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• Over two decades of ACL and Excel software usage• Wrote the first practical ACL publication on how to
use the product in 101 ways (101 ACL Applications)
• Has written and spoken on the use of audit data analytics for over 15 years.
• Received the Outstanding Achievement in Business Award by the Association of Certified Fraud Examiners for developing the publication Proactively Detecting Fraud Using Computer Audit Reports as a research project for the IIA
• Recently was a contributing author of:• Global Technology Audit Guide (GTAG #13) Fraud
in an Automated World - IIA• Data Analytics – A Practical Approach - research
whitepaper for the Information System Accountability Control Association.
• “Cost Recovery – Turning Your Accounts Payable Department into a Profit Center” – Wiley & Sons.
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Duplicates on card number, amount, and transaction date
Duplicates on merchant, amount, and transaction date (regardless of card)
Duplicates on merchant and amount
Duplicates on cardholder and amount
A multitude of transactions under the card purchase limit or MCC amount limit to identify split purchases on the card to purchase higher amount items using multiple charges.
Postings to unusual MCC codes
Align the P‐card to T&E system to ensure merchant and amounts line up for each transactions
Violating Statistical Patterns to the Norm• Supplier values that are deemed exceptional after applying regression and standard
deviation calculations• Invoice amount values themselves that appear unusual based on the number's digits and
past patterns• Suppliers who have a large percentage of rounded‐amount invoices or in sequence invoice
numbers.
Conflicting External Data • Supplier addresses not listed in Google Maps• Supplier matches to a world compliance “watch list”• Google Maps shows supplier (business) address to be an apartment or other personal
residence
Timing Differences• Suppliers who are consistently paid quickly, typically in less than 10 days• Checks cut on a weekend or after‐hours based on time stamps• Unusual increasing or decreasing trends across business quarters for a supplier
Sample Red Flag Vendor Reports (Focus on the potential accomplice )
1. Employees with low transaction, high dollar activity ‐ 20
2. Employees with a high proportion of round dollar payments. ‐ 25
3. Payments to any employees that exceed the twelve month average payments to that employee by a specified percentage (i.e., 200%) or 3x the standard deviation for that vendor. ‐ 20
4. Employees with a high proportion of charges near approval limits ‐ 35
Instead of selecting samples from reports, transactions that meet multiple report attributes are selected (kill more birds with one stone). Therefore a 50 unit sample can efficiently audit:
Who can have the card / Who cannot have the card (former employees, non‐employees, agents/students/vendors)
Reconciliation procedures
What can and cannot be purchased with the card
Restricting use to organizational business needs
How to get the card
How to handle exceptions and irregularities
How a card can and should be deactivated
How to get help
Cardholder agreements
Rights and responsibilities of the cardholder, department manager responsible for managing card usage, department manager, organization and card‐issuer