate how competent the officers were with the subject matter. </p><p>The training council assigned each shift the task of revising the tests for their computer-based training modules as well as the six-minute training tests. The goal was to make the tests more challenging and to obtain more accurate assessments of the effectiveness of the training program. </p><p>The training council also reviewed how the different shifts were conducting the six-minute lessons. Managers noted that the shifts initially followed the schedule of the six-minute subjects from week to week, but then they began to conduct their own lessons without an accepted lesson plan or to forgo training altogether. </p><p>To avoid this problem, the training council determined that the training program needed to be more structured. The group created a schedule to indicate which class would be covered each week. One of the shift supervisors volunteered to take over the six-minute training program and formally structure it so that each shift would conduct training in a consistent manner.</p><p>The training council has plans to further hone the training program in the near future. The council plans to analyze the program us­ing other quantitative evaluative instruments such as an employee survey and a comparison of disciplinary action data from previous years. </p><p>In battle, it is said that an army fights as it has trained. Thus, commanders know the value of training. In the businessworld, though the stakes are different, training is no less critical to the success of the mission.</p><p>Ronald J. Morris, CPP, is senior director of protective services at Cincinnati Children’s Hospital Medical Center. Dan Yaross, CPP, is manager of protective services. Colleen McGuire, CPS (crime prevention specialist), is sergeant of protective services. Both Morris and Yaross are members of ASIS International.</p>GP0|#cd529cb2-129a-4422-a2d3-73680b0014d8;L0|#0cd529cb2-129a-4422-a2d3-73680b0014d8|Physical Security;GTSet|#8accba12-4830-47cd-9299-2b34a4344465