Contract and Procurement Fraud. Vendor Management

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1 Contract and Procurement Fraud Vendor Management

2 Introduction Organizations must take steps to reduce vendor fraud, including: Conducting vendor due diligence Managing vendor risks via contracts Ensuring vendors are legitimate (avoiding shell company schemes) 2 of 28

3 Vendor Due Diligence Controls for vendor master file management Vendor background checks Vendor questionnaires Vendor due diligence checklists Vendor monitoring Compliance committees to oversee the retention of any vendors Watchlists 3 of 28

4 Controls for Vendor Master File Management Set procedures for setting up new vendors and changing vendor master file records. Prevent employees responsible for the vendor master file from approving invoices or signing checks. Establish clear vendor master file naming conventions. Keep vendor records accurate and up-to-date. Monitor the application of the accounts payable policies on vendor master files. 4 of 28

5 Vendor Background Checks Review watchlists. Conduct a corporate registry search. Search politically exposed persons (PEP) databases. Verify the vendor s key individuals. Verify vendor s insurance. Verify any professional licenses. 5 of 28

6 Vendor Background Checks Confirm physical addresses. Perform site visits. Test the reputation of the vendor and its key individuals. Conduct a media analysis. Compare vendor addresses against employee addresses. 6 of 28

7 Vendor Background Checks Conduct interviews. Require W-9 forms before paying vendors. Review the vendor s policies and procedures on fraud, governance, and compliance. Review the vendor s financial data. Review the vendor s banking information. 7 of 28

8 Vendor Questionnaires Management should consider giving potential vendors a questionnaire requesting various types of information. The questionnaires should be written for each company s specific needs. 8 of 28

9 Vendor Due Diligence Checklist To help ensure that the vendor due diligence process is conducted in a refined fashion, purchasing companies should develop and use a vendor due diligence checklist. 9 of 28

10 Vendor Monitoring Use monitoring and auditing systems to detect criminal conduct by vendors. Base monitoring systems on the red flags of vendor schemes that pose the greatest risk. 10 of 28

11 Compliance Committee Establish a compliance committee to review and record actions and contracts relating to the retention of any vendors. 11 of 28

12 Watchlists Excluded Parties List System (EPLS) OFAC s List of Specially Designated Nationals and Blocked Persons List The Denied Persons List The Debarred Party List Nonproliferation Sanctions Lists The Export Administration Regulation (EAR) Entity List 12 of 28

13 Managing Vendor Risks Via Contracts Considerations in vendor contracts: Compliance with the law Professional standards Indemnification clauses Insurance Limits on liability Conflicts of interest Contract default, termination, and renewal A right to audit 13 of 28

14 Risk of Shell Companies Part of vendor management involves ensuring vendors are legitimate business enterprises. A shell company is a company that has no physical presence and generates little independent economic value. 14 of 28

15 Shell Company Schemes Involve the issuance of false invoices for products and services never delivered or rendered Perpetrated by vendors or employees Three-part process: Setting up the shell company Submitting an invoice Obtaining payment approval for the fraudulent invoice 15 of 28

16 Preventing Shell Company Schemes Segregate the duties of: Authorizing purchases Confirming purchases Authorizing payment Require purchase orders for payment. Create an approved vendor list and prohibit payment of invoices to any company not on the list. 16 of 28

17 Preventing Shell Company Schemes Have prospective vendors fill out a vendor data form. Verify the authenticity of contractors before making payments. Segregate duties of approving payments and adding/deleting names on the approved vendor list. Periodically compare budgeted expenses with actual expenses. 17 of 28

18 Preventing Shell Company Schemes Compare vendor addresses with employee addresses. Track unusual invoicing patterns. Train personnel to be alert to the red flags of fraudulent invoices. Prohibit use of vendors that do not have a physical address. 18 of 28

19 Red Flags of Shell Company Schemes Payments to contractors not on approved vendor list Vendors not located in business directories Vendor address that is: Not a street mailing address Residential Incorrect Multiple addresses 19 of 28

20 Red Flags of Shell Company Schemes Invoices for unspecified or poorly defined services Unnumbered or sequentially numbered vendor invoices Vendor uses unfamiliar contractors Vendors with similar names Vendor and procurement employee have similar or identical information 20 of 28

21 Red Flags of Shell Company Schemes Vendor fails to submit an EIN Unexplained increase in volumes of purchases Boilerplate contracts that have no clear definition of goods or services to be delivered Poor, illegible, or missing documentation supporting a vendor payment 21 of 28

22 Red Flags of Shell Company Schemes Large billings broken into multiple smaller invoices that fall just below a threshold limit An invoice with an even amount (round number) that is not expected or reasonable A check for an out-of-town vendor cashed locally Contracting employee shows interest in invoices submitted by a particular vendor 22 of 28

23 Detecting Shell Company Schemes Check vendor addresses against mail drop address lists. Search for new vendors that have high activity. Research unusually large expenses, unexplained variances in expenses between years, or expenses that exceed budgeted amounts. 23 of 28

24 Detecting Shell Company Schemes Compare all paid contractors to: Approved vendor lists Business directories Telephone reverse directories D&B listings Government business filings Determine if invoiced goods or services were received. 24 of 28

25 Detecting Shell Company Schemes Examine financial statements for variances in expenses that should correlate with revenue. Examine work product from consultants. Examine documentation for payments to contractors that provide services or goods that are difficult to verify. 25 of 28

26 Detecting Shell Company Schemes Conduct a background check to identify: Ownership of contractor Contractors with undisclosed outside business interests or front companies owned by the contracting employee Contractor with family ties with a procurement employee Procurement employees with unexplained increase in wealth or outside income 26 of 28

27 Detecting Shell Company Schemes Cross-check vendor contact information with that of: Employees Employees outside businesses Employees relatives residences and businesses Compare shipping addresses to: Employee addresses Addresses of other vendors 27 of 28

28 Detecting Shell Company Schemes Compare vendor EIN to employees : SSNs Outside business EINs Relatives SSNs Relatives business EINs Conduct an on-site audit of the vendor. 28 of 28

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