Management overrides of internal controls can make your company more vulnerable to fraud. This is true even when managers have innocent intentions — for example, they do not feel they have time to follow proper accounts payable procedures because a vendor is requesting immediate payment. Your company is at even higher risk of fraud losses if a senior manager intentionally ignores the rules to manipulate financial statements.
Management overrides of financial controls can be difficult to detect. However, there are several warning signs that a manager is not fully adhering to the policies and procedures your organization has adopted. For instance, a manager may fail to call attention to business risks or dispute an auditor’s findings regarding his or her department. A senior manager may be unwilling to discuss issues that could require financial adjustments or insist on releasing overly optimistic reports on current or future performance.
Such behavior does not prove that fraud is occurring. However, it suggests that you need to improve or open new paths of communication and consider retraining managers on the importance of internal controls. If you do suspect fraud, you must be willing to investigate — regardless of whom it might implicate.
To prevent management overrides, build a culture that encourages honesty and supports employees who speak up when they suspect something’s wrong. Think about whether your managers experience pressure that unwittingly encourages fraud. For example, if your industry has seen increased business failures, some employees may think they need to keep profits at specified levels. They also might feel stressed if their compensation depends on achieving stretch goals for cash flow or operating results.
Employees a level or two below senior managers are most likely to observe management overrides. Give them access to a confidential hotline, and they are more likely to report fraud before it seriously harms your business. In addition, if you extend your hotline to vendors and customers, you will increase your chances for learning of improprieties early.
A Difficult Year
This year has been challenging for businesses of every size and in every sector. With many employees working from home and some companies downsizing, managers may be tempted to take short cuts they would not under ordinary circumstances. Or worse, managers with access to financial statements may feel pressure to fudge numbers to improve your company’s public profile or boost their own compensation. We can help identify flaws in your fraud-prevention program and design policies that even those willing to fraud will have trouble overriding.