The Examiner – Insights on Fighting Financial Fraud

Collusion - Tip 4 of 5 for Improving SOD

Written by Jeffrey N. Aucoin | May 20, 2015

Friends are special people and good ones are always there when you need them. They provide support and guidance. Friends can also be helpful when you want to pull a prank on someone.

I was lucky enough to have two close friends when I was younger. We were inseparable, and when you consider the pranks we pulled on each other, we were like the three stooges. I was more like Larry while they were Curly and Moe. Two of the threesome were always colluding to pull a prank on the other one. One summer night we were having a sleepover at Curly’s house and I pulled a great prank on Curly because he fell asleep first. The next morning Curly colluded with Moe to pull a prank on me. I don’t remember all the details, but let’s just say that I haven’t forgotten the outcomes.

One of them brought me outside to distract me, making sure I was barefooted by seeing to it that I left my shoes in the house. The other one filled my shoes with shampoo. This trick wouldn’t have worked without their colluding and without my trusting them.

The first outcome was hilarious to my friends. It was time for me to go home. One of my friends, probably Curly, brought my shoes and socks outside. I stuck my sock covered foot in the first shoe and then the second. They laughed as they watched my expression change when I realized something wasn’t right. The liquid soaked through my socks to my skin. I kicked off my shoes and angrily pulled off my socks. I rode my bike home barefooted, the metal pedals scratching the bottoms of my tender feet. I held my shoes and socks in one hand as I steered with the other. I forgave them by the time I got home and threw my shoes and socks into the washing machine.

My next surprise came 15 minutes later, when I went to the laundry room. There were bubbles coming out the top of the machine. They were everywhere. The anger returned. You can only imagine how long it took me to clean up this mess.

Whether you have colluding friends or colluding employees—believe me, bad things are going to happen. Collusion among employees is one of the easiest ways to circumvent segregation of duties (SOD). Below are a few tips to fight collusion within your organization:

  1. Rotate job duties and mandatory vacation policy. This takes a significant amount of planning and effort to implement, but it can be an effective way of shaking things up just enough to mitigate the risk of collusion or catch it if it is occurring.
  2. Develop monitoring controls and reporting. Well-designed reports can help identify unusual patterns. For example, the time between purchase order creation and payment authorization is usually 30 days, but if you notice that payments to a certain vendor average 2 days, you need to investigate.
  3. Proper policies and procedures in place. SOD may not stop every instance of fraud, but certain policies and procedures can create a trail that can be used later as evidence to prove a particular person was involved. This is a simple as a check box that requires the user to enter a response or a signature on a document to confirm they entered, reviewed, or approved the transaction.
  4. Culture with a zero tolerance for fraud. Building the right culture can help mitigate the risk of employees committing fraud. If there are more employees fighting fraud, then there are fewer employees available for collusion.

I miss playing pranks on my friends, and, sometimes, I even miss them playing pranks on me. But don’t let your employees pull a prank on you by stealing your hard earned profits.