In compliance with the Department of Justice and in accordance with the Sarbanes Oxley Act, management is required to identify, categorize, and map to financial statement assertions the Anti-Fraud internal controls by Corporate, Business Unit, and Account that serve to mitigate the six basic types of corporate fraud, and to remediate all areas that do not mitigate or address the risks. The scope of review of Anti-Fraud Controls will include Entity Level and all Business Operations according to the COSO and AICPA Guidelines:

• COSO-1 Control Environment
• COSO-2 Corporate Risk Assessment
• COSO-3 Control Activities
• COSO-4 Information & Communication
• COSO-5 Feedback & Monitoring
• SAS 99 -Consideration of Fraud in a Financial Audi

SOAProjects has Certified Fraud Specialists and Forensic CPAs onsite to accomplish this process and resolve any issues. The examination identifies anti-fraud controls and most importantly, missing anti-fraud controls whether they relate to Safeguarding of Assets or Information, Coporate Performance Reviews, or Segregation of Duties. It also identifies the Likelihood and Significance of fraud failures and according to Accounting Standard – 5, the chance of Management Override

Anti Fraud Program

Many executives do not realize that establishing and implementing an effective anti-fraud program is not only good business sense, but it is a legal requirement of the Department of Justice (DOJ). The DOJ has enacted this activity into law. SOAProjects’ Consultants are fully able to achieve these goals on behalf of management and can assist you two ways:

• We conduct anti-fraud seminars on behalf of management for all Section 16 Officers and corporate insiders to inform and educate them on the means and methods to avoid becoming victims of fraud, as well as covering Business Ethics and the Code of Conduct. The outside auditors are usually invited to this seminar and it gives management the opportunity to fulfill their duties at it relates to communicating to all employees their “tone at the top”.
• We conduct examinations of the anti-fraud structure, and report to management on the status of it.

We assist management in designing and testing the effectiveness of the anti-fraud program. In designing and evaluating anti-fraud program we will assist management to ensure it appropriately addresses the following:

• Develops anti-fraud controls that are “scheme and scenario” based according to the AICPA Guidelines on fraud.
• Categorize financial fraud into fraudulent financial reporting, misappropriation of assets, management override, inappropriate receipts or expenditures, or IT fraud,
• Identify and assess the anti-fraud controls in relation to all five elements of the COSO Framework (Control Environment/Entity Level Controls; Risk Assessment; Control Activities; Information and Communication and Monitoring)

SAS 99 – Consideration of Fraud in Financial Audit
We assist management in identifying and evaluating the requirement of Statement on Auditing Standards (SAS) No. 99 “Consideration of Fraud in Financial Statement Audit” to obtain reasonable assurance whether financial statement are free of material misstatement due to fraud or error. We understand Fraud can occur at any time at any level in company and thus assist management in evaluating:

• Risk of Management Override
• Risk Assessment Process
• Effectiveness of Audit Committee Oversight
• Whistleblower Program
• Code of Business Conduct and Ethics Policy
• Tone at the Top effective communication

Thus management can come into full compliance with the DOJ requirements and with Sarbanes-Oxley as well.