Internal Control/Anti-Fraud Program Design for the Small Business: A Guide for Companies NOT Subject to the Sarbanes-Oxley Act

PART ONE The Anti-Fraud Environment: The Blueprints, the Foundation, the Ground Floor

I REMEMBER VIVIDLY THE EXPERIENCE OF BUILDING my own home. I still remember the dinner with my wife where we crouched over napkins, illustrating each detail of our dreams. As we left the restaurant, we blissfully knew that this was a great idea. Little did we know that our dream home construction would turn into the single most frustrating process of our lives.

Early in the process, after having looked through what seemed like hundreds of magazines and catalogues, we selected what we wanted for items such as faucets, cabinet hardware, and lighting fixtures. Yes, we had finished out our new home. Then it dawned on us that we had not even started the process of finding the architect or a home building contractor. Stepping back for a moment, we realized that some things have to come first, mainly all of the foundational work.

Similar to building a home, the construction of an effective anti-fraud program includes certain issues that must be addressed in the proper order.

First, there must be a plan; a framework must be designed, similar to an architect's blueprint for building a home.

Second, the foundation must be put in place on which to build the structure. Accordingly, certain foundational policies must exist to support the structure of an anti-fraud program.

Once the plan is in place and the foundation is down, the ground floor is ready to be installed. The ground floor, the fraud risk assessment ...