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(1)

Accounts Payable Best Practices

(2)

Accounts Payable Best Practices

(3)

AP Top Practices

Document your current AP procedures

Can identify overlapping work

Can identify possible weaknesses in controls

Helps develop new staff

(4)

AP Top Practices

(Cont)

Document your current AP procedures

(Cont)

Areas to identify:

– Key personnel

– Major classes of transactions

– Risks inherent in the process

– I.T. systems

– Work flow

– AP controls

(5)

AP Top Practices

(Cont)

Document your current AP procedures

(Cont)

Areas to identify:

– Key personnel

– Controller/Finance Director

– AP Supervisor

– AP Clerk

– Major classes of transactions

– Receiving invoice from vendor

(6)

AP Top Practices

(Cont)

Document your current AP procedures

(Cont)

Areas to identify:

– Risks inherent in the process

– Cash disbursement transactions improperly reported

– Purchase was not properly approved

– Goods received do not match invoice but paid anyway

– I.T. systems

– Accounting software

(7)

AP Top Practices

(Cont)

Document your current AP procedures

(Cont)

Areas to identify:

– Work flow (example)

– Goods are received and counted

– Goods are checked against packing slip

– Information is transmitted to AP Department

– AP clerk checks invoice against P.O.

– AP Clerk checks for mathematical accuracy

(8)

AP Top Practices

(Cont)

Document your current AP procedures

(Cont)

Areas to identify:

– AP controls

– Review and update signature authorizations periodically

– Goods are received and checked against packing slip

– Department supervisor approves payment of invoice prior to submitting invoice for payment

– AP Clerk checks invoice for mathematical accuracy

(9)

AP Top Practices

(Cont)

Document your current AP procedures

(Cont)

Areas to identify:

– Security

– Secure check stock in a restricted area

– Restrict access to appropriate staff

– Lock up stock and provide key or combination to as few people as possible

(10)

AP Top Practices

(Cont)

Establish segregation of duties

Never have one person handling everything

Decreases fraud risk

(11)

AP Top Practices

(Cont)

Establish segregation of duties

(Cont)

Best practice is to have different people:

– Approve purchases

– Receive ordered materials

– Approve invoices for payment

– Review and reconcile financial records

Potential consequences if duties are not separated:

– Erroneous or fraudulent invoices approved for payment

(12)

AP Top Practices

(Cont)

Review and reconcile

Best practices:

– Review vendor invoices for accuracy by comparing to purchase orders

– Verify goods and services purchased have been received

– Perform monthly reconciliations of operating ledgers to assure accuracy of expenditures

Potential consequences:

– Improper charges made to department

– Improper budget restrictions to department

(13)

AP Top Practices

(Cont)

Train and cross-train AP staff

Relying on one person increases fraud and operational risk

Increases office functionality

Increases employee morale and productivity

Must have clear goal and plan

(14)

AP Top Practices

(Cont)

Maintain the Master Vendor File

Prevents fraud

Reduces duplicate payments

Reduces missed payments

Establishes separation of duties

(15)

AP Top Practices

(Cont)

Get a W-9 from every vendor

Documents vendor’s information

Creates a paper trail

Research the vendor

(16)

AP Top Practices

(Cont)

Pay invoices as they are billed

Don’t operate under a “clean desk rule”

Prioritize invoices in order of due dates (unless vendor

offers a discount)

(17)

AP Top Practices

(Cont)

Check for gaps and duplicate payments

Run gap detection reports on check registers

Keep inventory and log of check stock

(18)

AP Top Practices

(Cont)

Monitor the AP process

Monitoring helps identify ongoing effectiveness of AP

controls

– Monitor departmental budget to actual expenditures

– Monitor open purchase orders

(19)

Accounts Payable Best Practices

Purchasing Cards and Travel

Reimbursement

(20)

Accounts Payable Best Practices

Purchasing Cards

Used as a tool to enhance the delivery of services and

goods to the entity

Limits are usually set by the procurement department

Department heads should be responsible for oversight in

their respective departments

(21)

Accounts Payable Best Practices

(Cont)

Purchasing Cards

(Cont)

Monitor purchasing cards on a periodic basis

– Completeness of transactions is easy to achieve

– Take a different approach to sampling

– Review department head transactions

– Check for authorization

– Check for sales tax paid

(22)

Accounts Payable Best Practices

(Cont)

Purchasing Cards – How bad it can get?

The Department of Defense uncovered its own purchasing

card scandal

Over an 18-month period, Air Force and Navy personnel

used government-funded credit cards for the following

charges:

– $102,400 for admission to entertainment events

– $48,250 for gambling

– $69,300 for cruises

– $73,950 for exotic dance clubs

(23)

Accounts Payable Best Practices

(Cont)

Travel Reimbursement

Rates and guidelines are set by Florida Statutes

Local governments may differ if approved by the governing

body

Authorization forms are very important

– Provides attestation language that travel was for the benefit of the entity

(24)

Accounts Payable Best Practices

(Cont)

Travel Reimbursement

(Cont)

Common errors

– No receipt for transaction

– Sales tax paid during trip

– Mileage allowance not calculated correctly

(25)

Accounts Payable Best Practices

(26)

Accounts Payable Best Practices

Report to the Nations on Occupational Fraud and

Abuse

Report conducted every other year by the Association of

Certified Fraud Examiners

51% of all fraud cases involved

– Billing schemes (such as shell companies and personal purchases)

– Expense reimbursement fraud

– Check tampering

(27)

Accounts Payable Best Practices

(Cont)

Schemes, Risks and Perpetration

Shell company

– Employee creates a fake vendor and bills the entity

– May include inflated, above-market prices on goods and services

Personal purchases

– Employee orders personal items and submits invoice to employer for payment

(28)

Accounts Payable Best Practices

(Cont)

Schemes, Risks and Perpetration

(Cont)

Fraudulent expense reimbursement

– Employee files a false, inflated or fictitious expense report claim

– May also involve submissions of duplicate or inflated expenses

Check tampering

– Employee steals blank checks from the entity, uses them for personal use

– Employee can also counterfeit bank account and routing numbers from entity

(29)

Accounts Payable Best Practices

(Cont)

Symptoms, Red Flags, and Detection

Be on the lookout for:

– Causes behind increased costs, coupled with lower-quality goods or services

– Incomplete vendor information

– Address

– Tax identification number

(30)

Accounts Payable Best Practices

(Cont)

Symptoms, Red Flags, and Detection

(Cont)

Be on the lookout for:

– Missing or altered copies of supporting documentation

– P.O.’s – Invoices – Receiving documents – Changes in lifestyle – Lavish trips – Jewelry – Personal assets

(31)

Accounts Payable Best Practices

(Cont)

Symptoms, Red Flags, and Detection

(Cont)

Be on the lookout for:

– Increase in purchases from favored vendors or unusually close relationships with suppliers

– Goods received but not ordered, or goods ordered but not received

– Links between employee information and vendor master file

(32)

Accounts Payable Best Practices

(Cont)

Controls, Countermeasures, and Prevention

Stay ahead of the curve by:

– Separating the vendor setup and approval process from the payment process

– Rigorously vet all new vendors when they are set up

– Frequently review the vendor master file

– Payment volume activity

– Reasonableness and consistency with known operational trends and budgets

(33)

Accounts Payable Best Practices

(Cont)

Controls, Countermeasures, and Prevention

(Cont)

Stay ahead of the curve by:

– Maintaining and reviewing a log of sequentially numbered checks and payables processing batches

– Setting up automated fraud detection tolls

– Positive Pay

(34)

Accounts Payable Best Practices

(Cont)

Accounts Payable Case Studies

Case Study 1:

– A purchasing agent had a very good relationship with some of the company’s suppliers. On a surprise check on bids for a new project, it was discovered that the supplier chosen was charging a per unit price higher than other submitted bids. It turned out that this supplier was giving the purchasing agent a “commission” for each winning bid. Further investigation

revealed that this supplier was chosen frequently in the past, despite bidding higher than other vendors.

(35)

Accounts Payable Best Practices

(Cont)

Accounts Payable Case Studies

(Cont)

Case Study 2:

– The bookkeeper typed out the checks to the suppliers, which were then signed by the company owner. The bookkeeper used an erasing typewriter to remove the payee designation and amount from the check and replace them with her name and a significantly greater amount. These amounts were

entered in the disbursements journal as payments for

aggregate inventory to the company’s largest supplier, who received several large checks each month. More than

(36)

Accounts Payable Best Practices

(Cont)

Accounts Payable Case Studies

(Cont)

Case Study 3:

– A department head set up a dummy corporation and used his home address as the mailing address. Over a two-year

period, the department head submitted false invoices for more than $250,000. This scheme was eventually detected when a new employee noticed that the vendor’s address matched her boss’s address. If a P.O. box had been used, this scheme

(37)

Accounts Payable Best Practices

(Cont)

Accounts Payable Case Studies

(Cont)

Case Study in Depth - ING:

– A corporate mistake opened the door for Nathan J. Mueller’s fraud. Two years after the error was made, he discovered he was authorized to request and approve checks of up to

$250,000. A co-worker also was accidentally granted the same privileges, while a subordinate was authorized to request checks.

– Mueller, his subordinate, and the co-worker often logged on as one another to get work done. This allowed Mueller to

(38)

Accounts Payable Best Practices

(Cont)

Accounts Payable Case Studies

(Cont)

Case Study in Depth - ING:

– Mueller and his subordinate were allowed to physically pick up checks. This allowed Mueller to take physical checks to the bank to be deposited into the account of a fake vendor he set up.

– Mueller hid his debits in ledger accounts that he controlled. Better separation of duties could have helped to prevent the scheme.

(39)

Accounts Payable Best Practices

(Cont)

Accounts Payable Case Studies

(Cont)

Case Study in Depth - ING:

– The fraud netted nearly $8.5 million in four years. The money was used to buy expensive cars, watches, and nighttime

entertainment, as well as to pay for numerous trips from Minnesota to Las Vegas.

– Mueller told his wife his extra money was from gambling

winnings. After a while, she began to doubt that explanation, and they divorced.

(40)

Accounts Payable Best Practices

(Cont)

Accounts Payable Case Studies

(Cont)

Case Study in Depth - ING:

– The fraud was uncovered when Mueller’s ex-wife expressed her doubts about his income to his co-worker. The co-worker spotted questionable transactions in the company records and brought them to management’s attention. The scheme

unraveled quickly after that.

– Mueller was sentenced to 97 months in federal prison after pleading guilty to fraud. He is due to be released in

(41)

References

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