State of Kentucky Police Fraud Education and Awareness
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1 Fraud Education and Awareness Increasing Employee Fraud Awareness Joe Reed & Ralph Kimbrough University of Kentucky Internal Audit September 30, 2015 Agenda I. Introduction II. Fraud Awareness III. Fraud Detection IV. Outcomes 1
2 I. Introduction: UK Fraud Program Ethical Principles and Code of Conduct (Policies) Annual Fraud Training Proactive Activities (UKIA) Incident Reporting Investigation Responsibility I. Introduction: UK Fraud Team Media (Public Relations) Governance (Administration / Operations) Prosecution (Legal) Arrest (Police) Investigation (Internal Audit) 2
3 I. Introduction: Background / History No UKIA Calls or Collaboration (2004) Investigations Handled outside of UKIA (2004) Legal and HR Discussion (2005) The Call (Stores ) I. Introduction: Audit Timeline Stores June 2001 C. S. started working for B. C. because the Computer Store was moved under B. C M. R. (perpetrator) in charge of Stores and Computer Store July 14, 2005 Leather couches are delivered to warehouse from M. Furniture, allegedly one each was given to M. R. and S. Cr. as kickbacks. September 2005 M. R. delivers refrigerator to wife s and sister s place of employment September 2005 Bought a lot of microwaves to sell to students for their dorms. The students could not use wrong voltage (?) March 28, 2006 PO # Vinyl and maple cinnamon flooring ordered for $4, The Purchase Order is initialed by M. R. and charged to the Procard. Description changed to cover up purchase on 4/12/06. 3
4 I. Introduction: Audit Timeline Stores (Continued) August 29, 2006 Call made to compliance line regarding the disappearance of carpet and padding September 22, 2006 M. R., S. C. and S. Cr. placed on administrative leave pending an investigation of their activities in Stores. S. C. was placed on leave because he destroyed (shredded ) documents per M. R. s instructions. October 10, 2006 C. S. place on administrative leave pending an investigation into the activities in Stores. October 16, 2006 M. R. allowed to resign. II. Fraud Awareness 4
5 II. Fraud Awareness: University Policies Ethical Principles and Code of Conduct (GR or AR) Annual communication from Legal Counsel Incident Reporting BPM (Business Procedures Manual) Individual responsibility (BPM E-2-1) HR (Human Resources) Individual responsibilities (HR Policy #12) KRS (Kentucky Revised Statues) State laws (Chapter 514) II. Fraud Awareness: Training (Previous) UKIA created and introduced three seminars Cash Handling (2006) Partnership with Treasury Services ProCard (2006) Offered through 2011 Fraud (2007) Conducted annually 5
6 II. Fraud Awareness: Training Execution (Current) Fraud Seminars 8 to 9 times annually Business Officers Certification Training Advanced Fraud 2 times annually Reconciliations Web based On-demand II. Fraud Awareness: Client Communication Opening Meeting Previous / Similar Improper Activities Changes / Mission I/C Questionnaires Testing of weaknesses Closing Meeting Observations / Findings Process Weaknesses Discussed Results shared with process owners Testing of Weaknesses 6
7 III. Fraud Detection III. Fraud Detection Common Sources Employees Customer Anonymous Vendor Owner Competitor UKIA Sources Employee Tips Student Tips Audit Activity Hot Line Administration 7
8 III. Fraud Detection - Surprise Audits Unannounced Keys in on anticipated or known functional and entity weaknesses Standardized audit tasks and protocol (with some exceptions) Reports III. Fraud Detection-Inquiries Unit? Police and/or FBI collaboration University Legal Information Technology Unit Informing Administrators 8
9 III Execution of Fraud Investigation Inquires Review of concerns Communications Of validated concerns Investigations Performance of Investigation III. Fraud Detection: Employee Tip Audit evidence revealed that Y. s prepared invoices for the students participating in the program Invoices dated between 2008 and 2011 requested payment be made to the University of Kentucky. Invoices dated between 2012 and 2013 requested payment be made to the University of Kentucky/Y. UKIA located eight Invoice Authorization Forms. The invoices totaled $6,705. UKIA found no record of payment for these invoices (Y. or UKCD). Certificates Awarded for Non-Existent Program A fraudulent University document was created and authenticated with Y. s signature. 9
10 III. Execution of Fraud Investigation Audit Timeline Woodford County Farm 12/3/08 Incident Notification Employee call to Human Resources 12/18/08 B. P. informed UK Police of theft of 2,902 gallons of fuel 1/7/09 Police Report and Interview of M. P. (perpetrator) and A. M. 1/7/09 M. P. suspended pending investigation 1/13/09 UK Police notified IA of fuel theft at Woodford County Farm (WCF) 1/14/09 Date of M. P. s Termination 3/26/09 IA interview of S. R. at WCF re: list of items stolen from WCF 3/31/09 IA interview of S. H. re: information on the tobacco harvesting contracts 4/7/09 Interview of A. S. of M. Farm bought straw directly from M. P. M. Farm faxed cancelled check to IA. 5/8/09 Closing Presentation to College of Agriculture IV. Outcomes 10
11 IV. Outcomes - General UKIA unit audit Unit training Discipline of Unit Management Review / Changes in policies and procedures Process Owner changes Conclusion 1 st & 3 rd Tuesday - Compliance meeting 2 nd week - Fraud Seminar Last Thursday of Month - RMAC Committee 2 times annually - Advance Fraud Monthly - Cash Handling Training Ongoing Issues Group 11
12 THANK YOU! 12
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