Methods that Smith and Jones Could Have Used to Steal $34 million in Cash over 12 Years under KOSS's Internal Control System

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1. Describe methods that Smith and Jones could have used to steal $34 million in cash over 12 years under KOSS's existing internal control system. The second bullet from the AAER is significant. It states "While Koss’s internal controls policy required Michael J. Koss to approve invoices of $5,000 or more for payment, its controls did not prevent Sachdeva and Mulvaney from processing large wire transfers and cashier’s checks outside of the accounts payable system to pay for Sachdeva’s personal purchases without seeking or obtaining Michael J. Koss’s approval." There were various methods Smith and Jones could have used to steal the cash with KOSS's existing internal control system. They include: • Skimming. Because the wire transfers and cashier's checks were outside the accounts payable system (book keeping system), this is indicative of skimming. The wire transfers and checks transactions when posted to the bank accounts are historical and should be identified as part of the reconciliation process. The case states, "...many account reconciliations were either not prepared or were not maintained as part of Koss’s accounting records. To the extent that reconciliations were conducted, they were improperly performed by the same persons who initiated or recorded the transactions (i.e. Sachdeva or Mulvaney)" • Not identified, but certainly plausible with the internal control processes described is the "death by a thousand cuts". Sachdeva and Mulvaney were in position to put through small transactions that may not be detected. This is a cash larceny scheme. • Another cash larceny scheme that could have been committed was reversing transactions or revering entries. By stealing funds, Sachdeva and Mulvaney could have gone back into... ... middle of paper ... ...not have occurred (again the out-dated accounting system shortfall). Further, analytical procedures could be used to compare budgets / forecasts to actual results and variations could be investigated (i.e. expenses higher than anticipated or profit less than anticipated). The following is article by Tracy Coenen is more critical of KOSS' management than of the auditor, Grant Thorton. She contends that while auditor should have caught this fraud, management is more to blame because of not addressing internal control issues. http://www.sequenceinc.com/fraudfiles/2010/01/koss-corp-fraud-defending-grant-thornton-no/ Works Cited https://www.sec.gov/about/laws/soa2002.pdf (page 45) http://www.bizjournals.com/milwaukee/news/2013/07/05/koss-gets-85m-in-settlement-with.html http://www.aicpa.org/Research/Standards/AuditAttest/DownloadableDocuments/AU-00329.pdf

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