SAMPLE FRAMEWORK FOR A FRAUD CONTROL POLICY
SAMPLE FRAMEWORK FOR A FRAUD CONTROL POLICY NOTE: This appendix is a SAMPLE from another entity. As such, no adjustment has been made to this material. The information may or may not agree with all the concepts noted within this paper. The material is being provided as an example that may be a used as a tool, reference, or starting point. 1. EXECUTIVE SUMMARY Definition of FRAUD Statement of attitude to FRAUD Code of conduct (relationship to) Relationship with entity s other plans Roles and accountabilities 2. SUMMARY OF FRAUD CONTROL STRATEGIES Appointment of FRAUD CONTROL officer External assistance to the FRAUD CONTROL officer FRAUD CONTROL responsibilities FRAUD risk management (including FRAUD risk assessment) FRAUD awareness FRAUD detection FRAUD reporting Investigation of FRAUD and other improper conduct Internal CONTROL review following discovery of FRAUD Fidelity guarantee and criminal conduct insurance Internal audit program 3. FRAUD RISK MANAGEMENT Regular program for FRAUD risk assessment Ongoing review of FRAUD CONTROL strategies FRAUD risk assessment Implementation of proposed actions 4.
This sample is provided by the Association of Certified Fraud Examiners’ Sample Fraud Policy. Please note that other definitions of fraud exist, and thus it is important for the organization to explain clearly what types of transactions or activities are covered by the policy.
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