CFE-Fraud-Prevention-and-Deterrence Certified Fraud Examiner - Fraud Prevention and Deterrence Exam Question and Answers

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​​.

ï‚· Research Findings by Silk and Vogel:

Their research highlights that business leaders often justify non-compliance with regulations by arguing that adhering to such rules significantly increases operational costs and reduces profitability.

ï‚· Rationalization in Legal Violations:

This rationalization is consistent with the fraud triangle concept, where rationalization serves as a justification for unethical or illegal actions.

ï‚· Why A is Correct:

This accurately represents a common justification for regulatory non-compliance as documented in fraud and compliance research​​.

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.

The “Review and Revision” component is focused on evaluating how ERM practices contribute to organizational value and adapting them accordingly.

“As part of its ERM activities, the organization should review how well the ERM capabilities and practices have increased value over time and how they will continue to drive value.”

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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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:

Silk and Vogel’s research found that organizations often rationalize unethical or illegal behavior by diffusing responsibility across a group, thus minimizing perceived individual culpability. This"shared guilt" justification is reflected in option D. The other options either misunderstand the research or do not reflect actual rationalizations used in white-collar crime contexts.

The ACFE Code of Professional Ethics explicitly prohibits CFEs from participating in activities that create undisclosed conflicts of interest. This ensures that the examiner’s objectivity and independence remain intact throughout the investigation. While CFEs are allowed to provide professional opinions based on evidence and engage in legal activities, they must always disclose any potential conflicts of interest.

ï‚· 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.

ï‚· 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.

ï‚· 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​​.

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.”

Corporate Governance in Multinational Corporations:

Multinational corporations must adhere to the legal, regulatory, and governance frameworks of each jurisdiction in which they operate. These frameworks may vary significantly across countries.

Why Other Options are Incorrect:

B:There is no Universal Corporate Governance Act applicable globally.

C:G20/OECD Principles provide guidelines but are not mandatory compliance requirements.

D:Operating in multiple jurisdictions increases governance complexity, but does not exempt corporations from compliance.

Why A is Correct:

It reflects the reality of multinational operations, where governance compliance must align with local laws and regulations​​.

References for All Questions:

ACFE and Treadway Commission fraud prevention guidelines​​.

ISSAI standards and international governance principles​​.

COSO framework and legal requirements for multinational corporations​​.

ï‚· Professional Responsibility Under ACFE Code of Ethics:

The ACFE Code of Professional Ethics requires Certified Fraud Examiners (CFEs) to disclose material information to the proper authorities. When fraud is discovered, the CFE must act in the best interest of the organization while adhering to ethical standards.

In this scenario, Gray must report Green's involvement in unrelated fraud to ABC Corporation's board of directors. This ensures transparency and accountability without breaching client confidentiality unnecessarily.

ï‚· Relevant Principles from ACFE Code of Ethics:

Integrity:CFEs must act honestly and report findings to the appropriate parties.

Objectivity:The CFE must avoid conflicts of interest and ensure impartiality in all findings and disclosures.

ï‚· Board Reporting Responsibility:

Reporting to the board is appropriate because they are responsible for corporate governance and oversight. Law enforcement involvement should follow organizational protocols unless laws explicitly mandate direct reporting​​.

Modern Criminological Studies on White-Collar Crime:Studies highlight that white-collar crimes are often influenced by situational factors rather than inherent criminal traits. The availability of organizational opportunities to commit fraud plays a crucial role.

Analysis of Options:

A. Cultural ties:Less significant in white-collar crime.

B. Criminal history:White-collar criminals often have no prior criminal records.

D. Social class:While white-collar crime is associated with higher social classes, the determinant factor is the opportunity presented within an organization.

C. Organizational opportunity:This aligns with the fraud triangle concept, where opportunity is a primary driver.

Conclusion:Organizational opportunity is the determinant aspect of white-collar crime.

ï‚· Government Auditors' Responsibilities:

Reporting requirements vary depending on jurisdictional laws, regulations, and the specific audit mandates under which the government auditors operate.

Some jurisdictions require direct reporting to oversight agencies, while others may mandate internal reporting within the organization.

ï‚· Why D is Correct:

Government auditors' reporting responsibilities are not uniform globally and are tailored to the legislative frameworks of their jurisdictions and the purpose of the audit.

ï‚· Why Other Options are Incorrect:

A:Reporting requirements are not uniform for all government auditors.

B:Legal prohibitions on external reporting are uncommon but may vary by jurisdiction.

C:Private and public sector reporting standards differ significantly​​.

Routine activities theory identifies three main elements necessary for crime: a motivated offender, a suitable target, and the absence of capable guardians. The lack of accountability for misdeeds is not part of this theory, as it focuses on situational factors that facilitate criminal opportunities rather than broader social or institutional factors.

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ï‚· Statistics on Fraud Prosecution:

Research indicates that many organizations prefer to handle fraud cases internally rather than involving law enforcement due to concerns over reputation, cost, and time.

ï‚· Why B is Correct:

Organizations often resolve fraud cases through internal disciplinary actions, such as termination or restitution, rather than pursuing criminal prosecution​​.

ï‚· Why Other Options are Incorrect:

While internal handling is common, other factors like fear of publicity and legal costs also influence the decision to avoid prosecution.

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.

ï‚· 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.

ï‚· Why D is Correct:

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

ï‚· 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​​.

ï‚· Criminogenic Nature of Organizations:

Research suggests that organizational culture and pressures can override an individual's personal values, especially when authority figures issue direct orders to engage in unethical behavior.

ï‚· Why B is Correct:

Strong personal values do not guarantee resistance to unethical orders, as obedience to authority is a powerful psychological force, as seen in studies like the Milgram experiment​​.

ï‚· Implication for Fraud Prevention:

Organizations must establish strong ethical environments to reduce the influence of authority pressure on employees

Effective Background Check Policies:

Verifying employment history involves more than just confirming dates. It includes understanding job roles, responsibilities, and performance. Solely asking for employment dates does not provide sufficient information to assess fraud risk.

Analysis of Other Options:

B. Background checks for cash-handling roles:This is critical for reducing fraud risks.

C. Background checks for promotions:This ensures that employees in sensitive positions have maintained integrity since hire.

D. Contacting references:Essential to gain insights into the candidate's character and reliability.

Conclusion:Option A is false because it suggests an overly simplistic approach to employment verification.

Fraud Triangle Components:

The fraud triangle consists of perceived opportunity, rationalization, and perceived financial need.

Perceived non-shareable financial need refers to personal pressures, such as debt or addiction, that motivate fraudulent behavior.

Why D is Correct:

Jenny's actions are driven by her inability to share her financial struggles (her husband’s gambling debts) with others, aligning with the perceived financial need leg of the fraud triangle​​.

Why Other Options are Incorrect:

A. Rationalization:Describes justifying fraud, not financial need.

B. Perceived opportunity:Refers to access to resources to commit fraud.

C. Perceived acquiescence:Not part of the fraud triangle.

References for All Questions:

ACFE Fraud Examination Guide and related case studies​​.

International Standards on Auditing (ISA) guidelines, particularly ISA 240​​.

Criminological research on organizational fraud influences and fraud triangle applications​​.

Government auditors, like their private-sector counterparts, must adhere to International Standard on Auditing (ISA) 240, which provides guidance on the auditor’s responsibilities related to fraud. This standard applies to both private- and public-sector audits, emphasizing the importance of addressing risks of material misstatement due to fraud. Alicia must carefully evaluate fraud risks and incorporate relevant procedures, as mandated by ISA 240, ensuring a comprehensive audit approach.

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Behaviorist Theories in Conditioning:

Positive reinforcement, such as offering bonuses, is more effective than punishment in encouraging adherence to policies and reducing deviations.

Employees are more likely to repeat behaviors that are rewarded.

Why C is Correct:

This approach aligns with behaviorist principles, fostering compliance through incentives rather than fear or criticism, which could negatively impact morale.

Why Other Options are Incorrect:

A and D:Punishments may lead to resentment and reduced motivation.

B:Public criticism can create a toxic work environment, discouraging open communication​​.

References for All Questions:

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

ISA and GAAS requirements on unpredictability in audit procedures​​.

Behaviorist theories on employee motivation and conditioning​​.

CFEs must act ethically and responsibly when handling sensitive information. Eliece should inform Jewel that she will try to maintain confidentiality but must adhere to professional and ethical obligations, which may require disclosing the information to appropriate parties such as her employer or relevant authorities. This balanced response encourages transparency while maintaining ethical standards.

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ï‚· Corruption and Fraud Risks:

Corruption involves abuse of power for personal or organizational gain and includes bribery, kickbacks, and aiding vendor fraud.

ï‚· Why B is Correct:

Espionage by competitors is not typically classified as corruption, as it does not directly involve abuse of internal authority or a relationship of trust. It is instead an external threat.

ï‚· Other Options:

A, C, and D are classical examples of corruption-related fraud risks​​.

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 Behavioral Responses:

Positive reinforcement:Increases desired behavior by providing rewards.

Negative reinforcement:Increases desired behavior by removing an unfavorable condition.

Punishment:Reduces undesired behavior by introducing a negative consequence or removing a positive condition.

Application to the Scenario:

Demotion is a punitive action designed to discourage the employee’s poor performance, making it an example of punishment.

Conclusion:The manager’s action aligns with the concept of punishment.

Fraud Risk Assessment Objectivity:

The assessment must remain unbiased, but any prior disagreements or conflicts may highlight areas where policies or procedures are unclear, increasing fraud risks.

Why C is Correct:

Incorporating disagreements provides context to evaluate risks objectively, ensuring that all relevant factors are considered without bias.

Why Other Options are Incorrect:

A:Confronting Brandon could create further conflict without adding value.

B:Delegating the task unnecessarily avoids responsibility.

D:Automatically designating the area as high-risk lacks justification and could undermine credibility​​.

References for All Questions:

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

ISO 31000:2018 guidelines for risk management​​.

Criminological theories related to crime causation and fraud risk assessments​​.

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.

Simple organizational structures often suffer from lack of segregation of duties and fewer levels of oversight. According to the ACFE Manual:

“A simple or poorly designed structure can inhibit accountability and effective oversight. Lack of defined roles and responsibilities can increase the likelihood that fraud will go undetected.”

The ACFE research consistently finds that the majority of occupational fraudsters are first-time offenders. Specifically, “85% of occupational fraud perpetrators had never been punished or terminated for fraud-related conduct prior to the crimes in this study.”

ISO 31000:2018 emphasizes that effective risk management must be integrated into all activities across the organization—not just high-risk ones.

“An effective and efficient risk management program... is integrated into all organizational activities, is structured and comprehensive, and is customized and proportionate to the organization’s operations and objectives.”

Steve Albrecht's Research on Fraud Motivation:

Personal factors like "living beyond their means" are commonly cited as a driver of fraudulent behavior.

Organizational factors, such as excessive trust in key employees, create opportunities for fraud by reducing oversight and enabling unethical behavior.

Analysis of Options:

A. High personal debt:This can be a motivator, but it is less common than "living beyond their means."

B. Revenge:Rarely a primary driver of fraud.

D. Desire for recognition:This may motivate some individuals, but it is not as prevalent as financial pressure and opportunity.

Conclusion:Option C reflects the most common personal and organizational factors motivating fraudsters.

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.

Rational Choice Theory Overview:

This theory asserts that individuals make conscious decisions to commit crimes after weighing the costs (risk of detection and punishment) and benefits.

Why D is Correct:

Rational choice theory aligns with strategies to deter crime by reducing opportunities and increasing personal risks.

Why Other Options are Incorrect:

A (Differential association theory):Explains crime as learned behavior.

B (Routine activities theory):Focuses on environmental factors.

C (Justification of action theory):Not a recognized criminological theory​​.

References for All Questions:

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

Criminological theories and governance frameworks in fraud prevention​​.

Case studies on indirect fraud costs and ethical decision-making​​.

ï‚· Due Diligence in High-Corruption Risk Transactions:

When operating in high-risk environments, enhanced due diligence is critical. This includes evaluating payment methods, transaction patterns, and the customer's reputation.

ï‚· Why A is Correct:

Analyzing purchasing patterns and payment methods helps identify red flags such as unusual payment terms or volumes inconsistent with Green’s business profile.

ï‚· Why Other Options are Incorrect:

B: Due diligence is necessary regardless of payment terms.

C: Enhanced due diligence for high-risk countries does not constitute discrimination.

D: Ignoring due diligence poses significant compliance and reputational risks.

ï‚· References:

ACFE guidance on due diligence and anti-corruption practices in global commerce​​.

ï‚· ACFE Code of Professional Ethics:

Fraud examiners must avoid expressing opinions about guilt or innocence. They are tasked with presenting evidence and findings objectively, leaving determinations of guilt to legal or regulatory authorities.

ï‚· Why A is Correct:

Maria’s statement that "Rita is guilty" constitutes a violation because it goes beyond the role of a fraud examiner.

ï‚· References:

ACFE standards emphasize objectivity and avoidance of subjective judgments in fraud reporting​​.

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.

Focus of Risk Management:

Risk management seeks to balance the organization's risk appetite (the level of risk it is willing to accept) with its ability to achieve objectives.

Why D is Correct:

Effective risk management aligns the organization's risk tolerance with its strategic and operational goals to ensure sustainability and success.

Why Other Options are Incorrect:

A, B, and C:While internal controls, regulatory requirements, and resources are critical, the primary balance is between risk appetite and objectives​​.

References for All Questions:

ACFE Fraud Examination Guide and Risk Management Best Practices​​.

COSO frameworks for internal controls and fraud risk management​​.

Industry guidance on effective deterrence and governance practices​​.

ï‚· COSO Internal Control Framework Components:

The five components are:

Control Environment

Risk Assessment

Control Activities

Information and Communication

Monitoring Activities

ï‚· Why C is Correct:

Independent oversight, while important in governance, is not explicitly listed as one of the five COSO components. It may relate to broader governance structures but is not a core component of the internal control framework.

ï‚· References:

COSO Internal Control–Integrated Framework​​.

Fraud Response Responsibilities:

Management is responsible for responding to fraud because they oversee the organization's operations, culture, and compliance frameworks.

Other parties, such as internal auditors and the audit committee, provide oversight and recommendations but do not directly implement responses.

Conclusion:Management has the ultimate responsibility for responding appropriately to fraud.

ï‚· Diane Vaughan's Theory on Organizational Crime:

Vaughan argued that organizational environments prone to crime exhibit a "normalization of deviance," often influenced by management decisions that misalign employee incentives with organizational objectives.

ï‚· Why C is Correct:

Misaligned goals create conflicting priorities, increasing the likelihood of unethical behavior to meet individual or team objectives.

ï‚· Why Other Options are Incorrect:

A:Challenging the status quo promotes innovation and ethical accountability.

B:Social functions fostering loyalty do not inherently encourage crime​​.

Findings from the 2020 Report to the Nations:

Asset misappropriation:Most common form of occupational fraud (e.g., theft of cash or inventory). It is frequent but less costly.

Financial statement fraud:Most costly, involving significant manipulation of financial data.

Analysis of Options:

A. Asset misappropriation; corruption:Corruption is less costly than financial statement fraud.

B. Corruption, asset misappropriation:Incorrect order and does not match the costliest scheme.

C. Financial statement fraud; corruption:Incorrect pairing.

Conclusion:Asset misappropriation is most common, and financial statement fraud is most costly.

The G20/OECD Principles call for a corporate governance framework that ensures “the equitable treatment of all shareholders including minority and foreign shareholders.” This principle reinforces fairness and equal rights in governance systems.

“The Principles… call for a corporate governance framework that protects the exercise of shareholders’ rights and supports the equal treatment of all shareholders including minority and foreign shareholders.”

ï‚· Fraud Prevention Methods:

Prevention strategies often focus on education, awareness, and robust controls rather than covert methods. While covert audits can detect fraud, they are not primarily preventive.

ï‚· Why D is False:

Covert audits are reactive and focused on identifying existing fraud, not preventing it.

ï‚· Why Other Options are True:

A, B, and C accurately describe key aspects of fraud prevention, such as the importance of perception of detection and the challenges of detecting fraud​​.

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.

Comprehensive and Detailed in Depth Explanation:

ISA 240 (The Auditor's Responsibilities Relating to Fraud in an Audit of Financial Statements) outlines the auditor's responsibility to assess and respond to the risk of material misstatement due to fraud. It does not impose a primary responsibility for fraud prevention and detection upon auditors—that responsibility lies with management (eliminating C). The standard also does not require auditors to actively raise fraud awareness within the organization (eliminating A), nor does it establish requirements for fraud risk management programs for management (eliminating D).

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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Elements of Routine Activities Theory:

This theory posits that crime occurs when three elements converge:

Availability of suitable targets.

Absence of capable guardians.

Presence of motivated offenders.

Analysis of Other Options:

A. Conditioning theory:Focuses on learned behaviors through reinforcement.

C. Rational choice theory:Examines decision-making processes of offenders.

D. Social control theory:Relates to societal bonds preventing deviant behavior.

Conclusion:Routine activities theory best explains the convergence of these elements leading to crime.

Comprehensive and Detailed in Depth Explanation:

The G20/OECD Principles of Corporate Governance advocate for transparent and fair markets and the efficient allocation of resources, making Option A the correct statement. These principles are internationally recognized as a standard for policy makers, investors, corporations, and other stakeholders worldwide. The principles are intended to apply to both developed and emerging markets, not justemerging ones (rejecting Option C), and while influential, they are not legally binding mandates (rejecting Option D). They also support the equitable treatment of shareholders, regardless of share class (rejecting Option B).

External auditors are required to report significant deficiencies and material weaknesses in internal control to those charged with governance. The ACFE manual states:

“Auditors must communicate in writing to those charged with governance all significant deficiencies and material weaknesses identified during the audit.”

Corporate Governance Principles:

Transparency refers to disclosing material matters, enabling shareholders to make informed decisions.

This includes providing timely and accurate information about the company's financial performance, risks, and governance practices.

Analysis of Other Options:

B. Fairness:Involves equitable treatment of all shareholders.

C. Responsibility:Focuses on fulfilling legal and ethical obligations.

D. Accountability:Pertains to holding the board and management responsible for their actions.

Conclusion:Transparency ensures shareholders have the necessary information for decision-making.

Routine activities theory holds that crime occurs when three elements converge: (1) a motivated offender, (2) a suitable target, and (3) the absence of a capable guardian. “The lack of societal ethics” is not part of this theoretical model.

The ACFE manual emphasizes “tone at the top” as a foundational element of a strong ethical culture.

“Management must show employees through its words and actions that dishonest or unethical behavior will not be tolerated.”

ï‚· 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.

ï‚· 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.

ï‚· 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​​.

Collusion between contractors is an example of external fraud risk because it involves external parties conspiring to defraud the organization. The other options describe internal fraud risks, such as actions committed by employees within the organization.

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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.