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Executive Roadmap to Fraud Prevention and Internal Control: Creating a Culture of Compliance, 2nd Edition


Praise for Executive Roadmap to Fraud Prevention and Internal Control Second Edition

"This book touches all the bases on corporate fraud. The authors—both experienced fraud investigators and federal law enforcement agents—lay out the history and major milestones of corporate fraud, and discuss with precision the key issues facing today's executives and compliance leaders. The book provides a valuable overview for business leaders looking to develop and implement effective compliance programs and instill a culture of integrity in order to help their organizations defeat the challenges posed by today's sophisticated fraudsters."—Jeffrey Eglash, Senior Counsel, Litigation & Legal Policy, GE

"Biegelman and Bartow's book offers expert guidance to anyone tasked with understanding and tackling fraud in the workplace. Their straightforward approach informs the reader and provides a roadmap and guidance for implementation of an effective fraud mechanism within any organization—small or large. I plan to provide a copy of the book to my board of directors and executive members of management."—Lisanne E. S. Cottington, Compliance Officer, Insight Enterprises, Inc.

"Business leaders would be wise to follow the recommendations in this book. Fraud prevention is more than just creating a set of policies. As the subtitle indicates, it is essential to create a culture of compliance. Empty words accomplish nothing. The authors, both experienced fraud examiners, have spent decades investigating fraud, as well as developing strategies to prevent it. This book is an essential tool in creating an anti-fraud environment in any company."—James D. Ratley, CFE, President & CEO, Association of Certified Fraud Examiners

"Biegelman and Bartow's Executive Roadmap to Fraud Prevention and Internal Control is an essential guide for all who have an interest in eradicating corporate or institutional fraud. The new Second Edition is an indispensable addition to the libraries of internal compliance and legal officers and forensic accountants."—Joel M. Cohen, Partner, Gibson, Dunn &Crutcher; former New York federal prosecutor and liaison to the French Ministry of Justice and OECD

"This new edition is extremely timely. These authors have used their extensive corporate and government experience to create a practical and easy-to-understand compliance guide. A superb resource for any executive."—Karen Popp, Partner, Sidley Austin LLP, and former federal prosecutor and Associate Counsel to President Clinton

"Martin Biegelman and Joel Bartow convert their lifelong experiences and unparalleled knowledge into a concise, well-written book. They provide the essential tools to take aspirational goals for fraud prevention and compliance and build them into concrete and effective programs."—From the Foreword by Bradley J. Bondi, Partner, Cadwalader, Wickersham & Taft LLP

"Biegelman and Bartow provide great insight into not just how fraud occurs inside of companies, but why. Preventing fraud requires a solid understanding of both, making this book a must-read for any executive who is serious about creating the compliance mechanisms and the corporate culture needed for effective fraud prevention."—Aaron G. Murphy, Partner, Latham & Watkins LLP

Martin T. Biegelman, CFE, CCEP, has been fighting fraud and corruption for more than thirty-five years in various roles in law enforcement, consulting, and the corporate sector. He is currently a Director in the Global Investigations and Compliance Practice at Navigant Consulting. He previously served as Director of Financial Integrity at Microsoft Corporation.

Joel T. Bartow, CFE, CPP, is Operations Director for IntegriGuard, LLC. Mr. Bartow has over twenty-five years of experience in fraud and security investigations as an FBI Special Agent and in the private sector, where he developed successful fraud prevention programs.

Foreword to the Second Edition xiii

Foreword to the First Edition xvii

Preface xxi

Acknowledgments xxvii

CHAPTER 1 Fraud’s Feeding Frenzy 1

CHAPTER 2 Fraud Theory and Prevention 23

CHAPTER 3 The Path to Greater Corporate Compliance, Accountability, and Ethical Conduct: COSO to Sarbanes-Oxley 47

CHAPTER 4 The Path to Greater Corporate Compliance, Accountability, and Ethical Conduct: SAS 99 to the 2010 Amendments to the Federal Sentencing Guidelines for Organizations 81

CHAPTER 5 Internal Controls and Antifraud Programs 105

CHAPTER 6 Financial Statement Fraud 133

CHAPTER 7 Internal Fraud: Protecting a Company 157

CHAPTER 8 Former Fraudster and New Man 171

CHAPTER 9 External Schemes and Scams: The Rest of the Fraud Story 185

CHAPTER 10 Not Too Big to Fail 205

CHAPTER 11 Designing a Robust Fraud Prevention Program 231

CHAPTER 12 Whistleblowers and Hotlines 255

CHAPTER 13 Time to Do Background Checks 287

CHAPTER 14 Training, Training, and More Training 307

CHAPTER 15 Global Fraud and Corruption Risk 329

CHAPTER 16 The Feds Are Watching: What to Know and Do Now 349

CHAPTER 17 A Fraud Prevention Culture That Works 371

APPENDIX ACFE Fraud Prevention Checklist 391

About the Authors 395

Index 399