ACFE CFE-Fraud-Prevention-and-Deterrence Certified Fraud Examiner - Fraud Prevention and Deterrence Exam Exam Practice Test

Impact of Reporting to Law Enforcement:

Reporting fraud incidents to law enforcement demonstrates a zero-tolerance approach, acting as a deterrent to potential fraudsters.

It also ensures that perpetrators face legal consequences, discouraging others from engaging in fraudulent activities.

Prevention Mechanism:

The public nature of such actions signals organizational commitment to ethics and integrity, enhancing its reputation and strengthening internal controls.

Supporting References:

ACFE guidelines advocate for reporting fraud to appropriate authorities as part of an effective fraud prevention strategy​​.

Behaviorist Theories on Reinforcement:

Positive reinforcement is the most effective way to encourage desired behavior by providing rewards for compliance.

Analysis of Options:

B. Public criticism:May create resentment and decrease morale.

C. Loss of paid time off:A punitive measure that may not motivate improvement.

D. Demotion:Effective for extreme cases but harsh and potentially counterproductive for minor errors.

Conclusion:Offering a bonus for perfect reconciliation aligns with behaviorist principles of positive reinforcement.

Findings from the 2020 Report to the Nations:

A. Complaints about management:Not the most common red flag; lifestyle changes, such as living beyond means, are more common.

B. Gender of fraudsters:The report consistently shows that men commit more occupational frauds than women.

C. Median losses by executives vs. staff:Losses caused by executives are significantly higher.

D. Past offenses:Most fraudsters do not have a prior fraud-related disciplinary history.

Conclusion:Option B aligns with the findings of the 2020 Report to the Nations.

Regulatory and Legal Misconduct:

This category includes practices that violate laws or regulations, such as anti-competitive behavior, insider trading, and conflicts of interest.

Why A is Correct:

Fraudulent customer payments are typically categorized under operational or financial fraud, not regulatory and legal misconduct.

Why Other Options are Incorrect:

B, C, and D:These practices involve violations of regulations or legal obligations, directly aligning with regulatory and legal misconduct​​.

References for All Questions:

ACFE Fraud Examination Guide and related professional standards​​.

International and jurisdictional auditing standards for public-sector auditors​​.

COSO and governance frameworks on fraud risk management​​.

Integration of Fraud Risk Assessment in Audits:

The fraud risk assessment provides valuable input but does not replace the auditor’s independent responsibility to identify and assess fraud risks.

Why B is Correct:

Professional auditing standards require auditors to perform their own risk assessments, and the fraud risk assessment is only a tool to enhance this process.

Why Other Options are Correct:

A, C, and D reflect appropriate uses of fraud risk assessments in the audit process, such as increasing awareness and designing effective audit tests​​.

References for All Questions:

ACFE Code of Professional Ethics and Fraud Examination Guide​​.

COSO frameworks for corporate governance and fraud risk management​​.

Standards for incorporating fraud risk assessments into the audit process​​.

Purpose of Anti-Fraud Education:

Education is most effective when employees understand the real consequences of fraud. Providing examples of prior incidents reinforces the importance of compliance.

Analysis of Other Options:

A. Include detection procedures:While this can increase awareness, it risks exposing sensitive controls.

C. Restricting to formal mechanisms:Education should be flexible and incorporate informal, ongoing messaging.

D. Executives and professionals only:While they play an essential role, education should engage employees at all levels.

Conclusion:Including examples of prior misconduct effectively conveys the seriousness of fraud prevention.

 Principle Overview:

Responsibility pertains to the duty of an organization to act in the best interest of society, ensuring sustainable and ethical practices that benefit all stakeholders, including employees, customers, and the environment.

 Corporate Governance Definition:

Corporate governance frameworks emphasize corporate responsibility as a key pillar for maintaining societal trust and long-term value creation.

 Why Responsibility is Correct:

While transparency, fairness, and accountability are essential, responsibility uniquely emphasizes societal interests and ethical conduct​​.

 ACFE Code of Professional Ethics:

The ACFE Code of Ethics prohibits fraud examiners from making absolute statements about the absence of fraud. Fraud cannot be definitively ruled out based on an examination's findings.

 Why B is Correct:

Stevens cannot state that the organization is "free of fraud," as fraud detection is inherently limited by the scope and methods of the examination. Such a statement could mislead stakeholders and compromise ethical standards​​.

Internal Auditor's Role in Fraud Risk Management:

Internal auditors are not directly responsible for establishing or maintaining anti-fraud controls (Option D). This responsibility lies with management.

They are also not responsible for obtaining reasonable assurance that financial statements are free of fraud (Option A). This is the role of external auditors.

Oversight of management's fraud risk actions (Option B) is primarily a governance role, not the auditor's direct responsibility.

Internal auditors focus on identifying and assessing fraud risks, evaluating controls, and recommending further action when necessary.

Conclusion:Option C aligns with the internal auditor's responsibilities as per the standards outlined in the ACFE's fraud risk management framework.

 Theory of Differential Association:

This theory suggests that criminal behavior is learned through interaction with others, primarily within intimate groups.

Principles of the theory include:

Learning through communication.

Acquiring criminal knowledge similarly to other forms of learning.

 Why A is Incorrect:

General needs and values, such as poverty or desire for wealth, do not directly explain criminal behavior under this theory. Instead, the behavior is attributed to learned influences from others.

 Clarification of Other Options:

B, C, and D accurately reflect the principles of differential association​​.

Communication of Fraud Risk Assessment Process:Effective communication ensures that employees understand the objectives and importance of the fraud risk assessment process. The following practices contribute to its success:

A. Personalization:Personalized communication increases engagement by making the information relevant to employees' roles and responsibilities.

B. Appropriateness to Culture:Aligning the communication format with the organization's culture ensures clarity and resonance.

C. Visibility:Disseminating communication broadly reinforces its significance and encourages widespread participation.

Why All Options are Correct:

Fraud risk assessments require buy-in and participation across all levels of the organization. Combining personalization, cultural alignment, and visibility creates an effective communication strategy.

Conclusion:All three practices—personalization, cultural appropriateness, and visibility—are critical for effective communication.

Fraud Reporting Program Best Practices:

Ensuring anonymity encourages employees to report fraud without fear of retaliation. This enhances the effectiveness of the reporting program.

Why D is Correct:

Communicating confidentiality builds trust and increases participation in the fraud reporting program.

Why Other Options are Incorrect:

A: Fraud risks are not limited to organization size.

B: Restricting reports to immediate supervisors may create barriers.

C: Holding employees accountable for unsubstantiated tips discourages reporting.

Each scenario involves violations of the ACFE Code of Professional Ethics including unauthorized disclosure, failure to exercise due professional care, and inclusion of information outside of the scope of the engagement.

“CFEs must demonstrate a commitment to integrity and objectivity, avoid conflicts of interest, perform assignments with due diligence, and comply with lawful orders, balancing client confidentiality with legal obligations.”

 Purpose of Fraud Risk Assessment:

Fraud risk assessment aims to identify vulnerabilities and evaluate the organization's exposure to fraud risks. It does not specifically provide an estimate of fraud losses.

 Why D is Correct:

Estimating fraud losses is not a standard objective of fraud risk assessments; rather, they focus on identifying and mitigating risks.

 Why Other Options are Correct:

A: Employee behavior is a critical factor in fraud risk.

B: Fraud awareness is a key outcome of the assessment.

C: High-risk designations indicate vulnerability, not confirmed fraud​​.

Comprehensive and Detailed in Depth Explanation:

The Treadway Commission emphasized strengthening the internal audit function as a key fraud deterrent. This includes ensuring auditors have adequate resources, authority, and independence to carry out their duties. While formal structures like audit committee charters are useful, the commission specifically focused on functional empowerment of internal audit.

Corporate Governance Requirements for Public Corporations:

Publicly traded companies must adhere to the listing standards of the stock exchanges where their shares are traded (e.g., NYSE or NASDAQ).

B. G20/OECD Principles:These are guidelines, not binding requirements.

C. No requirements:Incorrect; corporate governance regulations apply regardless of jurisdiction.

D. Universal Corporate Governance Act:No such act exists globally.

Conclusion:Public corporations must comply with stock exchange-specific listing standards.

Comprehensive and Detailed in Depth Explanation:

A key element of vendor due diligence is ensuring that third-party vendors have robust ethics and compliance programs. This helps align values, mitigate fraud risks, and establish clear expectations. While audits and questionnaires are good practices, they are not always mandatory or feasible before engagement. Moreover, transparency in seeking vendor information (unlike in A) is a norm in legitimate vetting practices.

General Approaches to Control Corporate Crime:

Common approaches include government intervention, consumer action, and voluntary corporate changes.

Financial institution funding is not typically listed as a direct control mechanism for corporate crime.

Analysis of Options:

B. Government intervention:Effective through regulation and enforcement.

C. Consumer action:Encourages ethical practices through market pressures.

D. Voluntary corporate changes:Demonstrates internal commitment to compliance.

Conclusion:Withdrawal of financial institution funding is not one of the recognized general approaches.

Responsibility for Anti-Fraud Program Effectiveness:

Management holds ultimate responsibility for designing, implementing, and maintaining an effective anti-fraud program.

Internal and external auditors, as well as compliance functions, provide oversight and recommendations but are not directly responsible for the program's effectiveness.

Conclusion:Management is ultimately accountable for ensuring the success of the anti-fraud program.

Rational choice theory posits that criminal behavior is a result of deliberate decision-making. According to the ACFE manual:

“Rational choice theory assumes that individuals weigh the expected benefits of committing a crime against the possible consequences. If the perceived benefits outweigh the perceived risks, the individual may choose to offend.”

Comprehensive and Detailed in Depth Explanation:

Management is ultimately responsible for setting the ethical tone of an organization, often referred to as the "tone at the top." This tone influences the overall ethical culture, guiding employee behavior and setting the standard for compliance and integrity. While legal, HR, and fraud professionals play supporting roles, it is leadership’s responsibility to establish, model, and reinforce ethical conduct.

 ISSAI Standards:

The International Standards of Supreme Audit Institutions (ISSAI) require government auditors to consider fraud and abuse during financial audits. Abuse includes improper use of authority or resources, which may not always meet the legal threshold of fraud but still warrants attention.

 Expanded Audit Scope:

Unlike private-sector audits, public-sector audits often have broader objectives, requiring vigilance for misuse of public funds and resources.

 Why A is Correct:

Staying alert to abuse ensures comprehensive accountability, aligning with ISSAI's objectives​​.

Defining Fraud Risk Management Objectives:

Management should focus on tailoring objectives to the organization's needs, examining past fraud incidents, and balancing costs with benefits. Assigning a quantitative measure to risk appetite, while potentially useful, is not a requirement for effective fraud risk management.

Analysis of Options:

A. Examining previous frauds:This helps identify vulnerabilities and design controls.

B. Balancing costs and benefits:Essential to ensure the program's efficiency and feasibility.

D. Tailoring objectives:Necessary for aligning the program with organizational goals.

Conclusion:Option C is false because assigning a quantitative measure to risk appetite is not mandatory in defining fraud risk management objectives.

This scenario is an example of punishment. Punishment involves introducing a consequence (in this case, the loss of responsibility for cross-departmental projects) to discourage undesirable behavior. The manager uses this approach to address Devon’s negative attitude and to promote better cooperation with other departments in the future.

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Tips have consistently been the leading method for detecting occupational fraud, as confirmed by ACFE research:

“Figure 9 shows that the leading detection methods are tips, internal audit, and management review. This finding is not surprising as these have been the three most common means of detecting occupational fraud in every edition of the report since 2010.”

Understanding Behaviorism and Punishment:

Behaviorists like B. F. Skinner argue that punishment temporarily suppresses undesired behaviors rather than eliminating them.

Once the punitive stimulus is removed, the behavior is likely to reappear unless it is replaced with a more desirable behavior through reinforcement.

Analysis of Options:

B. Permanently suppressed:This contradicts the principles of behaviorism, as punishment alone does not permanently modify behavior.

C. Occur more frequently:Punishment typically decreases behavior temporarily.

D. Not affected by punishment:Punishment impacts behavior, but the effect is often temporary.

Conclusion:The most likely outcome is that the behavior will return once the punishment ceases.

The ACFE manual states:

“Employees should be trained to recognize and report signs such as unexplained lifestyle changes or behavioral red flags, and they should be informed that management will be watching for such indicators.”

Scope of Fraud Risk Assessment:

The fraud risk assessment team must consider various factors, including:

A. Incentive programs:Can create pressures that lead to fraud.

B. Management override of controls:A key risk for fraud occurring despite existing safeguards.

C. Risks to reputation:Fraud incidents can harm the organization's public image.

Comprehensive Discussion:

Considering all these factors ensures a thorough identification of inherent fraud risks.

Conclusion:The fraud risk assessment team should discuss all listed items.

International Standards on Auditing (ISAs) Requirements:

ISAs require auditors to communicate suspected or confirmed fraud to "those charged with governance" of the organization, as they have the responsibility for oversight.

ISA 240, “The Auditor's Responsibilities Relating to Fraud in an Audit of Financial Statements,” mandates that findings be reported to appropriate governance bodies before considering further actions.

Confidentiality and Legal Obligations:

Auditors must maintain confidentiality unless legal or regulatory frameworks require disclosure to authorities. Immediate reporting to law enforcement (option B) may breach confidentiality without proper internal escalation.

Why Option D is Correct:

Reporting to governance ensures proper internal actions are taken and protects the integrity of the audit process. It allows the organization to address the issue before external involvement if required.

Definition of Organizational Crime:

Organizational crime involves illegal actions conducted by or on behalf of organizations to benefit the organization or its management.

Why D is Correct:

Bid rigging is a classic example of organizational crime, where multiple companies collude to manipulate competitive bidding processes for mutual benefit.

Why Other Options are Incorrect:

A, B, and C:These represent individual crimes for personal gain, not organizational-level misconduct​​.

References for All Questions:

COSO Internal Control–Integrated Framework​​.

Criminological theories and studies on deterrence and organizational crime​​.

Diane Vaughan's research on organizational factors contributing to deviance​​.

Effect of Documenting Organizational Hierarchies:

Properly documenting hierarchies improves fraud prevention by clarifying responsibilities, ensuring accountability, and establishing clear information flow.

This reduces ambiguity and limits opportunities for fraud.

Why the Statement is False:

Documenting and communicating hierarchies strengthens fraud prevention, rather than hindering it.

Conclusion:The statement is false because clear hierarchies enhance fraud prevention initiatives.

Understanding the Factors of Economic Crime:The authors ofCrimes of the Middle Classesidentify factors contributing to economic crime:

A. Cultural pressures:Society's emphasis on material success creates incentives for unethical behavior.

B. Reliance on credit:A credit-based economy increases financial vulnerabilities and fraud opportunities.

D. Advancing technologies:These create new avenues for economic crime through sophisticated methods.

Analysis of Option C:

Increased regulatory constraints typically deter crime by establishing clear compliance requirements. They do not contribute to the rising problem of economic crime but instead act as a countermeasure.

Conclusion:Option C does not align with the factors discussed by the authors.

Purpose of Fraud Risk Assessment:

The goal is to identify vulnerabilities to fraud and implement preventive measures, not to wait for conclusive evidence of fraud before designating high-risk areas.

Proactive Identification:

High-risk areas are identified based on susceptibility to fraud (e.g., lack of controls, high cash transactions), even if no fraud has been detected. This approach allows organizations to act preemptively.

Improving Fraud Awareness:

Employee education and behavior monitoring are integral components of the assessment process to reduce fraud risks.

Incorrect Assumption in D:

Waiting for conclusive evidence contradicts the proactive nature of fraud risk assessment and undermines its preventative function​​.

References for All Questions:

ACFE Code of Professional Ethics​​.

Auditor Essentials on fraud prevention and deterrence principles​.

COSO and risk assessment frameworks in internal controls​​.

Understanding Fraud Risk Management Responses:

Risk mitigation refers to implementing controls or measures to reduce the likelihood or impact of a risk.

In this case, by implementing additional internal controls, management aims to mitigate the identified fraud risk.

Definition of Other Options:

A. Assuming the risk:This refers to accepting the risk without taking action to mitigate it. This is generally done when the risk is deemed tolerable.

C. Avoiding the risk:This involves changing business practices or ceasing activities to eliminate the risk entirely.

D. Transferring the risk:This occurs when the responsibility for the risk is shifted to another party, such as through insurance.

Conclusion:The described response clearly aligns with risk mitigation, as it focuses on reducing the risk through internal control measures.

Key Elements of an Ethics Program:

An effective ethics program involves assessing existing issues, such as ethical leadership gaps, and designing policies and practices to address them.

Analysis of Other Options:

A. Restricted access:Ethics policies should be accessible to external parties, including stakeholders, to enhance transparency.

C. Written policy alone:A written policy is insufficient without ongoing communication, training, and leadership support.

D. All of the above:Incorrect because options A and C are not true.

Conclusion:Considering existing ethical leadership issues is critical when designing an effective ethics program.

Due Diligence for Large Orders on Credit:

Before extending credit, it is critical to assess the financial stability of the new customer to mitigate credit risk.

Examining net worth provides a direct measure of ABC’s ability to fulfill financial obligations.

Analysis of Other Options:

A. Corruption risk countries:Due diligence should be applied universally, not selectively.

B. No verification needed:Verification is essential, especially for new customers.

D. Same due diligence for all customers:While consistency is important, the level of due diligence may vary based on transaction specifics.

Conclusion:Examining ABC's net worth is a necessary step in the due diligence process.

COSO Definition of Internal Control:

COSO defines internal control as a process executed by an entity’s board, management, and personnel to provide reasonable assurance about achieving objectives in operations, reporting, and compliance.

Analysis of Options:

A. Corporate compliance:Corporate compliance focuses on adhering to laws and regulations, not the broader operational objectives.

B. Fraud risk management:This is a component of internal control, not its definition.

C. Risk assessment:This is a step within the internal control process but not the overarching process.

D. Internal control:Matches the COSO definition accurately.

Conclusion:Internal control is the correct answer as defined by COSO.

Management is ultimately responsible for ensuring the effectiveness of the organization’s anti-fraudprogram. They set the tone at the top, establish internal controls, and ensure that the necessary resources and oversight mechanisms are in place to prevent and detect fraud. Other stakeholders, such as auditors and compliance officers, provide support but do not bear ultimate responsibility.

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According to ISA 240, the auditor is required to communicate identified fraud involving management to those charged with governance.

“When fraud involving senior management is identified or suspected, the auditor shall communicate these findings directly to those charged with governance.”

Understanding G20/OECD Principles of Corporate Governance:These principles provide a framework to improve corporate governance worldwide. Key elements include board responsibilities, shareholder rights, equitable treatment, and stakeholder roles.

Analysis of Options:

A. Guidance on board structures:This is included in the principles to ensure effective governance and oversight.

C. Framework for corporate governance:Governments are encouraged to create legal and regulatory frameworks supporting corporate governance.

D. Stakeholder importance:Stakeholders' roles in governance are recognized, acknowledging their contribution to sustainable business practices.

B. Stronger protection for foreign shareholders:The principles advocate for equitable treatment of all shareholders, not preferential treatment for any group.

Conclusion:Option B contradicts the principle of equitable treatment, making it the correct answer.

Comprehensive and Detailed in Depth Explanation:

Organizational crime refers to offenses committed by organizations or their agents to benefit the organization, rather than the individual alone. Price-fixing by a group of floral companies to manipulate market conditions is a classic example of organizational crime. The other options—fraudulent returns, theft of goods, and misuse of company funds—are examples of occupational or individual fraud, which benefit the perpetrator rather than the organization.

 Indirect Costs of Fraud:

Reputational damage is a significant indirect cost of fraud. It can lead to loss of customer trust, reduced employee morale, and long-term financial impact.

 Why A is Correct:

Quantifying reputational damage is challenging due to its intangible nature. The effects often manifest over time and are influenced by various factors, making precise calculation difficult​​.

Overview of Compliance Programs:An effective compliance program requires clear communication, enforcement, and promotion of ethical standards within an organization. Promoting compliance involves setting up positive incentives, such as rewards for ethical behavior, to encourage adherence to policies and regulations.

Role of Incentives:

Incentives serve as motivators for employees to align with the compliance culture. Examples include bonuses for meeting compliance goals, recognition for ethical behavior, and career advancement opportunities tied to compliance performance.

The U.S. Federal Sentencing Guidelines for Organizations emphasize that for a compliance program to be effective, it must include incentives to encourage proper behavior and discipline to deter violations.

Supporting Reference Materials:

The Association of Certified Fraud Examiners (ACFE) highlights the importance of integrating incentives into compliance programs. These incentives are seen as essential for fostering a culture of ethics and preventing fraud.

Industry standards and frameworks, such as COSO’s "Internal Control - Integrated Framework," also stress the integration of incentives to promote adherence to internal controls and compliance standards​​.

Importance of Positive Reinforcement:

Positive reinforcement through incentives leads to higher employee morale, enhanced commitment to ethical practices, and a reduced likelihood of non-compliance.

A compliance program that merely penalizes non-compliance without rewarding adherence can fail to motivate employees to prioritize compliance.

Application in Fraud Prevention:

By actively incentivizing compliance, organizations can proactively mitigate risks of fraud and unethical practices. This aligns employees’ personal goals with the organization’s ethical standards.

Objectives of a Fraud Risk Management Program:

A. Proactively identifying fraud risks:A fundamental goal is to identify and assess potential fraud risks to implement preventative measures.

B. Limiting the damage caused by fraud occurrences:Programs should have mechanisms in place to detect and respond to fraud promptly to minimize harm.

C. Punishing fraud perpetrators:Punishment serves as both a deterrent and a means of reinforcing the organization's commitment to ethical behavior.

Comprehensive Objective Coverage:

Effective fraud risk management includes preventative, detective, and corrective measures.

Conclusion:All the listed objectives are essential components of a fraud risk management program.

Impartiality in Fraud Risk Assessment:

As the lead on the fraud risk assessment, Glenda must maintain objectivity and avoid the appearance of bias.

Her history of disagreements with Bridgette creates a potential conflict of interest, which could compromise the assessment's credibility.

Why Option D is Correct:

Assigning the accounts receivable department's assessment to another individual eliminates the risk of perceived or actual bias.

Analysis of Other Options:

A. Confrontation:Not appropriate during a professional assessment.

B. Including disagreements:Personal conflicts should not influence risk evaluations.

C. Automatic high-risk designation:This lacks a factual basis and undermines objectivity.

Conclusion:Option D ensures objectivity and credibility in the fraud risk assessment.

Principles in the Fraud Risk Management Guide (COSO and ACFE):

Communicating expectations regarding fraud risk management.

Conducting comprehensive fraud risk assessments.

Implementing preventive and detective controls.

Monitoring and reporting the program’s effectiveness.

Analysis of Option D:

Fraud risk management requires ongoing evaluations, not one-time assessments, to adapt to evolving risks.

Conclusion:Option D is not included in the principles described in the Fraud Risk Management Guide.

Understanding Compliance Theory:

Compliance theory emphasizes preventing crime through incentives for voluntary adherence to laws and proactive administrative measures.

By addressing potential violations early, compliance theory aims to deter criminal behavior before it occurs.

Application of the Theory:

Examples include economic benefits for following regulations and monitoring mechanisms to identify early signs of noncompliance.

Conclusion:The statement accurately describes compliance theory.

 ISO 31000:2018 Guidelines:

This standard emphasizes that a risk management framework should align with the organization’s size, complexity, objectives, and operations to ensure effectiveness and relevance.

 Why A is Correct:

Proportionality ensures that resources are allocated efficiently, addressing risks that directly impact the organization’s goals while avoiding overcomplication.

 References:

ISO 31000:2018 risk management principles​​.

COSO Definition of Internal Control:

COSO defines internal control as a process enacted by an entity's board, management, and personnel to provide reasonable assurance regarding objectives in operations, reporting, and compliance.

Analysis of Options:

A. Operational risk assessment:A component of internal control, not the overall process.

C. Fraud risk management:Focuses specifically on fraud risks, a subset of internal control.

D. Financial reporting:A specific objective addressed by internal control.

Conclusion:The correct answer is internal control, as defined by COSO.

Comprehensive and Detailed in Depth Explanation:

The G20/OECD Principles emphasize the importance of full disclosure, including timely, accurate, and transparent mechanisms to maintain investor confidence and market integrity. While they support the equal treatment of shareholders, not members of the governing body (rejecting B), and call for corporate—not government—governance responsibilities (rejecting C). Protecting management’s rights (A) is not a governance principle focus.

Privilege of Fraud Examination Reports:

Reports prepared by fraud examiners are not inherently privileged. Privilege depends on the legal framework, the purpose of the report, and whether the attorney-client privilege or work-product doctrine applies.

Without specific legal protection, reports may be subject to disclosure.

Conclusion:Fraud examination reports are not automatically privileged.

Risk assessment is a core component of the COSO Framework and focuses on identifying, analyzing, and evaluating risks that could affect the organization's objectives. Andrew's initiative to evaluate threats aligns with this component, as it involves understanding the potential risks and their impact on achieving the organization's goals.

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 CFE Ethical Responsibilities:

As per the ACFE Code of Professional Ethics, fraud examiners must ensure transparency in their professional conduct. They cannot promise confidentiality if the information must be disclosed to management or other authorities as part of the investigation.

 Why D is Correct:

Agreeing to confidentiality in this situation would breach ethical and legal obligations, especially if the information pertains to fraud or misconduct that the organization needs to address.

 Why Other Options are Incorrect:

A and B:Attempting to maintain confidentiality is misleading and unprofessional.

C:Taking the request directly to management without clarification could breach trust prematurely​​.

According to the ACFE Manual, in public-sector audits conducted under INTOSAI standards, “government auditors might not have the same level of discretion as private auditors to withdraw from engagements when fraud is detected.” INTOSAI standards focus more on reporting and public transparency rather than withdrawal.

Best Practices for Vendor Due Diligence:

Including a clause requiring vendors to report misconduct demonstrates a commitment to transparency and ethical standards.

This measure also ensures accountability and provides the organization with critical information about potential issues.

Analysis of Other Options:

A. Internal audits:While valuable, conducting internal audits of vendors before an agreement is impractical and costly.

B. Concealing due diligence efforts:Transparency in due diligence helps build trust with vendors.

C. Post-contract questionnaires:Due diligence must occur before contracts are signed.

Conclusion:Including a contractual clause about misconduct reporting is the most accurate recommendation.

Risks Associated with Specialized Departments:

While specialization improves efficiency, it can create silos that hinder communication, coordination, and oversight, increasing fraud risk.

Isolated departments may lack cross-functional checks and balances.

Conclusion:Specialized departments often increase fraud risk if not managed with proper controls and oversight.

 Components of COSO Enterprise Risk Management (ERM):

The COSO ERM framework emphasizes the integration of risk management with strategy and performance, comprising the following components:

Governance and culture.

Strategy and objective-setting.

Performance.

Review and revision.

Information, communication, and reporting.

 Why D is Correct:

Governance and culture set the foundation for an organization’s risk management practices by establishing oversight, ethical values, and the operating structure.

 Why Other Options are Incorrect:

A (Independent monitoring):Monitoring is part of internal control, not specifically ERM.

B (Operating environment):Not a COSO ERM component.

C (Risk tolerance):A concept within ERM but not a standalone component​​.

Allowing employees to report fraud anonymously is a best practice in fraud reporting programs. This encourages whistleblowers to come forward without fear of retaliation or reprisal, increasing the likelihood of fraud detection. Transparency about confidentiality policies further supports employee trust in the reporting system.

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Tone at the Top:

Management must set a strong example by adhering to the same ethical standards as employees.

Visible adherence builds trust and reinforces an anti-fraud culture.

Analysis of Other Options:

A. Checklist of initiatives:Helpful but insufficient by itself.

B. Dissuading challenges:This is counterproductive, as it discourages transparency and accountability.

D. All of the above:Incorrect, as Option B is detrimental to an anti-fraud culture.

Conclusion:Visibly adhering to ethics policies is the most effective action.