Compliance, Control, COSO, DOJ, Enterprise Risk Resili..., Fraud and Forensic Inv..., Internal Audit, Internal Controls, Policies and Procedures, Process Improvement, Regulatory, Risk, Sarbanes-Oxley, SEC Jonathan T. Marks Compliance, Control, COSO, DOJ, Enterprise Risk Resili..., Fraud and Forensic Inv..., Internal Audit, Internal Controls, Policies and Procedures, Process Improvement, Regulatory, Risk, Sarbanes-Oxley, SEC Jonathan T. Marks

Internal Controls - A Process to Help Ensure Internal Controls are Designed Consistently and Appropriately

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ACFE, AICPA, Anti-fraud, Baker Tilly, Bank Secrecy Act, Board of Directors, Books and records, Bribery, Business Intelligence, Compliance, Culture, Disclosure, Dodd-Frank, DOJ, Enforcement, Enterprise Risk Resili..., Ethics, Evidence, False Claims Act, FCPA, Federal Sentencing Gui..., Foreign Corrupt Practi..., Forensic Accounting, Forensically Speaking, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Task Force, General Counsel, Governance, GRC, Hotline, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Jonathan T- Marks, Kickbacks, KYC, Leadership, Legal, Management Override, Money Laundering, Monitoring, NACD, Not for Profit, OFAC, Policies and Procedures, Process Improvement, Qui Tam, RegTech, Regulatory, Remediation, Remote Internal Invest..., Remote Investigations, Risk Assessment, Risk factors, Risk Management, Risk-focused, Root Cause, Sarbanes-Oxley, SEC, Third Party, Thought Leadership, Webinar, Whistleblower, White Collar Crime Jonathan T. Marks ACFE, AICPA, Anti-fraud, Baker Tilly, Bank Secrecy Act, Board of Directors, Books and records, Bribery, Business Intelligence, Compliance, Culture, Disclosure, Dodd-Frank, DOJ, Enforcement, Enterprise Risk Resili..., Ethics, Evidence, False Claims Act, FCPA, Federal Sentencing Gui..., Foreign Corrupt Practi..., Forensic Accounting, Forensically Speaking, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Task Force, General Counsel, Governance, GRC, Hotline, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Jonathan T- Marks, Kickbacks, KYC, Leadership, Legal, Management Override, Money Laundering, Monitoring, NACD, Not for Profit, OFAC, Policies and Procedures, Process Improvement, Qui Tam, RegTech, Regulatory, Remediation, Remote Internal Invest..., Remote Investigations, Risk Assessment, Risk factors, Risk Management, Risk-focused, Root Cause, Sarbanes-Oxley, SEC, Third Party, Thought Leadership, Webinar, Whistleblower, White Collar Crime Jonathan T. Marks

Still time to join us on February 23-25! Baker Tilly’s 1st Annual Virtual Fraud and Compliance Summit

We are introducing our first annual virtual Baker Tilly Fraud and Compliance Summit, hosted by Jonathan T. Marks, who leads Baker Tilly’s Global Forensic, Compliance, and Integrity Services Practice.

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10-80-10, 10-A, 3 Lines, ACFE, AICPA, Analytics, Anti-fraud, Antitrust, Audit, Audit Committee, Automation, Baker Tilly, Blockchain, Board of Directors, Books and records, Bribery, Business Intelligence, Caremark, Cash, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, Colleges and Universities, Collusion, Compliance, Compliance Coordinator, Conflict of Interest, Continuous Auditing, Continuous Monitoring, Control, Control Environment, Coronavirus, Corporate Fraud, Corruption, COSO, Court, COVID -19, Crisis, Crisis Management, Critical Audit Matters, Cross Border Investiga..., Cryptocurrency, Culture, Culture Assessment, Cyber, Damages, Data, Data Analytics, Data Integrity, Directors, Disclosure, Dodd Frank, Dodd-Frank, DOJ, Due Diligence, Dunning Kruger, Enforcement, Enterprise Risk Resili..., Enterprise Risk Resili..., EQS, ERM, Ethics, Evidence, Exit Interview, Fake Invoices, False Claims Act, FCPA, Federal Sentencing Gui..., Financial reporting an..., FinCen, Food Safety, Foreign Corrupt Practi..., Forensic Accounting, Forensically Speaking, Four eyes approval, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Task Force, Fraud Triangle, GAAP, GDPR, General Counsel, Gifts, Global, Governance, GRC, Guidance, Hidden Assets, Hotline, IDORP, IIA, IIA Philadelphia, IIOT, Impairment, Initial Coin Offering, Insider Trading, Internal Audit, Internal Control Defic..., Internal Controls, Interview, Investigations, Jonathan T- Marks, Judgment and Estimates, Keyword, Kickbacks, Leadership, Legal, Lessons Learned, Management Override, Materiality, MD&A, Money Laundering, Monitor, Monitoring, Monitorship, NACD, Nonprofit, Not for Profit, OFAC, Office of Foreign Asse..., Oversight, Phishing, Podcast, Policies and Procedures, Process Improvement, Proxy, Qui Tam, ransom, Ransomeware, Red Flag, RegTech, Regulatory, Related Party, Remediation, Remote Internal Invest..., Remote Investigations, Reputation, Restatement, Risk, Risk Assessment, Risk factors, Risk Management, Robotic, Root Cause, Sampling, Sarbanes-Oxley, Seaboard, SEC, Shell Company, Skepticism, Slush Fund, Supreme Court, Tax, Tax Fraud, Technology, Theft, Third Party, Thought Leadership, Three Lines, Three Lines of Defense, Tips, tone at the top, Tone from the Top, Training, Treasury, Triage, Uncategorized, Values, Webinar, Whistleblower, White Collar Crime, Yellow Flag Jonathan T. Marks 10-80-10, 10-A, 3 Lines, ACFE, AICPA, Analytics, Anti-fraud, Antitrust, Audit, Audit Committee, Automation, Baker Tilly, Blockchain, Board of Directors, Books and records, Bribery, Business Intelligence, Caremark, Cash, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, Colleges and Universities, Collusion, Compliance, Compliance Coordinator, Conflict of Interest, Continuous Auditing, Continuous Monitoring, Control, Control Environment, Coronavirus, Corporate Fraud, Corruption, COSO, Court, COVID -19, Crisis, Crisis Management, Critical Audit Matters, Cross Border Investiga..., Cryptocurrency, Culture, Culture Assessment, Cyber, Damages, Data, Data Analytics, Data Integrity, Directors, Disclosure, Dodd Frank, Dodd-Frank, DOJ, Due Diligence, Dunning Kruger, Enforcement, Enterprise Risk Resili..., Enterprise Risk Resili..., EQS, ERM, Ethics, Evidence, Exit Interview, Fake Invoices, False Claims Act, FCPA, Federal Sentencing Gui..., Financial reporting an..., FinCen, Food Safety, Foreign Corrupt Practi..., Forensic Accounting, Forensically Speaking, Four eyes approval, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, Fraud Pentagon, Fraud Risk Management, Fraud Task Force, Fraud Triangle, GAAP, GDPR, General Counsel, Gifts, Global, Governance, GRC, Guidance, Hidden Assets, Hotline, IDORP, IIA, IIA Philadelphia, IIOT, Impairment, Initial Coin Offering, Insider Trading, Internal Audit, Internal Control Defic..., Internal Controls, Interview, Investigations, Jonathan T- Marks, Judgment and Estimates, Keyword, Kickbacks, Leadership, Legal, Lessons Learned, Management Override, Materiality, MD&A, Money Laundering, Monitor, Monitoring, Monitorship, NACD, Nonprofit, Not for Profit, OFAC, Office of Foreign Asse..., Oversight, Phishing, Podcast, Policies and Procedures, Process Improvement, Proxy, Qui Tam, ransom, Ransomeware, Red Flag, RegTech, Regulatory, Related Party, Remediation, Remote Internal Invest..., Remote Investigations, Reputation, Restatement, Risk, Risk Assessment, Risk factors, Risk Management, Robotic, Root Cause, Sampling, Sarbanes-Oxley, Seaboard, SEC, Shell Company, Skepticism, Slush Fund, Supreme Court, Tax, Tax Fraud, Technology, Theft, Third Party, Thought Leadership, Three Lines, Three Lines of Defense, Tips, tone at the top, Tone from the Top, Training, Treasury, Triage, Uncategorized, Values, Webinar, Whistleblower, White Collar Crime, Yellow Flag Jonathan T. Marks

2020 Top 10 Articles on Fraud, Compliance, and Risk Management

Happy New Year, and thank you to the more than 100,000 people that visited Board and Fraud in 2020!
With everything that happened last year, fraud, compliance, and risk management have arguably become more important than ever.

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Business Intelligence, Compliance, Data Analytics, Enterprise Risk Resili..., Ethics, Fraud, Fraud and Forensic Inv..., Internal Audit, Internal Control Defic..., Internal Controls, Regulatory, Risk, Risk Assessment, Risk Management, White Collar Crime Jonathan T. Marks Business Intelligence, Compliance, Data Analytics, Enterprise Risk Resili..., Ethics, Fraud, Fraud and Forensic Inv..., Internal Audit, Internal Control Defic..., Internal Controls, Regulatory, Risk, Risk Assessment, Risk Management, White Collar Crime Jonathan T. Marks

SEC and its New Silent Whistleblower: Risk Based Data Analytics

The SEC just announced its first actions arising from investigations generated by the Enforcement Division's EPS (Earnings Per Share) Initiative, which utilizes risk-based data analytics to uncover potential accounting and disclosure violations caused by, among other things, earnings management practices.

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Anti-fraud, Audit Committee, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, DOJ, Enterprise Risk Resili..., Fake Invoices, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, General Counsel, Internal Audit, Kickbacks, Money Laundering, Red Flag, Shell Company, White Collar Crime Jonathan T. Marks Anti-fraud, Audit Committee, Board of Directors, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, DOJ, Enterprise Risk Resili..., Fake Invoices, Foreign Corrupt Practi..., Forensic Accounting, Fraud, Fraud and Forensic, Fraud and Forensic Inv..., Fraud Investigations, General Counsel, Internal Audit, Kickbacks, Money Laundering, Red Flag, Shell Company, White Collar Crime Jonathan T. Marks

DOJ Unravels a Decade-Old Scheme that involved Kickbacks, Money Laundering, Sham Shell Companies, and Fake Invoices

According to evidence presented at trial, Aleksandr Pikus, 45, of Brooklyn, New York, and his co-conspirators perpetrated a scheme through a series of medical clinics in Brooklyn and Queens over nearly a decade.   The clinics employed doctors, physical and occupational therapists, and other medical professionals who were enrolled in the Medicare and Medicaid programs.  In return for illegal kickbacks, Pikus referred beneficiaries to these health care providers, who submitted claims to the Medicare and Medicaid programs.Pikus and his co-conspirators then laundered a substantial portion of the proceeds of these claims through companies he controlled, including by cashing checks at several New York City check-cashing businesses.  Pikus then failed to report that cash income to the IRS.  Instead, Pikus used the cash to enrich himself and others and to pay kickbacks to patient recruiters, who, in turn, paid beneficiaries to receive treatment at the medical clinics.  The evidence further established that Pikus and his co-conspirators used sham shell companies and fake invoices to conceal their illegal activities.

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3 Lines, Audit, Audit Committee, Business Intelligence, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, Compliance, Enterprise Risk Resili..., Fraud and Forensic Inv..., General Counsel, Governance, IIA, Internal Audit, Jonathan T- Marks, Risk, Three Lines, Three Lines of Defense Jonathan T. Marks 3 Lines, Audit, Audit Committee, Business Intelligence, Chief Audit Executive, Chief Compliance Officer, Chief Legal Counsel, Compliance, Enterprise Risk Resili..., Fraud and Forensic Inv..., General Counsel, Governance, IIA, Internal Audit, Jonathan T- Marks, Risk, Three Lines, Three Lines of Defense Jonathan T. Marks

Compliance snubbed? Three Lines Model or Enterprise Resiliency Model?

In July 2020, The Institute of Internal Auditors ("IIA") updated its Three Lines of Defense Model ("Model") to emphasize more active forms of risk management and governance that appear to go beyond merely defensive maneuvers made by the internal audit function.  Some believed the old model sent a message that we should fear risk. I never saw it that way. I understood the subliminal message was the model was about achieving objectives, which requires both the creation and the protection of value. The new model does a much better job of confirming that risk management contributes "to achieving objectives and creating value, as well as to matters of "defense" and protecting value."Learn why the Enterprise Risk Resilient Model might be a better choice.

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ACFE, Anti-fraud, Audit, Audit Committee, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Compliance, Control, Corporate Fraud, DOJ, Enterprise Risk Resili..., ERM, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Four eyes approval, Fraud, Fraud Risk Management, General Counsel, Global, Governance, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Process Improvement, Red Flag, Regulatory, Remediation, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Skepticism, Third Party, White Collar Crime Jonathan T. Marks ACFE, Anti-fraud, Audit, Audit Committee, Board of Directors, Books and records, Bribery, Chief Audit Executive, Chief Compliance Officer, Compliance, Control, Corporate Fraud, DOJ, Enterprise Risk Resili..., ERM, Ethics, FCPA, Foreign Corrupt Practi..., Forensic Accounting, Four eyes approval, Fraud, Fraud Risk Management, General Counsel, Global, Governance, IIA, Internal Audit, Internal Control Defic..., Internal Controls, Investigations, Process Improvement, Red Flag, Regulatory, Remediation, Risk, Risk Assessment, Risk Management, Root Cause, Sarbanes-Oxley, SEC, Skepticism, Third Party, White Collar Crime Jonathan T. Marks

Internal Control Defined and Some Guidance

Compliance officers talk about controls constantly. Effective controls are the lifeblood of what makes a compliance program work. Most of us can rattle off examples of controls, or recognize a control when we see one.
So my fellow speaker asked the audience: What is a control?
Nobody dared answer. We all, me included, were suddenly uncertain that we could define a control correctly.
The speaker who posed this question is Jonathan T. Marks, partner at Baker Tilly and a prolific thinker on all things forensics, audit, and internal control. Lately Marks has been asking audit and compliance audiences to define a control — and to his dismay, most people can’t.Read Marks’ definition of internal control.

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