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B e s t P r a c t i c e s T a s k F o r c e

Establishing and Maintaining a

Purchasing Card Program with

Adequate Management Controls

to Prevent Fraud, Misuse, and Abuse

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TABLE OF CONTENTS

@

Acknowledgements

@

Overview

@

Distinguishing Between Fraud and Misuse

#

Integrating Fraud Deterrents in

Program Design — Planning and Preparation

#

Prevention

Systemic Controls Policies

Establishing Roles and Responsibilities Procedures

Security in Card Handling

&

Detecting Fraud and Employee Misuse

Auditing Reconciliation

Your Suppliers’ Role in Reducing Fraud

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Using Reports and

Queries for Early Detection

Declined Transaction Analysis Activity Analysis

Disputed Charges Analysis Account Listing

BL

Conclusion

BM

Appendix — Sample Employee Agreement

BN

Index

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Acknowledgements

The following members of the NAPCP Best Practices Task Force contributed to this document:

Tamara Corbin, Spherion,Tony Giarnella, Mellon Financial, Anne Hawley, City of Portland, Oregon Alex Julewitz,Wright Express, Cynthia Martin, U.S. Dept. of the Interior, NAPCP Subcommittee Team Leader, Eddie Page, Eastman Chemical Company, Julia Stout Black and Veatch Wanda Waite, PPG Industries,Terri Westmoreland, Lansing Community College,Tom Wissel, UPS, NAPCP Best Practices Task Force Chair

Overview

Media reports of employee misuse of Purchasing Card programs, particularly in publicly funded organizations, often are front-page items. Publicity surrounding these incidents would lead one to the conclusion that fraud is rampant within commercial card programs. In actuality, however, research conducted by Richard Palmer and Mahendra Gupta in 2003 indicates that Purchasing Card misuse accounts for an average of $270 of misuse for every $1 million of card spend and that the incidence of misuse in the public sector is lower than that reported in the private sector.1Nevertheless, real or perceived laxity of controls and insufficient oversight within a

Purchasing Card program can result in withdrawal of management support and the diversion of activity to alternate means of procurement and settlement.

This document is intended to serve as a valuable tool to administrators of Purchasing Card programs interested in minimizing the potential for fraud and misuse of the card within their organization. Several types of controls can be designed in the card function or the organization’s policies and procedures to reduce exposure to loss. Other techniques will focus on an auditing process that may help detect misuse and limit financial loss.

Distinguishing Between Fraud and Misuse

The terms “fraud” and “misuse” or “abuse” are often used interchangeably in describing unauthorized credit card activity.These terms actually are more limited, and a distinction should be made between them:

• Fraud involves unauthorized use of the card by someone other than the individual to whom it was issued.This may include stolen cards, counterfeit cards, or identity theft. Credit card fraud could be committed either by individuals outside the organization or by your own employees. It may also involve non-employees or former employees working in collusion with those on the inside of the company.

• Merchant fraud is another example of unauthorized activity, and involves charges for goods or services not provided charged by a merchant to a credit card.

• Misuse (or abuse) involves unauthorized activity or purchasing by the employee to whom the card is issued. Misuse covers a wide range of violations, some of which are more severe than others. For example, misuse could include poor asset management resulting from buying a larger quantity than necessary, purchasing materials or goods of a higher quality than the organization would deem appropriate, or buying from unauthorized suppliers. Using the Purchasing Card for personal gain would represent a serious abuse of the card.

B e s t P r a c t i c e s T a s k F o r c e

@

1Palmer, R., and M. Gupta, “2003 Purchasing Card Benchmark Survey,” (RPGM Research, 2003), available through the

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Liability differs for fraud and misuse. Unauthorized use by an employee is the responsibility of the employer. Card associations and issuers may provide some form of liability protection for employee misuse. Program administrators should check with their issuer to determine availability and conditions of liability waiver protection. Fraud perpetrated on a commercial credit card is not covered under the consumer protection legislation, however, and program administrators are advised to consult their issuer for details on liability and charge back rights.

Integrating Fraud Deterrents in

Program Design — Planning and Preparation

It is important to integrate appropriate system controls within a Purchasing Card program. These include guidelines for card issuance, policies, procedures, credit limit controls, velocity controls, merchant blocking, reconciliation processes, and auditing procedures.The optimal time to embed these controls is in the design stage of a new program. Controls, however, can be strengthened or incorporated into existing programs.

During the design phase of a program, a team drawn from multiple business functions can help secure consensus and support for the controls that will be integrated into the program. A cross-functional approach will also facilitate a unified strategy relating to what types of purchasing or commodities are within the scope of the Purchasing Card, what constitutes inappropriate use of the card, and the repercussions for policy violations.The design team should determine what management controls are needed to regulate and monitor purchases. Functional representation during the design phase may consist of Finance and Accounting, Procurement, Internal Audit, Information Technology, as well as other areas.

Other suggestions to be considered during the design stage are: • Intended card distribution

• Approval levels required for card issuance • Reporting requirements

• Standard and ad hoc reporting needs • Access to information

• Communication strategy

• Selection of a card design (if available) — appearance that readily distinguishes it from a consumer card will reduce confusion

• Testing of controls — Internal Audit should be involved in salting the process to ensure controls are working as intended

Prevention

Several features can be included in a Purchasing Card program to reduce exposure to loss from fraud or misuse.

S

YSTEMIC

C

ONTROLS

Controls limiting the incorrect use of Purchasing Cards are a key feature of any program.These controls consist of any of the following (Note: not all features are available for all card issuers):

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• Single transaction limits

• Monthly or cycle spending limits • Merchant category blocks

• Velocity controls (limits the number of times a card can be used within a specified period of time)

• Multi-tiered restrictions (higher spending limits may be established for preferred suppliers, with lower limits for non-preferred suppliers)

• Store-front merchant blocking (limits a particular merchant site that can be used) Purchasing Card Program Administrators typically employ one or more of these controls to limit the company’s exposure to misuse or loss from fraud. Excessive restrictions, however, may result in maximum benefits from the card not being realized. For example, very restrictive Merchant Category Code blocks may result in transactions being declined for legitimate business purchases. Frequent declined transactions for legitimate business purchases will involve extra time for the employee to ultimately make the purchase, and will impact the acquisition cost to some extent.

P

OLICIES

Policies can range from very general guidelines for card use to very specific attempts to address all foreseeable situations. Generally, policies prohibit activities such as personal use, transaction splitting, and card sharing.

• Personal use is not permitted by most organizations due to corporate liability for charges placed on the Purchasing Card.

• Cash access, whether it be through an ATM, convenience checks, or through a bank teller transaction, is generally prohibited in most Purchasing Card programs. Some organizations, however, do utilize this feature under some circumstances.

• Transaction splitting involves a merchant splitting a purchase that exceeds the single transaction limit placed on the Purchasing Card into two or more smaller transactions to facilitate transaction authorization.Transaction splitting circumvents an important systemic card control feature. • Sharing of cards by employees dilutes the organization’s ability to hold the employee accountable

for card activity. Cards are typically issued in the name of an employee and that employee is responsible for the security of the card, as well as the charge activity that occurs on it. If the organization sanctions card sharing, it may result in policies that are less easily enforced if fraud or misuse occurs. In addition, suppliers who diligently attempt to reduce credit card fraud by verifying the identity of the cardholder should decline the card if presented by someone other than the cardholder. Some organizations use department cards or “no name” cards to increase their purchasing flexibility.These cards do not provide for merchant charge back or disputes because the merchant cannot authenticate the cardholder.

• “Ghost Cards” provide an alternative implemented by many organizations to reduce the opportunity for card sharing or the widespread issuance of cards to employees who deal exclusively with one supplier. “Ghost Cards” are so-named because a credit card number is issued without the production of a charge card (“the plastic”).The card number is used in transactions with the supplier as though the card were in the buyer’s possession.These “cards” function well when transactions with a supplier are executed electronically or on the phone without the card being physically present. Ghost Cards are not suited for all types of procurement activity, but should be considered when appropriate.

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Policies also generally identify the job role or position that should be issued a Purchasing Card and nature of purchasing that should be completed using the card.

In establishing policies for card use, it is likely these policies may change over time.Thought should be given to the process for communicating policy changes to the cardholders. Suggested communication methods may involve a “push” strategy (broadcast voice mail messages, e-mails) complemented by a “pull” strategy, such as the company’s internal pipeline (intranet, other communication vehicles).

E

STABLISHING

R

OLES AND

R

ESPONSIBILITIES

The roles and responsibilities for each individual involved in the Purchasing Card internal supply chain should be clearly defined to minimize gaps in accountability.

The Program Administrator plays a key role and is the company’s primary liaison with the card issuer.The Program Administrator’s responsibilities include managing card issuance and maintaining related credit limitations. In addition, the Program Administrator is authorized to cancel cards, suspend accounts, and report suspected employee misuse of the card.

Managers, supervisors, and approvers are responsible for oversight and monitoring of cardholders’

compliance with company policy and procedures. All approvers should be required to complete the Purchasing Card training.While each organization may define the roles for managers, supervisors, and approvers differently, responsibilities may include:

• Review billing statements and supporting documentation on at least a monthly basis. • Sign the front of each employee’s monthly statement as indication review and approval of

all transactions have been completed.

• Investigate and report instances of apparent misuse to the appropriate manager. • Make sure employees are trained in the proper use of the card.

• Monitor spending patterns and vendor sources (a sudden unexplained increase in purchases or questionable vendor sources may indicate a problem).

Employees are responsible for the security of their Purchasing Card, using the card only for

official authorized purposes, reviewing their monthly statement each month, and verifying purchases. Errors and discrepancies must be promptly identified and disputed. Employees must also maintain accurate and complete records supporting their Purchasing Card transactions, including original receipts and any required approval. Cardholders are the key control to protect the organization against outside fraud and must fulfill their role of statement review.

The card issuer typically has fraud detection systems in place and is instrumental in detecting fraud based upon out-of-pattern purchases.

P

ROCEDURES

Procedures establish the guidelines for approvals, supporting documentation requirements, approval for card issuance, changes in card account maintenance, receipt retention, etc. Key elements that are typically addressed by procedure manuals include:

• General information about the program • Background and reference information • Statement of purpose

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• Requirements for obtaining a card • Roles and responsibilities

• Cardholder

• Supervisor/Approving manager • Program administrators • Administrative

• Orientation and training • Lost or stolen cards

• Exit procedures for closing account and retrieving card • When and where the card can be used

• Where the card cannot be used • How to obtain and activate a card • Purchasing procedures

• Accounting distribution process

• Reconciling, reviewing and approving accounts • Reports

• Disputes

• What happens if fraud, misuse or abuse is suspected or occurs

With respect to fraud prevention, procedures should define the authorization required for card issuance. Several key controls are usually established at the time a card is issued, including the merchant blocks and credit limits placed on the card.The individual authorizing should be in an appropriate position of responsibility within the organization. Some companies, for example, require the authorizing manager to have budgetary responsibility. Procedures should also specify the approvals required to change card restrictions or the relaxation of controls.

Procedures should also address the documentation required to support purchases. For example, cardholders may be required to submit a billing statement or Web-accessed statement that is unalterable by the cardholder. Substitutions for this documentation could possibly be altered by the cardholder intent on misrepresenting what was actually purchased.The procedure also should specify the type of receipts required to be turned in to support the expenditure and to satisfy the requirements of the IRS and state tax agencies. Sales drafts frequently do not provide much information about what was purchased. An itemized receipt or invoice typically provides more information about the nature of the purchase.

Internal procedures should also be in place to monitor the cardholder population. For example, if an interface does not exist to ensure only active employees have cards, a scheduled review should be performed to identify terminated employees and those on temporary leaves of absence. Even though your organization may have a well-defined exit process to retrieve the card, some employees leave their job by simply not showing up. It is worth considering having a procedure in place to backstop the normal process.

Many companies also require employees to sign an agreement form that specifies the responsibilities and guidelines governing the Purchasing Card. Key features of typical employee agreements include:

• Acknowledgement the employee has been informed of the policies and understands them • Employee understands that violations of the policy may result in disciplinary action • Employee agrees to make restitution to the company for personal use

• Employee agrees to surrender the card on demand Employee Agreements should be kept on file by the company.

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S

ECURITY IN

C

ARD

H

ANDLING

Some basic steps can be taken to reduce the risk of cards falling into the wrong hands prior to distribution to the employee. If possible, duties should be segregated so that the individual responsible for ordering cards is not the same individual who receives the cards from the issuer. Cards are sometimes pilfered in transit between the issuer and the recipient. In most cases, it is difficult to activate the card without the secure information required by the issuer. In some cases, however, this information could be obtained and the card activated. Be suspicious if the cards appear to have been tampered with in transit, and verify with the issuer the cards that should have been received in a particular shipment if this is the case.

When using internal distribution channels to deliver the card to the employee, it is best to make sure the packaging does not indicate “Credit Card Enclosed” or other such wording. Pilferage can be reduced by packaging the card to appear as normal internal correspondence.

Detecting Fraud and Employee Misuse

A

UDITING

An audit will include not just a review of transactions but also an interview with cardholders to learn whether or not they understand the requirements and process for complying.This confirms that the education related to policies and procedures has in fact taken place and the concepts retained by the cardholders.

With respect to fraud, auditing programs typically follow two approaches: attribute testing and transactional auditing. Attribute testing involves assessment of the internal controls to prevent fraud or improper activity. Specific attributes, such as a personal purchase on the card, will be traced through the process to see how the various controls operate to prevent or detect the activity. If the controls are found to be ineffective, modifications or supplemental controls may be necessary.

Transactional auditing is one of the primary fraud detection tools .While the level of activity in most programs precludes the option to review every transaction, some form of random audit supplemented by auditing of high-risk areas may detect improper use of the card. Audit sample selection methodology should be consistent with your organization’s internal audit procedures; however, cluster sampling, in which every nth cardholder is audited rather than every nth trans-action, may allow inappropriate activity to go undetected.

Your policies and procedures should be integrated within your audit work papers or procedures. Areas that might be included for review in the auditing process are:

Documentation

• Are the receipts or other supporting documentation compliant with your company policy? • Are the receipts detailed enough to identify what was purchased?

• Based on the signatures on sales drafts, does it appear the employee is sharing the card with others?

• Are the receipts altered in any way?

• If applicable, is the number of missing receipts acceptable?

• If receipts are missing, does the nature of the purchase indicate possible inappropriate use of the card?

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Approvals

• Were the proper approvals obtained for: • Card issuance?

• Account maintenance? • Approvals of purchases?

Expense control

• Did the purchaser obtain favorable pricing from the supplier? • Are preferred suppliers used?

• Is the quantity purchased appropriate?

Procedural compliance

• Are policies and procedures being followed? • Is there any indication of transaction splitting?

High-risk transactions should also be included in the regular audit scope.These would include high dollar transactions (compliance with organization’s procurement procedures), large number of transactions by employee, and analysis of Merchant Category Codes that may not represent a legitimate business purchase.

Utilizing some basic auditing principles will make the process more effective: • Audits should be scheduled, unannounced, and random

• All cardholders should be audited at a minimum of once a year; however, many organizations prefer semi-annual audits

• High-risk items should be audited more frequently.These may include:

• Auditing the cardholders with the most transactions monthly (the number to be audited should be determined in conjunction with Internal Audit or an appropriate manager) • Auditing the cardholders with the highest dollar amount of spend monthly • Auditing purchases that are charged out to clients

• Audit employees with multiple disputed transactions monthly • Audit documentation for unusual merchant codes monthly • Audit frequency may be stepped up for those with exceptions

Employees who have recently been trained should be audited for the first cycle or longer to assess compliance with policies and procedures and to determine if retraining might be in order. Managers of newly-implemented programs might also increase the audit sample in the beginning for the same reasons.

R

ECONCILIATION

One of the first lines of defense against credit card fraud is the cardholder.Through a timely review of the card activity and a reconciliation of the charges on the card (matched back to documentation, receipts, purchasing records, etc.), unauthorized charges can be identified and the card reported stolen or compromised.This is also effective in identifying merchant fraud or other forms of fraudulent use, such as account takeover, counterfeit cards, Internet fraud, etc.

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Y

OUR

S

UPPLIERS

’ R

OLE IN

R

EDUCING

F

RAUD

The suppliers with whom you do business are also a resource to help reduce unauthorized activity on your Purchasing Cards. Based on how familiar your vendors are of how and what your employees purchase, suppliers may alert you to fraudulent purchases. In addition, you should request your suppliers provide detailed statements or invoices listing the items or services purchased. (Note: Invoices should clearly indicate the charges were processed on a credit card or show no balance due to prevent possible duplicate payment).

You should also request your suppliers do not keep your card numbers on file and use them as a house account (with the exception of “ghost card” or supplier card applications). Several employees from different business units, with different purchasing restrictions, may all use the same vendor. Commingling the purchases on one card or an incorrect card may lead to unnecessary disputes of the charges and added expense for all involved. It also may dilute the accountability by the cardholder for purchases made on his or her card.

Using Reports and Queries for Early Detection

Development of a standard reporting suite can keep management aware of card usage and compliance with policies and procedures. Reports, in conjunction with the ability to query your transaction level data and produce ad hoc reports, can assist in the early detection of inappropriate or fraudulent card activity.

D

ECLINED

T

RANSACTION

A

NALYSIS

A review of declined transactions may spot merchant fraud in progress. For example, if a merchant has the card number but does not have the card verification code or expiration date, multiple declines for these reasons may indicate the merchant is using trial and error.

Declined transactions for non-business-related Merchant Category Codes (MCC) may also indicate fraud or attempted misuse by the employee. Particular attention should be paid to those MCCs that involve cash access.

A

CTIVITY

A

NALYSIS

A review of card transactions to identify unusual activity may be an early indicator of misuse. Program administrators should review transaction detail for high volume of charges, particularly those of a retail nature.This may indicate a stolen or counterfeit card.

Multiple transactions by the same cardholder with the same supplier on the same day should be evaluated to determine if the employee is attempting to circumvent the spending controls placed on the card. In some cases, however, multiple transactions may be completely in compliance with the company’s policy regarding transaction splitting.

A list of potential “taboo” MCCs may be useful to match up to card activity.This list could consist of those MCCs which should have no relation to your line of business, as well as those that might be marginally related.

Another type of analysis might look for activity that is cash convertible, such as gift certificates.

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These are typically purchased in even dollar increments ($20.00, $50.00, etc.).While this in itself may not represent inappropriate use, it may indicate misuse by the employee.

D

ISPUTED

C

HARGES

A

NALYSIS

A history of disputed charges may indicate an employee requires retraining in the proper procedure to resolve merchant discrepancies, but it may also mean improper purchasing behavior. A high frequency of disputes involving a single merchant may also indicate merchant fraud.This pattern might not be visible without analyzing dispute patterns for the entire organization.

A

CCOUNT

L

ISTING

The roster of employees issued cards should be reviewed to determine current need based on the employee’s job responsibility.This report can be made more useful by indicating cards that have not been used within a specified time frame, such as six months. Periodic review by management will create an awareness of employees with active Purchasing Cards and will identify cards that may no longer be needed due to a change in the employee’s job responsibilities.This report may also be distributed to Human Resources to assist in retrieval of the card as part of the employee exit process.

Conclusion

There are many controls and reports available to managers of Purchasing Card programs to help control exposure to fraud and misuse.This guide offers several suggestions to deter fraud and to identify misuse in an early stage.While it may be tempting to try to lock down every conceivable element of risk, there may also be a corresponding tradeoff in flexibility.

Organizations must attempt to find the balance that is compatible with their corporate control culture.Those organizations that are unable to find this balance between control and flexibility risk failure to achieve the maximum benefit from their programs.

Users of this material should keep in mind that misuse of the Purchasing Card remains a small percentage of the total transactional traffic on the card. Misuse cases could be accurately described as being concentrated in relative few organizations rather than pervasive throughout all Purchasing Card programs. In the 2003 Purchasing Card Benchmark Survey Results, Gupta and Palmer reported that 4% of the organizations reporting card misuse account for 70% of the dollars involved.1

Gupta and Palmer also noted that the major processing savings associated with Purchasing Card programs is attributed to the shift from pre-purchase control to post-purchase review. Nearly two-thirds of misuse incidents are identified through internal controls and the internal audit process. Organizations that incorporate controls, institute an effective review process, and follow adequate security procedures reduce their exposure to fraud. Audit samples can be very specific to target detection of certain types of exceptions, making them more efficient, as well as effective. Many organizations have come to recognize that, by incorporating appropriate process-es and educating the partiprocess-es involved, the Purchasing Card posprocess-essprocess-es appropriate controls that have allowed them to detect fraud that had been occurring using traditional payment processes. In summary, the Purchasing Card trades up-front approval for improved back-end accountability. In designing a program, recognition of the importance of the tools to support that accountability will lead to a better product that takes advantage of the cost benefit associated with the card.

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APPENDIX 1 – Sample Employee Agreement

I, _______________________________, hereby acknowledge receipt of a COMPANY NAME Purchasing Card. I have verified the information contained on the COMPANY NAME Purchasing Card and attest to its accuracy.

I also agree to the following regarding my participation in the COMPANY NAME Purchasing Card Program:

 I understand I am being entrusted with a COMPANY NAME Purchasing Card and will be making financial commitments on behalf of and for the benefit of COMPANY NAME and its affiliated corporations and subsidiaries and will strive to obtain the best value for such corporations.  I agree to use the COMPANY NAME Purchasing Card only for actual and necessary business

expenses, and that under no circumstances will I use or permit others to use the COMPANY NAME Purchasing Card to make personal purchases or purchases unrelated to the business of COMPANY NAME and its affiliated corporations and subsidiaries. I further agree that during the term of this agreement, I am the only individual entitled to make purchases for the benefit of COMPANY NAME and its affiliated corporations, and I will not allow any other individual, whether employed by COMPANY NAME or its affiliated corporations, to use the COMPANY NAME Purchasing Card.

 I have been given a copy of the COMPANY NAME Purchasing Card Program Guide and understand the requirements for using the COMPANY NAME Purchasing Card.

 I will follow the established procedures set forth in the COMPANY NAME Purchasing Card Program Guide for using the Purchasing Card. I understand that failure to do so may result in either revocation of my use privileges or other disciplinary action, including, but not limited to, termination of my employment.

 I further agree that should I willfully and intentionally misuse or permit the misuse of the COMPANY NAME Purchasing Card for purposes other than those specified herein or in the COMPANY NAME Purchasing Card Program Guide, I will reimburse COMPANY NAME or its affiliated corporations for all incurred charges and any fees related to the collection of those charges and do all such other things to remedy the situation.

If the card is lost, stolen, or misplaced, I will immediately notify ISSUER by telephone. I will also inform the COMPANY NAME Card Administrator of this loss. I understand that failure to notify ISSUER of the theft, loss, or misplacement of the COMPANY NAME Purchasing Card will make me personally responsible for any fraudulent or unauthorized use. I also understand that unauthorized use of the COMPANY NAME Purchasing Card may result in immediate disciplinary action, up to and including termination of my employment.

I agree to surrender the COMPANY NAME Purchasing Card immediately upon my transfer, retirement or any termination of my employment, or upon the request of any authorized representative of COMPANY NAME. I understand that use of the COMPANY NAME Purchasing Card after privileges are withdrawn is strictly prohibited.

(Signed and dated by Employee and Manager)

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About The National Association of Purchasing Card

Professionals:

The National Association of Purchasing Card Professionals (NAPCP) is a non-profit professional trade association committed to the advancement of Purchasing Card professionals and practices. The NAPCP is a resource for Purchasing Card professionals at all levels — from novice to expert. It provides the Purchasing Card industry with a broad and in-depth forum for news and information, networking, and professional education for end users, card associations, card issuers, and solution providers.

P.O. Box 184 Excelsior, MN 55331 Phone: (952-470-0379) Internet: www.napcp.org

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B e s t P r a c t i c e s T a s k F o r c e

About NAPCP ...12 Approvals Card issuance ...6 Auditing ...7 High-risk elements ...8 Sample ...8 Scope ...7 Card design ...3 Card distribution ...3 Card handling ...7 Card sharing ...4 Cash access...4 Controls Merchant blocks ...4 Storefront blocking ...4 Systemic ...3 Testing ...3 Tiered...4 Velocity ...4 Declined transactions ...4 Documentation ...6 Employee agreement ...6, 11 Fraud Defined ...2 Merchant, defined ...2 Ghost Cards ...4, 9 Liability ...3 Limits Monthly ...4 Single transaction...4 Misuse Detection ...7 Employee, defined ...2 Frequency ...2 Monitoring cardholders ...6 Personal use ...4 Policies ...4 Communicating ...5 Procedure manuals ...5 Procedures ...5 Reconciliation ...8 Reporting Strategy ...3

BN

Reports Activity analysis ...9

Cards issued review ...10

Cash convertible purchases ...9

Declined transaction analysis ...9

Detection tool ...9

Disputed charges...10

Roles and responsibilities ...5

Employees ...5 Issuer ...5 Management ...5 Program administrator...5 Suppliers’ role...9 System controls Design phase...3 Transaction splitting ...4

INDEX

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