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Organisations traditionally focus on
internal controls to battle fraud and misconduct. Although I think this is both
a great place to start and a good thing to do, internal controls will not offer
complete protection against fraud. Unfortunately, many organizations have no
insight into the behavioural factors of employees. These organizations tend to
take a legalistic approach and focus primarily on battling fraud by adding more
“opportunity” controls (Cressey, 1973). Doing so might even result in
bureaucratic and costly internal control systems with many sign-offs, yet they
still experience incidents of non-compliance. An example of this effect is the
approach that some companies have made toward implementing the Sarbanes-Oxley
internal control frameworks. The frameworks required a lot of paperwork, yet
according to many employees, it added little in terms of actual control against
unethical behavior ultimately having an adverse effect because of this
ineffectiveness (Dittmar, 2006).
I believe a more appropriate way for fraud
management will also need to incorporate the behavioral factors of the Fraud
Triangle, namely the “Pressure” and “Rationalization” factors. In particulars,
to assess the pressure factors is to have an integrity survey with employees.
The following step in training employees for them to be aware of and alert for
possible rationalisations is to provide dilemma training.
By establishing such an approach to
internal control will lead to a much more effective internal control and also a
more cost efficient one as well.
Reference
Donald R. Cressey, Other People's Money (Montclair: Patterson Smith, 1973) p.
30.
Dittmar, S. W. (2006). The Unexpected Benefits of
Sarbanes-Oxley. Harvard Business Review.
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