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International Fraud Handbook








Dr. Joseph T. Wells























Wiley Logo








For Andi McNeal

This book would not have been possible without her superb efforts.

Preface

My 40-year career has been devoted to the investigation and prevention of white-collar crimes. And while I have witnessed much change, I have also seen so much stay the same.

Through the ebbing and flowing trends and the technological advances, I have learned several enduring lessons about fraud and human nature. First, fraud is timeless; as long as people are put in positions of trust, fraud will occur. Second, the variations on fraud are not limitless. As explored in my previous publication, Corporate Fraud Handbook, frauds tend to fall into time-tested and universal categories. Finally, ignoring the problem will never solve the problem. In fact, quite the opposite is true: all organizations are inherently vulnerable to fraud, but the ones that are reluctant to admit it are the ones most at risk.

Along with these truths, I have also seen the evolution of our profession. Technology has helped both the fraudsters and the fraud fighters accomplish their tasks more effectively and efficiently. Governments in numerous countries have enacted new regulations and bolstered their enforcement efforts against fraud, resulting in an increased focus on compliance in many organizations. Business operations – and frauds – now routinely span geographical borders, requiring new knowledge and skill sets for those attempting to prevent, detect, and investigate white-collar crimes. As the fraud examination profession has grown globally and the fight against fraud has grown more complex, the need for information and professional connection has never been greater.

It is out of this need, demonstrated by the numerous and increasing requests that the ACFE receives every year for resources to assist in this international effort, that the inspiration for this book arose. It focuses solely on combatting those frauds perpetrated against organizations; frauds against individuals are pervasive and devastating, and consequently merit separate, in-depth discussion.

The foundation for effectively addressing fraud against organizations – the tools of the trade used to prevent, detect, and respond to these crimes – look about the same throughout most of the world. However, important geographical nuances and considerations exist. Thus, to help fraud examiners everywhere, the material in this book is provided in two parts:

Much like the fight against fraud, this book was truly a global effort. Each section discussing specific countries in Part II lists the specific ACFE members who contributed that material. My deepest gratitude to these volunteers – listed individually in the Acknowledgments section – who helped us with this significant undertaking.

My appreciation also goes to the members of the ACFE team who helped research, compile, and review various parts of this publication. In particular, I’d like to thank John Gill, JD, CFE; Andi McNeal, CFE, CPA; Ron Cresswell, JD, CFE; Jordan Underhill, JD, CFE; Mason Wilder, CFE; Bobbie Dani; and Mark Blangger.

And finally, my thanks and admiration go to the fraud fighters everywhere who have dedicated their professional lives to the prevention and detection of fraud. As the first US president, George Washington, said, “Truth will ultimately prevail where pains is taken to bring it to light.” By sharing information and joining forces as part of the worldwide anti-fraud community, we can continue to bring truth to light and be successful in the global fight against fraud.

Dr. Joseph T. Wells

Austin, TX

February 2018

Acknowledgments

Thanks to the following individuals for their time and effort in assisting with this publication. The information they provided in Part II of this book is invaluable in highlighting the anti-fraud environment and resources in their respective countries.

Syed Zubair Ahmed, MBA, CFE, MCom

  • ACFE Islamabad Chapter Secretary
  • Islamabad, Pakistan

Gertrudis Alarcon, CFE

  • ACFE Spain Chapter President
  • Senior Managing Director, Grupo GAT
  • Madrid, Spain

Abdallah Alomari, CFE

  • ACFE Jordan Chapter Treasurer
  • Managing Director, KYC Jordan
  • Amman, Jordan

Mukesh Arya, CFE

  • ACFE India Chapter Treasurer
  • Managing Director, Red Flag
  • Gurgaon, India

Tomasita Pazos Aurich, CFE, CRISC

  • ACFE Lima Chapter President
  • Fraud Prevention Manager, Banco de Crédito del Perú (BCP)
  • Lima, Peru

Adel Ayyoub

  • ACFE Jordan Chapter Secretary
  • Amman, Jordan

S.K. Bansal, CFE

  • ACFE India Chapter President
  • Managing Partner, Bansal & Co., LLP, Chartered Accountants
  • New Delhi, India

Alison Benbow, CFE, CMIIA

  • ACFE Oman Chapter Secretary
  • Muscat, Oman

Vibeke Bisschop-Mørland, CFE

  • Senior Manager, BDO Norway
  • Oslo, Norway

Dom Blackshaw, CFE

  • ACFE Perth Chapter President
  • Manager, Corporate Governance, Risk and Compliance, Finders Resources Limited
  • Perth, Australia

Thomas Bøgballe, CFE

  • ACFE Denmark Chapter Treasurer and Board Member
  • Head of Fraud and Forensics, Novozymes A/S
  • Bagsværd, Denmark

Stefano Bordoli

  • Consultant, Deloitte Forensic
  • Santiago, Chile

Dr. Jose A. Brandin, MBA, CFE, CIA, CISA

  • ACFE Spain Chapter Board Member
  • Head of Audit Spain, International Airlines Group
  • Barcelona, Spain

Muna D. Buchahin, PhD, CFE, CFI, CGAP, CRMA

  • ACFE Mexico Chapter Vice President
  • Director General, Forensic Audit, SAO Mexico
  • Mexico City, Mexico

Bandish Bundhoo, CFE

  • ACFE Mauritius Chapter Secretary
  • Riviere du Rempart, Mauritius

Nereyda López Canales

  • Lima, Peru

Piotr Chmiel, CFE, CISA, CIA

  • ACFE Poland Chapter President
  • Compliance Manager, T-Mobile
  • Warsaw, Poland

Sun Hee Cho

  • Bae, Kim & Lee, LLC
  • Seoul, South Korea

Shamsa Dagane, CFE

  • Nairobi, Kenya

Dr. Anna Damaskou, CFE, PhD, LLM

  • Chair of the Board of Transparency International — Greece
  • Black Sea Trade & Development Bank — Compliance & Operational Risk Management Office
  • Thessaloniki, Greece

Sandra Damijan, PhD, CFE

  • Partner, Western Balkans Forensic Leader, Grant Thornton
  • Ljubljana, Slovenia

Fadi Daoud, MBA, CACM, CIPT

  • ACFE Jordan Chapter Board Member
  • Education and Youth Advisor, Talal Abu Ghazaleh Organization
  • Amman, Jordan

Roger Darvall-Stevens, MBA, MA, CFE

  • Former ACFE Melbourne Chapter President; ACFE Regent Emeritus
  • Partner and National Head of Fraud and Forensic Services, RSM Australia
  • Melbourne, Australia

Mario B. Demarillas, CFE, CPISI, CRISC, CISM, CISA, CIA

  • ACFE Philippines Chapter Board Member
  • ISACA Manila Chapter President and Board Member
  • Partner, Advisory Services, Reyes Tacandong & Co. (RSM Philippines)
  • Makati City, Philippines

Evangelia Dimitroulia, CFE, CIA

  • ACFE Greece Chapter President
  • Partner, Fraud Education Center
  • Athens, Greece

John Ederer, CFE, FCA

  • ACFE Switzerland Chapter Vice President
  • Chartered Accountant, JADEN Consulting LLC
  • Gattikon-Zurich, Switzerland

Hossam El Shaffei, CFE

  • ACFE Jordan Chapter Vice President
  • Amman, Jordan

Mahmoud Elbagoury, GRCA, CPFA, CICA, CACM

  • ACFE Egypt Board Member
  • Head of Audit and Compliance, Union Group
  • Cairo, Egypt

Hossam Elshafie, CFE, CRMA, CCSA, CFCI

  • ACFE Egypt Chapter President
  • Partner, RSM Egypt
  • Cairo, Egypt

Hazem Abd Eltawab

  • ACFE Egypt Chapter Vice President
  • Board Member, Egyptian Society of Accountants and Auditors (ESAA)
  • Cairo, Egypt

Edward J. Epstein, LLB, LLM

  • Solicitor, Hong Kong, England & Wales, Australia, and the Republic of Ireland
  • Shanghai, China

Marco Antonio E. Fernandes

  • Director, Berkeley Research Group
  • São Paulo, Brazil

Dante T. Fuentes, CFE, CPA, CAMS

  • ACFE Philippines Chapter President
  • Chief Compliance Officer, Security Bank Corporation
  • Association of Bank Compliance Offices, Inc., President
  • Good Governance Advocates & Practitioners of the Philippines, Inc., Senior Adviser
  • Makati City, Philippines

Atty. Laureano L. Galon Jr., CFE, CPA

  • ACFE Philippines Chapter Secretary
  • Partner, Rodriguez Casila Galon & Associates Law Firm
  • Manila, Philippines

Gertjan Groen

  • ACFE Netherlands Chapter President
  • Business Line Manager Forensics & Incident Response, Fox-IT
  • Rotterdam, Netherlands

Makito Hamada, CFE, CPA

  • ACFE Japan Chapter President
  • Visiting Professor, Rikkyo University
  • Tokyo, Japan

Tim Harvey, CFE, JP

  • ACFE Global Head of Chapter Development
  • ACFE UK Chapter President
  • London, UK

Sandra Hauwert, CFE

  • ACFE Netherlands Chapter Communication Chair
  • Netherlands

Adv. Jan Henning, SQ

  • Bloemfontein, South Africa

Pavla Hladká, CFE

  • ACFE Czech Republic Chapter President
  • Associate Partner of Forensic Services, EY
  • Czech Republic

Francis Hounnongandji, CFE, CFA

  • ACFE France Chapter President
  • President, Institut Français de Prévention de la Fraude (IFPF)
  • Paris, France

Shun Hsiung Hsu, CFE, CPA

  • ACFE Taiwan Chapter President
  • Managing Partner, YMH Company CPAs
  • Taipei, Taiwan

Katie Huchler, CFE

  • Manager, BDO Norway
  • Oslo, Norway

Siti Zeenath Shaik Ibrahim

  • Head, Group Corporate Crime Prevention, Kenanga Investment Bank Berhad
  • Kuala Lumpur, Malaysia

Vladimir Ikonomov, CFE

  • ACFE Bulgaria Chapter President
  • Project Manager, First Investment Bank
  • Sofia, Bulgaria

Jaco de Jager, CFE

  • ACFE South Africa CEO
  • Pretoria, South Africa

Wong Siew Jiuan, CFE

  • Head, Group Legal, Kenanga Investment Bank Berhad
  • Kuala Lumpur, Malaysia

Peter Juestel, CFE, CAMS

  • ACFE Switzerland Chapter Secretary
  • Attorney, Lustenberger Rechtsanwaelte
  • Zurich, Switzerland

Deoraj Juggoo

  • ACFE Mauritius Chapter Board Member
  • Mauritius

Agata Kamińska, Master in International Relations

  • Gdańsk, Poland

Hyeon Kang, CFE

  • ACFE South Korea Chapter Board Member
  • Bae, Kim & Lee, LLC
  • Seoul, South Korea

Maheswari Kanniah, CFE

  • Group Chief Regulatory & Compliance Officer, Kenanga Investment Bank Berhad
  • Kuala Lumpur, Malaysia

Andrew H. Kautz, CFE

  • ACFE Faculty
  • Manager, Special Investigations Unit, Great-West Life Assurance Company
  • London, Ontario, Canada

Umaer Khalil

  • Bae, Kim & Lee, LLC
  • Seoul, South Korea

Robert Kilian, CFE

  • ACFE Germany Chapter President
  • Managing Director, DRB Deutsche Risikoberatung GmbH
  • Frankfurt, Germany

Kwang Jun Kim

  • Bae, Kim & Lee, LLC
  • Seoul, South Korea

Mojca Koder, CFE

  • ACFE Slovenia Chapter President
  • Senior Manager in Forensics, PwC Slovenia
  • Ljubljana, Slovenia

Aniket Kolge

  • Senior Manager, EY LLP
  • Mumbai, India

Sara Koski

  • Senior Associate, Compliance, DLA Piper
  • Paris, France

Mihael Kranjc

  • ACFE Slovenia Chapter Board Member
  • CEO, Sasa Accounting Services and Tax Consulting, Ltd
  • Ljubljana, Slovenia

Sharad Kumar, CFE

  • ACFE India Chapter Secretary
  • Officer on Special Duty, Ministry of External Affairs
  • New Delhi, India

Eric Lasry

  • Partner, Baker & McKenzie AARPI
  • Paris, France

Jun Ho Lee

  • Bae, Kim & Lee, LLC
  • Seoul, South Korea

Dr. Sheree S. Ma, CPA

  • ACFE Taiwan Chapter Vice President
  • Professor of Accounting, National Chengchi University
  • Taipei, Taiwan

Sumit Makhija, CFE

  • ACFE India Chapter Vice President
  • Partner, Deloitte Touche Tohmatsu India, LLP
  • Gurgaon, India

Jose Damian Garcia Medina, CFE

  • ACFE Spain Chapter Vice President
  • Corporate Security Director, Vodafone Spain
  • Madrid, Spain

Nicoleta Mehlsen, MBA, CFE

  • ACFE Denmark Chapter Board Member
  • Head of Internal Audit, Danfoss
  • Nordborg, Denmark

Ahmed Mokhtar, CFE, CRMA

  • ACFE Egypt Chapter Board Member
  • Internal Audit Manager, Al-Mansour Automotive
  • Cairo, Egypt

Iyad Mourtada, CFE, CIA, CCSA, CRMA, CSX

  • ACFE Authorized Trainer in the United Arab Emirates
  • Open Thinking Academy
  • Dubai, United Arab Emirates

Bernard M. K. Muchere, CFE

  • ACFE Kenya Chapter President
  • Nairobi, Kenya

Lukelesia Namarome, CFE

  • Nairobi, Kenya

Ralf Neese, CIA

  • Associate Director, DRB Deutsche Risikoberatung GmbH
  • Frankfurt, Germany
  • New Zealand ACFE Chapter members and committee members
  • Qosai Obidat

ACFE Jordan Chapter Board Member

  • Amman, Jordan

Carsten Allerslev Olsen, CFE

  • ACFE Denmark Chapter Board Member
  • Assistant Professor, Copenhagen Business School
  • Frederiksberg, Denmark

Miguel Angel Osma, CFE

  • ACFE Spain Chapter Board Member
  • Investigations & LI Manager, Vodafone Spain
  • Madrid, Spain

Zulhisham Osman

  • Vice President, Group Chief Regulatory & Compliance Officer’s Office, Kenanga Investment Bank Berhad
  • Kuala Lumpur, Malaysia

Luis Navarro Pizarro

  • Lima, Peru

Chris Porteous

  • Senior Forensic Advisory Specialist, Electricity Networks Corporation
  • Perth, Australia

Tony Prior, MBA, CFE, CAMS

  • ACFE Sydney Chapter President
  • Director, Compliance, AUSTRAC
  • Sydney, Australia

Sagar Rajkumar, MBA, CFE, PJSC

  • Risk Management, Finance House P.J.S.C.
  • Abu Dhabi, United Arab Emirates

Andrea Rondot, CFE

  • Manager, Deloitte Forensic
  • Santiago, Chile

George Rostantis, CFE

  • ACFE Cyprus Chapter Secretary
  • Manager Network Audits & Investigations, Internal Audit Division, Bank of Cyprus
  • Nicosia, Cyprus

Pooja Roy, CA

  • Senior Manager, EY LLP
  • Mumbai, India

Raymond A. San Pedro, CPA, CICA

  • ACFE Philippines Chapter Operations Manager
  • Makati City, Philippines

Dong Woo Seo, CFE

  • ACFE South Korea Chapter Board Member
  • Bae, Kim & Lee, LLC
  • Seoul, South Korea

Hazem Adel Shahin, CFE

  • ACFE Jordan Chapter President
  • Amman, Jordan

Sameh Abu Shamaleh, CFE

  • ACFE Jordan Chapter Board Member
  • Finance Director, Adidas Group
  • Amman, Jordan

Mukul Shrivastava, CFE, CA

  • ACFE Mumbai Chapter Vice President
  • Partner, EY LLP
  • Mumbai, India

Rajkumar Shriwastav, CFE, Lawyer

  • ACFE Mumbai Chapter Manager
  • Director, EY LLP
  • Mumbai, India

Arpinder Singh, CFE, CA, Lawyer

  • ACFE Mumbai Chapter President
  • Partner and Head — India and Emerging Markets, EY LLP
  • Mumbai, India

Tae Kyung Sung, PhD, CFE

  • ACFE South Korea Chapter President
  • Kyonggi University
  • Seoul, South Korea

Agis Taramides, CFE, FCA

  • ACFE Cyprus Chapter Treasurer
  • Managing Director, Navigant Consultants Limited
  • Nicosia, Cyprus

Sabrina Tatli-Van der Valk

  • ACFE Netherlands Chapter Treasurer
  • Netherlands

Pedro Trevisan, CFE

  • ACFE Chile Chapter President and Board Member
  • Senior Manager, Deloitte Forensic
  • Santiago, Chile

Sachie Tsuji, CFE, CPA

  • ACFE Japan Chapter Board Member
  • President & CEO, SPLUS Co., Ltd.
  • Tokyo, Japan

Ayumi Uzawa, CFE, CPA

  • ACFE Japan Chapter Board Member
  • Representative, Uzawa Accounting Firm
  • Tokyo, Japan

Adv. Chris van Vuuren, CFE

  • Pretoria, South Africa

Josephat K. Wainaina, CFE

  • Nairobi, Kenya

Loes Wenink, CFE

  • ACFE Netherlands Chapter Events Chair
  • Amsterdam, Netherlands

Caoyu Xu

  • Due Diligence Analyst
  • Menlo Park, California, United States

Toshiaki Yamaguchi, CFE

  • ACFE Japan Chapter Board Member
  • Lawyer, Yamaguchi Law Office
  • Osaka, Japan

Rodrigo Yáñez

  • ACFE Chile Chapter Secretary and Board Member
  • Senior Manager, Deloitte Forensic
  • Santiago, Chile

Sherlyn Yeo

  • ACFE Singapore Chapter Marketing and Event Coordinator
  • Singapore

George Yiallouros, CFE

  • ACFE Cyprus Chapter Board Member
  • Internal Auditor — Investigations, Internal Audit Division, Bank of Cyprus
  • Nicosia, Cyprus

Nagy Mohammed Ibrahim Yousef

  • CEO, Bit Al-khabera Financial
  • Dubai, United Arab Emirates

Daisuke Yuki, CFE

  • ACFE Japan Chapter Board Member
  • Partner Attorney, Nozomi Sogo Attorneys at Law
  • Tokyo, Japan

Hervé Zany, CFE

  • Managing Director, Financial Intelligence & Processing (FIP)
  • Paris, France

About the ACFE

The Association of Certified Fraud Examiners (ACFE) is the world’s largest anti-fraud organization and premier provider of anti-fraud training and education. Together with nearly 85,000 members, the ACFE is reducing business fraud worldwide and inspiring public confidence in the integrity and objectivity within the profession.

Established in 1988, with headquarters in Austin, Texas, the ACFE supports the anti-fraud profession by providing expert instruction, practical tools, and innovative resources in the fight against fraud. The ACFE hosts conferences and seminars year-round while offering informative books and self-study courses written by leading practitioners to help members learn how and why fraud occurs and to build the skills needed to fight it effectively. Members of the ACFE also have the ability to expand their anti-fraud knowledge and assert themselves as experts in the anti-fraud community by obtaining the Certified Fraud Examiner (CFE) credential. This globally preferred certification indicates expertise in fraud prevention, deterrence, detection, and investigation.

The ACFE oversees the CFE credential by setting standards for admission, administering the CFE examination, and maintaining and enforcing the ACFE Code of Professional Ethics.

The ACFE is also committed to providing educational resources to the academic community and has established the Anti-Fraud Education Partnership to address the unprecedented need for fraud examination education at the university level. In pursuit of this objective, the ACFE has provided free training and educational materials to institutions of higher learning throughout the world.

Criminologist and former FBI agent Dr. Joseph T. Wells, CFE, CPA, is chairman and founder of the ACFE. Dr. Wells has lectured to tens of thousands of business professionals, and is the author of 22 books, and scores of articles and research projects. His writing has won numerous awards, including the top articles of the year for both the Internal Auditor and the Journal of Accountancy magazines, and he is a winner of the Innovation in Accounting Education Award presented by the American Accounting Association. He was named nine times to Accounting Today magazine’s annual list of the “Top 100 Most Influential People” in accounting. In 2010, for his contributions to the anti-fraud field, he was honored as a Doctor of Commercial Science by York College of the City University of New York.

Labeled “the premier financial sleuthing organization” by The Wall Street Journal, the ACFE has also been cited for its efforts against fraud by media outlets such as the BBC, U.S. News & World Report, The New York Times, CNN, CNBC, Fortune, ABC-TV’s Nightline and 20/20, and CBS News’ 60 Minutes.

Further information about the ACFE is available at www.acfe.com, or 800-245-3321.

PART I