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Fraud Prevention for Nonprofits:
Avoiding Fraud Schemes and Fraudsters
Richard Wolf, CPA, CGMA, CFE
Introductions
• CPA, CGMA, CFE
• Principal at Gross
Mendelsohn
• 19 years of public
accounting experience
in the nonprofit sector
Today You’ll Learn
• Why nonprofit fraud education matters
• Common fraud schemes in nonprofits
• Why some employees commit fraud
• General fraud prevention and deterrence
• What to do if an issue is discovered
WHY NONPROFIT FRAUD
EDUCATION MATTERS
Susceptibility
Disclosure requirements
Cost
Public image
Susceptibility
Disclosure requirements
Cost
Public image
Susceptibility
Disclosure requirements
Cost
Public image
Susceptibility
Disclosure requirements
Cost
Public image
Form 990 – Return of Organization Exempt
from Income Tax
Nonprofits must explain the
nature of a diversion of assets.
Initial
Detection of
Occupational
Frauds
Type of Victim Organization
Type of Victim Organization
Size of Victim Organization
Size of Victim Organization
Industry of
Victim
Organization
Schemes by Industry
Control Weaknesses That Contributed
to Fraud
Perpetrator’s
Department
Non-Fraud-Related Misconduct
Human-Resources-Related Red Flags
COMMON FRAUD SCHEMES IN
NONPROFITS
Billing Schemes
False invoicing via shell companies
False invoicing via non-accomplice
vendors
Personal purchases with company funds
Billing Schemes
False invoicing via shell companies
False invoicing via non-accomplice
vendors
Personal purchases with company funds
Billing Schemes
False invoicing via shell companies
False invoicing via non-accomplice
vendors
Personal purchases with company funds
Billing Schemes
False invoicing via shell companies
False invoicing via non-accomplice
vendors
Personal purchases with company funds
Red Flags for
Billing Schemes
Detection of Billing Schemes
Fraud Prevention: Billing Schemes
• Review vendor list
• Approval by multiple employees
• Analyze vendor purchase
Types of Check Tampering
Forged maker
Forged endorsement
Altered payee
Authorized maker
Types of Check Tampering
Forged maker
Forged endorsement
Altered payee
Authorized maker
Types of Check Tampering
Forged maker
Forged endorsement
Altered payee
Authorized maker
Types of Check Tampering
Forged maker
Forged endorsement
Altered payee
Authorized maker
Types of Check Tampering
Forged maker
Forged endorsement
Altered payee
Authorized maker
Altered Payee - Example
The majority of check tampering
schemes do not consist of a single
occurrence but instead continue over
an extended period of time.
Red Flags for
Check Tampering
Schemes
Detection of Check Tampering
• Account analysis through bank cut-off
statements or online access
• Bank reconciliations
• Examine for possible alterations
• Examine cancelled checks and review
endorsements
Fraud Prevention: Check Tampering
• Bank assisted controls
• Physical tampering prevention on checks
• Avoid pre-signing checks
• Check cutting
• Mail delivery
Expense Reimbursement Schemes
Mischaracterized expenses
Overstated expenses
Fictitious expenses
Multiple reimbursements
Expense Reimbursement Schemes
Mischaracterized expenses
Overstated expenses
Fictitious expenses
Multiple reimbursements
Expense Reimbursement Schemes
Mischaracterized expenses
Overstated expenses
Fictitious expenses
Multiple reimbursements
Expense Reimbursement Schemes
Mischaracterized expenses
Overstated expenses
Fictitious expenses
Multiple reimbursements
Expense Reimbursement Schemes
Mischaracterized expenses
Overstated expenses
Fictitious expenses
Multiple reimbursements
Detection of Expense Reimbursement
Schemes
• Review and analysis of expense accounts
• Detailed review of expense reports
Fraud Prevention: Expense
Reimbursement Schemes
• Clearly defined expense reimbursement
policies and procedures
• Detailed review of expense reports
Types of Payroll Fraud
Ghost employee schemes
Falsified hours and salary schemes
Commission schemes
Types of Payroll Fraud
Ghost employee schemes
Falsified hours and salary schemes
Commission schemes
Types of Payroll Fraud
Ghost employee schemes
Falsified hours and salary schemes
Commission schemes
Types of Payroll Fraud
Ghost employee schemes
Falsified hours and salary schemes
Commission schemes
Detection of Payroll Schemes
Fraud Prevention: Payroll Schemes
• Segregation of duties
• Periodic review and analysis of payroll
WHY SOME EMPLOYEES COMMIT
FRAUD
10% Will never steal
10% Will steal whenever possible
80% May steal based on circumstances
BEHAVIORAL RED FLAGS
In 92% of fraud cases reviewed,
at least one common behavioral
red flag was identified
Living Beyond Means
Living Beyond Means
Financial Difficulties
Living Beyond Means
Financial Difficulties
Unusually Close Association
with Vendor/Customer
Unwillingness to
Share Duties
Living Beyond Means
Financial Difficulties
Unusually Close Association
with Vendor/Customer
Unwillingness to
Share Duties
FRAUD PREVENTION
How can I prevent fraud
in my organization?
Effective management oversight | Establish a tone at the top |
Increasing the perception of detection | Segregation of duties
(as best as possible for the size of the organization) | Bank
reconciliations should be done on a monthly basis and
appropriately reviewed | Enforcement of mandatory vacations |
Job rotation policy | Conduct fixed asset inventories | Perform
background checks on new employees and volunteer leaders |
Fraud risk assessment by management to determine areas of
highest risk | Perform self-audits; don’t assume your year-end
audit will catch instances of fraud | Acquire proper insurance
coverage | Tip line – should be anonymous, managed by a 3rd
party, and available 24/7 | Ethics programs and training |
Employee support programs | Clearly defined code of conduct
There are many ways
to prevent fraud…
Effective management oversight | Establish a tone at the top |
Increasing the perception of detection | Segregation of duties
(as best as possible for the size of the organization) | Bank
reconciliations should be done on a monthly basis and
appropriately reviewed | Enforcement of mandatory vacations |
Job rotation policy | Conduct fixed asset inventories | Perform
background checks on new employees and volunteer leaders |
Fraud risk assessment by management to determine areas of
highest risk | Perform self-audits; don’t assume your year-end
audit will catch instances of fraud | Acquire proper insurance
coverage | Tip line – should be anonymous, managed by a 3rd
party, and available 24/7 | Ethics programs and training |
Employee support programs | Clearly defined code of conduct
There are many ways
to prevent fraud…
CASE STUDY
Title: Director of Finance
Schemes Involved: Fraudulent checks
and wire transfers; altered salary and
duplicated paychecks; expense
reimbursements
Length of Fraud: 7 months
Title: Director of Finance
Schemes Involved: Fraudulent checks
and wire transfers; altered salary and
duplicated paychecks; expense
reimbursements
Length of Fraud: 7 months
Amount Lost: $161,750
Lessons Learned
• Lack of segregations of duties
• Lack of oversight controls and financial
reviews, including review of bank
reconciliations
• Importance of fidelity bond coverage
• Too much trust placed in individual
WHAT DO I DO IF AN ISSUE IS
DISCOVERED?
Interviews
Selection of investigative team
Evidence preservation
Evidence gathering
Reporting
Interviews
Selection of investigative team
Evidence preservation
Evidence gathering
Reporting
Interviews
Selection of investigative team
Evidence preservation
Evidence gathering
Reporting
Interviews
Selection of investigative team
Evidence preservation
Evidence gathering
Reporting
Additional Items to Consider
• Consult employment counsel before
attempting to recover any funds from final
paycheck or vacation time
• Need to manage internal and public
disclosure
Download
the Webinar
CLICK HERE
Contact Me
Richard L. Wolf, CPA, CGMA, CFE
rwolf@gma-cpa.com | LinkedIn
Gross, Mendelsohn & Associates
36 S. Charles Street, 18th Floor
Baltimore, MD 21201
www.gma-cpa.com
800.899.4623
Feel free to contact us anytime with questions.

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