How Internal Auditors can win The War against Spreadsheet Fraud

To prevent another round of million dollar scandals due to fraudulent manipulations on spreadsheets, regulatory bodies have launched major offensives against these well-loved User Developed Applications (UDAs). Naturally, internal auditors are front and center in carrying out these offensives.

While regulations like the Sarbanes-Oxley Act, Dodd-Frank Act, and Solvency II can only be effective if end users are able to carry out the activities and practices required of them, auditors need to ascertain that they have. Sad to say, when it comes to spreadsheets, that is easier said than done.

Because spreadsheets are loosely distributed by nature, internal auditors always find it hard to: locate them, identify ownership, and trace their relationships with other spreadsheets. Now, we’re still talking about naturally occurring spreadsheets. How much more with files that have been deliberately tampered?

Spreadsheets can be altered in a variety of ways, especially if the purpose is to conceal fraudulent activities. Fraudsters can, for instance:

  • hide columns or rows,
  • perform conditional formatting, which changes the appearance of cells depending on certain values
  • replace cell entries with false values either through direct input or by linking to other spreadsheet sources
  • apply small, incremental changes in multiple cells or even spreadsheets to avoid detection
  • design macros and user defined functions to carry out fraudulent manipulations automatically

Recognising the seemingly insurmountable task ahead, the Institute of Internal Auditors released a guide designed specifically for the task of auditing user-developed applications, which of course includes spreadsheets.

But is this really the weapon internal auditors should be wielding in their quest to bring down spreadsheet fraud? Our answer is no. In fact, we believe no such weapon has to be wielded at all?because the only way to get rid of spreadsheet fraud is to eliminate spreadsheets once and for all.

Imagine how easy it would be for internal auditors to conduct their audits if data were kept in a centralised server instead of being scattered throughout the organisation in end-user hard drives.

And that’s not all. Because a server-based solution can be configured to have its own built-in controls, all your data will be under lock and key; unlike spreadsheet-based systems wherein storing a spreadsheet file inside a password-protected workstation does not guarantee equal security for all the other spreadsheets scattered throughout your company.

Learn more about Denizon’s server application solutions and discover a more efficient way for your internal auditors to carry out their jobs.

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How Internal Auditors can win the War against Spreadsheet Fraud

 

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Disadvantages of Spreadsheets

 

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How DevOps oils the Value Chain

DevOps ? a clipped compound of development and operations – is a way of working whereby software developers are in a team with project beneficiaries. A client centred approach extends the project plan to include the life cycle of the product or service, for which the software is developed.

We can then no longer speak of a software project for say Joe?s Accounting App. The software has no intrinsic value of its own. It follows that the software engineers are building an accounting app product. This is a small, crucially important distinction, because they are no longer in a silo with different business interests.

To take the analogy further, the developers are no longer contractors possibly trying to stretch out the process. They are members of Joe?s accounting company, and they are just as keen to get to market fast as Joe is to start earning income. DevOps uses this synergy to achieve the overarching business goal.

A Brief Introduction to OpsDev

You can skip this section if you already read this article. If not then you need to know that DevOps is a culture, not a working method. The three ?members? are the software developers, the beneficiaries, and a quality control mechanism. The developers break their task into smaller chunks instead of releasing the code to quality control as a single batch. As a result, the review process happens contiguously along these simplified lines.

Code QC Test ? ? ?
? Code QC Test ? ?
? ? Code QC Test ?
? ? ? Code QC Test
Colour Key Developers Quality Control Beneficiary

This is a marked improvement over the previously cumbersome method below.

Write the Code ? Test the Code ? Use the Code
? Evaluate, Schedule for Next Review ?

Working quickly and releasing smaller amounts of code means the OpsDev team learns quickly from mistakes, and should come to product release ahead of any competitor using the older, more linear method. The shared method of working releases huge resources in terms of user experience and in-line QC practices. Instead of being in a silo working on its own, development finds it has a richer brief and more support from being ?on the same side of the organisation?.

The Key Role that Application Program Interfaces Play

Application Program Interfaces, or API?s for short, are building blocks for software applications. Using proprietary software-bridges speeds this process up. A good example would be the PayPal applications that we find on so many websites today. API?s are not just for commercial sites, and they can reduce costs and improve efficiency considerably.

The following diagram courtesy of TIBCO illustrates how second-party applications integrate with PayPal architecture via an API fa?ade.

Working quickly and releasing smaller amounts of code means the OpsDev team learns quickly from mistakes, and should come to product release ahead of any competitor using the older, more linear method. The shared method of working releases huge resources in terms of user experience and in-line QC practices. Instead of being in a silo working on its own, development finds it has a richer brief and more support from being ?on the same side of the organisation?.

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The DevOps Revolution Continues ?

We close with some important insights from an interview with Jim Stoneham. He was general manager of the Yahoo Communities business unit, at the time Flickr became a part. ?Flickr was a codebase,? Jim recalls, ?that evolved to operate at high scale over 7 years – and continuing to scale while adding and refining features was no small challenge. During this transition, it was a huge advantage that there was such an integrated dev and ops team?

The ?maturity model? as engineers refer to DevOps status currently, enables developers to learn faster, and deploy upgrades ahead of their competitors. This means the client reaches and exceeds break-even sooner. DevOps lubricates the value chain so companies add value to a product faster. One reason it worked so well with Flickr, was the immense trust between Dev and Ops, and that is a lesson we should learn.

?We transformed from a team of employees to a team of owners. When you move at that speed, and are looking at the numbers and the results daily, your investment level radically changes. This just can’t happen in teams that release quarterly, and it’s difficult even with monthly cycles.? (Jim Stoneham)

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Is the GDPR Good or Bad News for Business

The European Union?s General Data Protection Act (GDPR) is a new data authority coming into force on 25 May 2018. It replaces the current Data Protection Directive 95/46/EC, while extending the remit to include the export of personal data outside the EU. It aims to give EU citizens and residents living there more control over their personal information. It also hopes to make regulatory compliance simpler for participating businesses.

The Broad Implications for Business
The GDPR puts another layer of accountability on businesses falling within its remit. It requires them to implement ?comprehensive but proportionate governance measures? including recording how they make decisions. The long-term goal is to reduce privacy infringements. In the short run, businesses without good governance may find themselves writing new policies and procedures.

Article 5 of the European Union?s General Data Protection Act lays down the following guidelines for managing personal data. This shall be ?
? Processed transparently, fairly, and lawfully
? Acquired for specific, legitimate purposes only
? Adequate, relevant and limited to essentials
? Not used for any other, incompatible purpose
? However it may be archived in the public interest
? Kept up to date with all inaccuracies corrected
? Ring-fenced when the information becomes irrelevant
? Adequately protected against unauthorised access
? Stored in a way that prevents accidental loss
Furthermore, affected businesses shall appoint a ?controller responsible for, and able to demonstrate, compliance with the principles.?

Implementing Accountability and Governance
The UK Information Commissioner?s Office has issued guidelines regarding provisions to assure governance and accountability. These are along the lines of the ?don’t tell me, show me? management approach the office has generally been following. In summary form, a business, and its controller must:
? Implement measures that assist it to ensure demonstrated compliance
? Maintain suitable, relevant records of personal data processing activities
? Appoint a dedicated data protection officer if scale makes this appropriate
? Implement technologies that ensure data protection by design
? Conduct data protection assessments and respond to results timeously

Implementing the General Data Protection Act in Ireland
The Irish Data Protection Commissioner has decided it is unnecessary to incorporate the GDPR into Irish law, since EU regulations have direct effect. The office of the Commissioner is working in tandem with data practitioners, and industry and professional bodies to raise awareness in business through 2017. It has produced a document detailing what it considers the essentials for business compliance. Briefly, these pre-requisites are:
? Ensure awareness among key personnel, and make sure they incorporate the GDPR into their planning
? Conduct an early assessment of quality management gaps, and budget for additional resources needed
? Do an audit of personal data held, to determine the origin, the necessity to hold it, and with whom shared
? Inform internal and external stakeholders of the current status, and your future plans to implement the GDPR
? Examine current procedures in the light of the new directive. Could you ?survive? a challenge from a data subject?
? Determine how you will process requests for access to the data in the future from within and outside your organization
? Assess how you currently obtain customer consent to store their data. Is this “freely given, specific, informed and unambiguous”?
? Find how you handle information from underage people. Do you have systems to verify ages and obtain guardian consent?
? Implement procedures to detect, investigate, and report data breaches to the Data Protection Commissioner within 72 hours
? Implement a culture of always assessing the effect on individual privacy before starting new initiatives

So Is the GDPR Good or Bad for Business
The GDPR should be good news for business customers. Their personal data will be more secure, and they should see their rate of spam marketing come down. The GDPR is also good news for businesses currently investing resources to protect their clients? interests. It could however, be bad news for businesses that have not been focussing on these matters. They may have a high mountain to climb to come in line with the GDPR.
Disclaimer: This article is for information only and not intended as a comprehensive guide.

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The Better Way of Applying Benford’s Law for Fraud Detection

Applying Benford’s Law on large collections of data is an effective way of detecting fraud. In this article, we?ll introduce you to Benford’s Law, talk about how auditors are employing it in fraud detection, and introduce you to a more effective way of integrating it into an IT solution.

Benford’s Law in a nutshell

Benford’s Law states that certain data sets – including certain accounting numbers – exhibit a non-uniform distribution of first digits. Simply put, if you gather all the first digits (e.g. 8 is the first digit of ?814 and 1 is the first digit of ?1768) of all the numbers that make up one of these data sets, the smallest digits will appear more frequently than the larger ones.

That is, according to Benford’s Law,

1 should comprise roughly 30.1% of all first digits;
2 should be 17.6%;
3 should be 12.5%;
4 should be 9.7%, and so on.

Notice that the 1s (ones) occur far more frequently than the rest. Those who are not familiar with Benford’s Law tend to assume that all digits should be distributed uniformly. So when fraudulent individuals tinker with accounting data, they may end up putting in more 9s or 8s than there actually should be.

Once an accounting data set is found to show a large deviation from this distribution, then auditors move in to make a closer inspection.

Benford’s Law spreadsheets and templates

Because Benford’s Law has been proven to be effective in discovering unnaturally-behaving data sets (such as those manipulated by fraudsters), many auditors have created simple software solutions that apply this law. Most of these solutions, owing to the fact that a large majority of accounting departments use spreadsheets, come in the form of spreadsheet templates.

You can easily find free downloadable spreadsheet templates that apply Benford’s Law as well as simple How-To articles that can help you to implement the law on your own existing spreadsheets. Just Google “Benford’s law template” or “Benford’s law spreadsheet”.

I suggest you try out some of them yourself to get a feel on how they work.

The problem with Benford’s Law when used on spreadsheets

There’s actually another reason why I wanted you to try those spreadsheet templates and How-To’s yourself. I wanted you to see how susceptible these solutions are to trivial errors. Whenever you work on these spreadsheet templates – or your own spreadsheets for that matter – when implementing Benford’s Law, you can commit mistakes when copy-pasting values, specifying ranges, entering formulas, and so on.

Furthermore, some of the data might be located in different spreadsheets, which can likewise by found in different departments and have to be emailed for consolidation. The departments who own this data will have to extract the needed data from their own spreadsheets, transfer them to another spreadsheet, and send them to the person in-charge of consolidation.

These activities can introduce errors as well. That’s why we think that, while Benford’s Law can be an effective tool for detecting fraud, spreadsheet-based working environments can taint the entire fraud detection process.

There?s actually a better IT solution where you can use Benford’s Law.

Why a server-based solution works better

In order to apply Benford’s Law more effectively, you need to use it in an environment that implements better controls than what spreadsheets can offer. What we propose is a server-based system.

In a server-based system, your data is placed in a secure database. People who want to input data or access existing data will have to go through access controls such as login procedures. These systems also have features that log access history so that you can trace who accessed which and when.

If Benford’s Law is integrated into such a system, there would be no need for any error-prone copy-pasting activities because all the data is stored in one place. Thus, fraud detection initiatives can be much faster and more reliable.

You can get more information on this site regarding the disadvantages of spreadsheets. We can also tell you more about the advantages of server application solutions.

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