TOOLS FOR FRAUD DETERRENCE AND DETECTION BUILDING A HOUSE OF CARDS: USING THE REVERSE ENTRY TO HIDE FRAUD
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1 TOOLS FOR FRAUD DETERRENCE AND DETECTION BUILDING A HOUSE OF CARDS: USING THE REVERSE ENTRY TO HIDE FRAUD Financial statement accounts can, when used together in a specific way, perpetrate fraud and even cleanse financial statements of the occurrence of fraud. Case in point: A debit to accounts payable and a credit to expense in the same period have the essential impact of reducing both payables and expenses in a given period. Done in increments appropriate for the period and size of the financial statement balances, a fraud of this nature could operate for an extended period of time. This session is designed to focus on the lesser-covered concept of using the method of reversal entries as normal accrual entries to strategically alter account balances. ADAM K. BOWEN, CFE, CPA, CMA, CFF Manager of Forensic Audit VION Investments Atlanta, GA Prior to joining VION, Bowen held the position of advisory manager with KPMG LLP s Atlanta Office, providing forensic services to clients both domestic and international. Bowen has also held internal controls and compliance positions with Southern Company and worked in small and boutique accounting firm environments, providing services to clients ranging in size from individuals to small businesses and municipal governments. Bowen was a contributor to Fraud Casebook: Lessons from the Bad Side of Business (2007 Wiley), authored by Joseph T. Wells, and Managing the Risk of Fraud and Misconduct (2011 McGraw Hill). Association of Certified Fraud Examiners, Certified Fraud Examiner, CFE, ACFE, and the ACFE Logo are trademarks owned by the Association of Certified Fraud Examiners, Inc. The contents of this paper may not be transmitted, re-published, modified, reproduced, distributed, copied, or sold without the prior consent of the author. 2014
2 What is universally understood about fraud examination and financial statements? Fraud examiners need not have a thorough understanding of financial statement mechanics to uncover fraud. Targeted fraud ratios have been postulated to identify the presence of fraud in financial statements. Journal entries are the primary mechanism to interact with the statements. Entries are routine matters and can occur in counts of the thousands or millions depending on the entity size. Entries often follow a predictable pattern with uniform relationships between accounts. Where expected relationships deviate, fraud examination techniques can be employed to understand why. Why would predictable journal entry patterns deviate from expectations? Correction of an error Period adjustments Adjustment in the chart of accounts Changes in accounting policy for certain transactions Changes in the business or business environment Possible inappropriate manipulation of balances What is the motivation for manipulating account balances through journal entries? Adjustment of balances to improve perceived financial performance (EPS) Shifting of balances from one account to another to cover other manipulation Re-alignment of balances across segments of the balance sheet and income statement to meet covenants Pro forma manipulation to obtain credit or other equity infusion
3 Transfers across the statements to rid one account of a burden, such as transferring balances from accumulated depreciation to unearned revenue, changing a reduction in assets into a prospective revenue stream (even if classified as a liability) What is key about the reversal entry? Reversal entries are used to adjust account balance and, often, to correct errors in the original booking of transactions. Reversing an entry is as simple as making the original entry in a reverse fashion to reinstate the original state of the accounts. Reversal entries can be easily explained as corrections. Calculation error can lead to legitimate entry reversal. Reversal entries can be powerful tools for fraud perpetration when used appropriately and explained appropriately. Reversal entry fraud differs from journal entry fraud. Reversal entry fraud backtracks on the original transaction where journal entry fraud creates a new transaction to perpetrate a fraud. Sometimes both are used in conjunction with one another, often with reversal entries as the first step. The Scheme of the Reversal Entry: A Scenario Using Only Reversal Entries Reversal entries are used to adjust account balances for an original and specified transaction, but they can be used to adjust multiple transactions in one entry. Supporting documentation for the adjustment is often required by currently expected accounting procedure. Additionally, current practices often require supervisory level approval for entries that are reversed. This is not true in all organizations where a master level journal entry accountant may exist in the organization
4 Investigatory methods into this type of fraud should focus on the master journal entry accountant, if one exists. The approver of an entry might or might not be the preparer of the entry. And, in most cases, a master level journal entry accountant can create and complete journal entries without higher level approval. Period-end entries can be the commonplace for improper reversal entries. As accruals are being made at a higher level during this period, a reversal could be mistaken as ordinary. Consider the following: Eon, Inc. employs a small accounting staff with a master level journal entry accountant. Account balances are reviewed by management for variances outside of pro forma expectations, but individual journal entries are not reviewed. Robert is the master level journal entry accountant. Robert begins perpetrating a multi-period fraud within the balance sheet, which has flowed through to the income statement where it is closed each period through summary closing entries to retained earnings. Eon receives invoices through both electronic submission and paper submission. When an invoice is received, it is accumulated in an accounts payable holding account and in an expense account called un-coded invoices or UCI for 15 days and then paid. During this time, invoices are distributed to approvers for expense coding and payment. Once the batch is approved and paid, any remaining invoices are transferred to the main accounts payable master account and remain in the UCI expense account. As rolling approvals come to accounting on the remaining UCI invoices, they are
5 paid and transferred to the appropriate expense account per the approval. In any given 15 day period, approximately $5 million in unpaid invoices remain in the UCI expense account awaiting approval and coding. At the end of the period, the amount remaining in the UCI account is approximately $7.7 million in unpaid invoices. These invoices represent period expenses that should automatically flow-through to the income statement in a manner consistent with other (unclassified) expenses. Since they have yet to be paid, but still stand as incurred, they should simultaneously remain in accounts payable for final approval and coding. $7.7 million currently represents 24% of Eon s outstanding accounts payable balance of $32 million. Loan covenants require Eon s accounts payable balance to stay below $25 million for the period pending. Robert must adjust Eon s accounts payable account to meet the covenant requirement. To do so, he debits accounts payable for $7.7 million reducing the balance to $24.3 million. Correspondingly, he credits the UCI expense account by $7.7 million to bring the balance to zero at the end of the period. Robert does not provide documentation with his entry file. He notes in his personal steno pad that he made this adjustment to properly state accounts payable. He further notes he has adjusted the UCI expense account by the same amount to eliminate falsely submitted invoices per approver feedback. Although Robert has received no feedback from individual approvers he uses this rationalization
6 under the pretense that no feedback means not valid. Eon s financial statements reflect accounts payable at $24.3 million, and expenses are understated by $7.7 million. However, the invoices and their corresponding liability and expense classification still exist. Valid invoices will ultimately result in approvals or inquiries from vendors when not paid. To pay these invoices, accounting will need to utilize the accounting system to issue cash payments, which will present a misbalance of the accounting equation in subsequent periods. The foundation for the house of cards has begun with one reversing journal entry. What has Robert done? Robert was aware that Eon would be in violation of debt covenants if accounts payable exceeded $25 million. He used unapproved and un-coded invoices as a basis for reversing expenses and decreasing the balance of accounts payable. Robert made this entry in an initial period or the inception period. Has Robert properly calculated how his actions will impact future periods or is he only worried about today? How will these actions impact financial reporting for Eon tomorrow? What is Robert s motivation for this perpetration? Is he acting alone or collusively?
7 The Scheme of Correction: A Scenario Using Fictitious Entries as a Cover In the previous example, Robert adjusted the books of Eon on both the balance sheet and income statement to reduce both expenses reported and liabilities reported. This is the first period in which Robert has made one of these entries. However, the invoices still exist. Vendors submitted them for payment and there is evidence of them electronically, in paper format and being distributed to approvers via for review. Robert might not have contemplated that the invoices would ultimately need to be paid and that this action would require use of the accounting system to accomplish. In fact, this is what has already begun to occur in period two: Eon, Inc. has begun to receive invoices for period two and has begun the 15 day process of booking them to the accounts payable holding account and the UCI account to manage them for the period, facilitate approvals, and transfer UCI invoices to their proper expense accounts. However, $7.7 million in invoices from the prior period still remain outstanding but not book due to Robert s reversing entry at the end of period one. Eon is again subject to the same covenant on accounts payable of $25 million for the period. Management expects to have no issue meeting this liability covenant, even though they were close in the prior period. Robert and the entire accounting team is issued an from management thanking them for their diligence in processing invoices for payment and assisting the company in meeting contractual obligations to lenders
8 However, this period becomes more complex for the accounting team, especially Robert. Approvals from the prior $7.7 million in invoices begin to arrive and accounting issues payment per policy, crediting cash and debiting accounts payable. Given that it is widely believed that the UCI invoices from the prior period were closed out as Other Expense on the income statement, Robert feels some relief that the cash in and accounts payable down movement of the old invoices will provide the company with sufficient cushion to meet debt covenants. As period-end approaches, $6.3 million of the original $7.7 million in reversed invoices have been paid by Eon, in addition to $4.7 in current period invoices paid and $3.5 million remaining in the UCI and accounts payable accounts. The structure of the current situation: $6.3 million paid (of $7.7 originally reversed) $4.7 million in current invoices paid $11 million paid in cash during the current period $11 million paid against accounts payable master account per policy $3.5 million unpaid from current period in both AP and UCI $24.3 million in opening AP balance in period two $24.3 million balance + $3.5 current period unpaid - $11 million paid $16.8 anticipated ending accounts payable balance What is Robert s current situation with Eon? Robert s $7.7 million adjustment in period one has resulted in Eon s cash payments of invoices that were reversed out of both accounts payable and expense
9 Although Robert may have temporarily dispensed with concern about the expenses associated with the $7.7 million, their resulting cash payments and entries against accounts payable has resulted in a closing balance of AP that is 30 percent lower than the prior period. Management expects to be within pro forma forecasts of contractual obligations, and last period was dead on for profitability and cutting close for current liabilities. Eon has expended higher than anticipated cash levels during this period, without resulting expenses in financial reporting. The house of cards is rocky; eventually accounts payable could drop to a debit balance if outstanding invoices, in addition to his reversed invoices, are paid. Adjustment of the accounts will be necessary, but how? Robert has created his house of cards. To compensate for the cash amounts spent, he must adjust the financial accounts to correct for the imbalances amount the other balance sheet accounts. If low cash balances without corresponding expenses or an appropriate account payable balance, suspicion will arise at both the management and lender level. Robert must act; if he begins to add some or all of the $6.3 million, the financial statements may appear more presentable. Robert is considering bringing $5 million back onto the balance sheet and the income statement so that he can bolster accounts payable and expenses. He is considering how he can adjust the accounts and which ones to adjust. He is unsure of the variance tolerances in the expense account; if he raised the expense accounts out of variance, or doesn t raise
10 accounts payable enough, his house of cards could fall. Robert decides the best course of action is to make a $5 million entry to increase accounts payable. He debits ten income statement accounts he thinks are the most susceptible in increments of $500,000 each, including: Sales and Administrative Expenses Fuel Charges Software Licensing General Marketing Project Marcus Development Foreign Executive Travel Lease Expense Telephony Infrastructure Server Maintenance Contractor Expense Robert spreads his expense entries across multiple sub-accounts in each of the income statement parent accounts in a single journal entry using amounts that are not rounded. However, he is rounding on each of the ten expense accounts. In each account, he makes an entry to no less than five sub-accounts. With this scheme, Robert believes he has increased accounts payable to a safely explainable amount. He is confident this will correct the situation from period one and not cause any further issues. Where is Robert at the end of period two? Robert has made at least 50 subaccount entries to the income statement and a balance sheet entry to accounts payable, totaling $5 million. Robert has used a fictitious entry to cover his tracks from a reversal entry in the prior period to reduce the
11 accounts payable account to beneath covenant requirements. Robert has increased his detection exposure significantly by adding to the accounts payable balance and increasing expense accounts. Expense account reviewers could possibly call into question the charges to their pro forma budgets from the charges made to these accounts. Will this correct the period one issue or cause additional problems? Is Robert acting on his own motivation, or is he being directed? Where are the holes for detection that a fraud examiner could identify in period two? THE SCHEME: CARRY-ON OR HOUSE WINS? At Eon, Inc., Robert has built a house of cards in only two periods. What started as a simple reversal entry has become a correction scheme. Robert has now employed a multi-account journal entry in an attempt to cover his tracks and bolster account balances that are artificially low because of his actions. With his corrections, he might be able to continue perpetrating his house of cards for many more periods. The benefit of the scheme was only in the inception period; he is now working overtime to adjust his actions back into Eon s financial system. How would you examine Robert to determine if financial malfeasance had occurred? How to Uncover Robert s Scheme Robert will only be able to maintain his scheme for so long; he is open to detection by his own entries
12 Robert might not be initially identified as a perpetrator; however, he is the master journal entry accountant and a good lead. Eon will have a detection trigger in the form of one of the following: An identified cash loss (why did we pay out so much cash this month, and to whom did we pay it?) A variance detection in one of the accounts that Robert made an entry to (why do I have an additional $500,000 charged to my account?) Why did we miss our debt covenant of $25 million in accounts payable this period? (Robert was unable to maintain his entries, or he might have wanted to get caught) Income statement analysis (why was Other Expense so much higher this period? It was hardly anything last period ) When a detection trigger happens, identifying the target accounts will be crucial. In the case of Eon, the target accounts were accounts payable, UCI/Other Expense, and the ten income statement accounts. Seek out entries that are non-characteristic for a specific account. Reverse entry fraud is simply the beginning. In many situations, a fraudster can make immaterial adjustments and escape detection. Collusion increases the probability that the perpetrators will elude detection. A multitude of accounts can be manipulated fictitiously, but only those that have normal relationships can be manipulated in a reverse manner, which leads to the fictitious nature of the follow-on. Where fraud is conceived by reversing entries, it is further perpetrated by fiction, acknowledging that the first
13 reversing entry was indeed fictitious. In the end, the house will win and the cards will fall. If Robert s scheme follows its natural course, it is only a matter of time before his actions are discovered, time enough to damage his company s financial reporting
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