Chiang Kai Shek College

Department of Accountancy

A case study on

Bangko Sentral ng Pilipinas Employee Theft

Submitted by:

Ng Cheong, Jasmine Marie M.

Submitted to:

Prof. Cristy Allauigan, CPA, MBA

Case

Two Bank of the Philippine Islands employees have been separately sued by their
employers for theft in the Manila Regional Trial Court. On June 3, six counts of qualified theft
were filed against Jay San Rafael, a former BPI relationship manager and Diane Barit, a BPI
teller.

Jay San Rafael worked in the BPI Morayta Branch for 15 years. He was said to have
broken the bank’s trust by setting up an automated teller machine (ATM) account for a customer
without him knowing it. From that customer’s account, he diverted almost P3M which he
withdrew in varying amounts from January to August 2011. When he was confronted, he denied
the accusation and said that it was all just a mistake. However, the city prosecutor approved the
filing of charges against him and recommended no bail for the case.

On the other hand, Diane Barit, a BPI Remedios branch teller, allegedly forged the
signature of a client to illegally withdraw $250 from the client’s account. Assistant City
Prosecutor Rommelia Quiming-Baguio set her bail at P30,000.

Company Background

In 1939, the the Philippine legislature passed a law establishing a central bank. Because it
was a monetary law, it required the approval of the United States president. However, President
Franklin D. Roosevelt disapproved it due to strong opposition from vested interests. A second
law was passed in 1944 during the Japanese occupation, but the arrival of the American
liberalization forces halted its implementation.

Not long after President Manuel Roxas assumed office in 1946, he instructed Finance
Secretary Miguel Cuaderno, Sr. to draw up a charter for a central bank. As a result of the
findings of the Joint Philippine-American Finance Commission chaired by Mr. Cuaderno, the
establishment of a monetary authority became imperative a year later. The Commission, which
studied Philippine financial, monetary and fiscal problems in 1947, suggested a shift from the
dollar exchange standard to a managed currency system. A central bank was needed to
implement the proposed reformation of the currency system.

The Central Bank Council, created by President Manuel Roxas to prepare the charter of a
proposed monetary authority, immediately produced a draft, which was submitted to the
Congress in February 1948. In June 1948, the bill was signed into a law as Republic Act 265 by
President Elpidio Quirino. On November 29 1972, the Presidential Decree No. 72 adopted the
recommendations of the Joint IMF-CB Banking Survey Commission which made a study of the
Philippine banking system. The Commission proposed a program designed to ensure the
system’s soundness and healthy growth.

In the 1973 Constitution, the National Assembly was commissioned to establish an

independent central monetary authority. Years later, PD 1801 designated the Central Bank of the
Philippines as the central monetary authority (CMA). Years later, the 1987 Constitution adopted
the provisions on the CMA from the 1973 Constitution that were aimed essentially at
establishing an independent monetary authority through increased capitalization and greater
private sector representation in the Monetary Board.

On June 14 1993, President Fidel V. Ramos signed into law Republic Act No. 7653, the
New Central Bank Act, in accordance with a provision in the 1987 Constitution. The law
provides for the establishment of an independent monetary authority to be known as the Bangko
Sentral ng Pilipinas, with the maintenance of price stability explicitly stated as its primary
objective. This objective was only implied in the old Central Bank charter. The law also gives
the Bangko Sentral fiscal and administrative autonomy which the old Central Bank did not have.
On 3 July 1993, the New Central Bank Act took effect (BSP, n.d.).
Review of Related Literature

Fraud

Fraud is “a false representation of a material fact made by one party to another party with
the intent to deceive and induce the other party to justifiably rely on the fact to his or her
detriment.” (Hall, 2008).

For an act to be considered fraudulent, four elements must be present:

1. A false representation which is material in nature (either a false statement or an omission

of a material fact).
2. The knowledge that one’s statement is false and the reckless ignorance to truth must be
present.
3. The person receiving the false representation has justifiably and reasonably relied on it.
4. The false representation has caused injury or loss to the receiving party (Gangolly, n.d.).

Financial losses from fraud are difficult to measure due to a number of reasons:

1. Not all fraud is detected.

2. Not all detected fraud is reported.
3. In many fraud cases, the information gathered is incomplete.
4. There is no proper distribution of information to management or law enforcement
authorities.
5. Most of the time, companies do not take proper civil or criminal action against fraudsters
(Hall, 2008).
 Fraud is very costly as it causes substantial damages and losses to businesses and
individuals (Funk, 2015). It causes legal and financial losses to businesses and physical, mental
and economic damages to victims. Here are some of the consequences of fraud:

 Lost confidence in capital markets

 Lawsuits
 Damaged reputation
 Large bankruptcies
 Longer and more costly audits
 Fines and investigations
 Damages and losses to injured employees
 Lost employee retirement and pension funds (Amani & Davani, n.d.)

Strategies to Reduce the Risk of Fraud

In considering how to manage fraud risk, prevention is always better than cure. The
design, implementation and maintenance of internal controls that can prevent, detect and correct
fraud is required to reduce fraud risk. The support and compliance of company owners and
managers with all company policies and procedures enforced to manage fraud risk is required to
minimize this risk. In order for internal controls to be effective and successful, they must be
visible and integrated into the daily operations of the business and there must be proper
disciplinary action taken for fraudulent acts of employees (CPA Australia Ltd, 2011).

1. Lead by example

All members in the company, regardless of position or superiority, must comply with all
company policies and procedures and be held responsible for their actions (CPA Australia Ltd,
2011).

2. Create a positive working environment

 A positive working place motivates employees to comply with company policies and
procedures and to work for the goals and objectives of the company. Having a clear
organizational structure, clear job responsibilities, just and equitable employee practices, open
and effective line of communication between management and employees, and positive
employee recognition minimizes the probability of employee fraud occurrence (CPA Australia
Ltd, 2011).

3. Have a policy manual

Policies and procedures must be documented, they must be accessible to employees and
employees must be trained to adhere to them. Reports on the execution of the policies and
procedures must be made to senior management regularly. There should be no condonance to
violations and adherence to company policies and procedures must be included in the conditions
to be hired as an employee (CPA Australia Ltd, 2011).

4. Establish a code of conduct

It must be clearly stated in the company’s code of conduct that no fraudulent activities
will be tolerated on any business level and that any fraudulent act or behavior will be reported to
the police. It must also be clearly stated in the company’s code of conduct what constitutes
employee fraud because this is usually a gray area for employees (CPA Australia Ltd, 2011).

5. Segregation of duties

The responsibility for a complete transaction from beginning to end should not be given
to one employee only. For small companies, where there is impractical, employees who take
charge of company funds must be subject to close and strict supervision (CPA Australia Ltd,
2011).
 6. Authorization controls

Policies that clearly state person or persons who are authorized to enter into transactions
on behalf of the company and who are accountable for each step that a transaction goes through
(including who are authorized to permit payments over certain amounts and conducting
transactions) (CPA Australia Ltd, 2011).

7. Implement a whistleblowing policy

A company must have a whistleblowing policy that outlines that steps to be taken by an
employee if he suspects misconduct or fraud. In addition to the whistleblowing policy, a process
or procedure that permits employees to anonymously report concerns about potential fraud is
recommended. It is important that employees are knowledgeable about the negative or adverse
consequences of whistleblowing. Management must also show that the follow up on all issues
raised by employees through the whistleblowing mechanism (CPA Australia Ltd, 2011).

8. Create an organizational chart

The roles and responsibilities of all employees must be clearly defined. This could
include: job descriptions, separation of duties, compulsory job rotations, authorization policy and
leave (CPA Australia Ltd, 2011).

9. Implement a comprehensive hiring policy

Ensure that your hiring policy includes:

 Verification of previous employment and seeking of explanations for any employment
gaps
 Police checks
 Checking of qualifications
 Employment reference checks
 Employment credit checks
  Use of technology to look for potential employees (CPA Australia Ltd, 2011).

10. Monitor employee behavior

There are a number of employee behavior that may indicate that an increased probability
that an employee is carrying out fraud:
 The employee frequently works outside of business hours and seldom takes leave. Even
though he may look like industrious in doing his job, they may have ulterior motives for
being in the workplace unmonitored.
 The employee seems to be spending or living too far his means.
 Reports and reconciliations are not done.
 Tax returns and other compliance forms are not filed on time (CPA Australia Ltd, 2011).

11. Implement supervisory processes

Close and strong supervision is very important, especially in small companies that may
have a hard time in separating duties. This can include approval, review, authorizations and
infrequent spot checks which may include redoing work (CPA Australia Ltd, 2011).

12. Perform regular accounting reconciliations

If there are regular accounting reconciliations, such as bank reconciliations, payroll

reconciliations, analysis between budgeted and actual figures, concealing fraud will usually be
difficult to do. The person assigned to do the bank reconciliation should not be the same person
assigned to do the banking (CPA Australia Ltd, 2011).

13. Implement physical access controls

Physical access to sites or properties, cash registers, computer systems, safes and other
secure systems must be controlled. For example:
 Ensure that doors, desks and filing cabinets are locked and secured
  Implement systems that report on employee activity, such as the viewing and alteration of
data in the database
 Consider installing electronic surveillance systems (CPA Australia Ltd, 2011).

14. Investigate every incident

Gather all the facts necessary to make informed decisions through an in-depth and
prompt investigation of breaches of policies and procedures, allegations of fraud, and red flags of
fraud (CPA Australia Ltd, 2011).

15. Others

 Frequently review financial statements

 Deposit cash and checks every day and ensure that the person assigned to do the banking
is not the same person assigned to collect the money
 Secure blank checks, signature stamps and access to electronic funds (EFT) payments
 never sign or authorize payments that are not fully completed
 occasionally check suppliers’ details, including bank account details, with the actual
supplier
 Make payments on original invoices only
 Review complaints of billing errors from clients
 Hire an external auditor to audit their books
 Make sure that employees take annual leave during the year
 Conduct a cross training program to ensure that employees are flexible to perform
another job function
 Occasionally compare payroll payees with employee records
 In situations where they use a personnel agency, check their contract with the agency to
ensure that the personnel hired have undergone a police check
 Question suspicious accounting methods or unnecessary complexities in an accounting
transaction or extremely long charts of accounts
  Hire a contract accountant to substitute the accountant on leave (CPA Australia Ltd,
2011).

Reasons Why Employees Commit Fraud

1. Pressure Factors

Pressure is a financial or emotional force that leads someone to commit fraud. Most
people need some form of pressure to commit fraud. It does not matter whether the pressure
makes sense to others or not. (Brumell Group, 2015). Pressure factors can include:

 Greediness
 Aspiration to live a good life
 Mounting personal liabilities
 Mounting medical bills
 Unforeseen monetary needs (O¨zkul & Pamukc¸u, 2012)

2. Opportunity Factors

Opportunity is the ability to commit fraud without getting caught (Brumell Group, 2015).
To commit fraud, fraud perpetrators first find an opportunity and exploit that opportunity to carry
out the fraudulent act. The opportunity to commit fraud can arise if the company members have
access to assets and information that opens up a way for them to both commit and cover up
fraud. When a company has poor or defective internal controls, weak processes and procedures,
unauthorized or unchecked access to its assets and information, and ineffective management
oversight, fraud is likely to occur (Glasbeek, n.d.). Opportunity factors can include:

 Unhealthy internal control environment

 Improper accounting system
 Ineffective control procedures
  Weak moral policies
 Nondisclosure of contracts made with third parties and partners
 Incapability of evaluating the quality of the performance of employees
 Absence of proper disciplinary action to fraudsters
 Weakness of the flow of information among employees
 Ignorance, indifference, and inabilities of top management
 Lack of healthy audit works (O¨zkul & Pamukc¸u, 2012)

3. Rationalization

Rationalization is the justification of fraudulent actions (Brumell Group, n.d.). Employees

may justify their fraudulent acts by believing that they have good, honest and sincere reasons in
committing fraud (Glasbeek, n.d.). Here are some of the justifications that fraudsters make to
excuse themselves:

 I borrowed the money, I would pay it back later

 I deserve this in return for my efforts and contributions in the company
 Nobody suffered as a result of this
 I took the money for a good purpose
 I was not knowledgeable that this was a crime
 The company deserves this
 Since the company committed tax evasion, I just took something which already belonged
to me (O¨zkul & Pamukc¸u, 2012)

Misappropriation of Assets

Misappropriation of assets happens when people who are assigned to take charge of the
assets of a company steal from it (Asset misappropriation fraud, n.d.). It happens when a
fraudster employs deception to steal or misuse a company’s resources (Albrecht, Kranacher &
Albrecht, n.d.). It is also known as insider fraud. It involves third parties or employees in a
company take advantage of their position to steal assets from the company through fraudulent
activities (Asset misappropriation fraud, n.d.).

Misappropriation of assets can be done by company directors, employees or anyone else

assigned to hold and take charge of the assets and interests of a company. Usually, the assets
stolen are cash or cash equivalents, but it can extend to include company data or intellectual
property (Asset misappropriation fraud, n.d.).

Misappropriation of assets can be mainly divided into two categories:

1. Misappropriation of cash
2. Theft of non-cash assets (Albrecht, Kranacher & Albrecht, n.d.)

Misappropriation of assets can occur under different circumstances:

1. Prior to their recording in the books and records of a company

2. While they are currently held or owned by the company
3. During the process of buying goods or services (Albrecht, Kranacher & Albrecht, n.d.)

Misappropriation of assets may take place when the perpetrator

1. Is experiencing pressures to commit it

2. Finds opportunities to commit it
3. Finds a way to justify his or her actions (Albrecht, Kranacher & Albrecht, n.d.)

Misappropriation of Assets Schemes

1. Skimming
 Skimming involves acts by which funds are taken before they have been entered into the
company’s accounting records. This may be done at the point of sale, from receivables and from
refunds (Albrecht, Kranacher & Albrecht, n.d.). This is an off-book type of fraud because the
company never receives a report on the receipt of cash (Association of Certified Fraud
Examiners, n.d.). The most common schemes of skimming are:
 Unrecorded sales
 Understated sales
 Stealing of incoming checks
 Swapping of checks for cash (Association of Certified Fraud Examiners, n.d.).

Skimming Red Flags:

 Missing transaction records
 Inventory shortage
 Cash receipts or deposit totals differ from expected patterns
 Unusual journal entries or unusual items on the bank reconciliation
 Unusual behaviour of suspects
 Inadequate segregation of duties
 Different dates between deposits and entries to accounting books Differences between
deposits slip names and amounts of credits to accounts
 Unauthorized write-offs of pledges or promises to give (Ernst & Young, LLP)

Detection of skimming:
 Detection at the receipt or sales level
o Physical inventory count
 Review of journal entries
o False credits to inventory to cover up unrecorded or unstated sales
o Lost, stolen or obsolete inventory write-offs
o Accounts receivable write-offs
o Irregular entries to cash
 Detection of lapping
 o Comparison of dates when the customers paid and dates when the payments were
posted (Association of Certified Fraud Examiners, 2016).

Prevention of skimming:
 Installation of visible video cameras in all locations where employees take charge of cash
 Reconciliation of physical inventory count with perpetual inventory records to uncover
shrinkage

2. Cash larceny

Cash larceny includes acts by which funds are stolen after they have been recorded.
Usually, the funds stolen come from the cash on hand, such as from the cash register or the petty
cash fund, or from deposits (Albrecht, Kranacher & Albrecht, n.d.). This is an on-books type of
fraud because it is the theft of cash that has already been recorded in the company’s accounting
records (Dervaes, 2005).

Detection of cash larceny:

 Controls
o Reconciliation of cash register log totals with the amount of cash in the drawer
o The person assigned to do bank deposit should be not the same person assigned as
the cashier or the accounts receivable clerk
o A person who does not do cash receipts and accounts receivable functions should
compare journal entries to the cash receipts journal with authenticated bank
deposit slips and deposit per bank statements
o All employees should have different access codes to the cash registers
(Association of Certified Fraud Examiners, 2016)

Prevention of skimming:
 Segregation of duties
o Cash receipts
o Cash disbursements
 o Bank deposits

 Rotation of assignment and compulsory vacations

 Conduction of surprise cash counts (Association of Certified Fraud Examiners, 2016)

3. Fraudulent disbursements

Fraudulent disbursements occur when an employee takes advantage of his position to

cause a payment for a dishonest purpose. This is an on-book type of fraud because cash or
checks leave the entity, with it being recorded, thus creating an audit trail (Association of
Certified Fraud Examiners, n.d.).

These are the types of fraudulent disbursement schemes:

 Billing schemes - using false invoices to cause payments for personal purchases
Billing scheme categories
 Shell company schemes - fake entities established for the sole purpose of
committing fraud (Short, 2009)
 Pay-and-return schemes - an employee intentionally causes a vendor to
overpay and when the vendor reimburses the overpayment to the
company, he subsequently pockets it (Association of Certified Fraud
Examiners, n.d.)
 Personal purchase schemes - an employee submits an invoice for personal
purchases to the company for payment or an employee uses company
credit card for personal purchases (Association of Certified Fraud
Examiners, n.d.)

 Check tampering - altering or forging a company’s check for own benefit

Check tampering schemes
 Forged maker schemes - forging an authorized signature on a company
check (Association of Certified Fraud Examiners, n.d.)
  Forged endorsement schemes - intercepting a company check intended for
a third party and converting the check by forging the signature
endorsement of the third party (Check Tampering Fraud Schemes, 2012)
 Altered payee schemes - intercepting a company check intended for a third
party and converting the check by changing the name of the payee (Check
Tampering Fraud Schemes, 2012)
 Authorizes maker schemes - an employee with signature authority writes
fraudulent checks for his own personal use (Association of Certified Fraud
Examiners, n.d.)

 Expense reimbursements - making claims for reimbursements of fictitious business

expenses
Expense reimbursement schemes:
 Mischaracterized expenses - an employee asks for reimbursement for an
expense that is not related to the business (Association of Certified Fraud
Examiners, n.d.)
 Overstated expenses - an employee inflates the cost of actual expenses and
requests reimbursement for it (Association of Certified Fraud Examiners,
n.d.)
 Fictitious expenses - an employee claims reimbursement of fictitious
expenses (Expense reimbursement schemes, 2014)
 Multiple reimbursements - an employee submits a reimbursement for the
same expense several times (Association of Certified Fraud Examiners,
n.d.)
 Payroll schemes - submission of false documents or manipulation of payroll system to
generate unauthorized paychecks by an employee (Top Misappropriation Schemes, 2013)
Payroll scheme forms:
 Ghost employee schemes - a perpetrator alters personnel records to
generate payroll disbursements to a ghost employee (Association of
Certified Fraud Examiners, n.d.)
  Falsified hours and salary schemes - overpayment of salaries through
overstatement of number of hours worked or pay rate (Association of
Certified Fraud Examiners, n.d.)
 Commission schemes - fraudulently overstating the amount of sales or the
rate of commission (Association of Certified Fraud Examiners, n.d.)

Prevention of Asset Misappropriation

Through fraud prevention, companies can save themselves from losses due to asset
misappropriation fraud. Most companies have established preventive controls but even the best
controls cannot prevent all fraud from happening, because any person with a perceived pressure,
opportunity and an ability to justify their fraudulent actions can carry out fraud. Even if
companies believe that their employees are honest, they should still take a proactive approach to
fraud prevention (Albrecht, Kranacher & Albrecht, n.d.).

The major elements of fraud prevention are:

1. Creating a culture of honesty, openness, and assistance for all employees
2. Eliminating opportunities for fraud occurrence (Albrecht, Kranacher & Albrecht, n.d.)

Creating a culture of honesty, openness, and assistance for all employees include:
1. Recruiting honest people and providing fraud awareness training programs
2. Creating a positive workplace
3. Implementing effective employee assistance programs (Albrecht, Kranacher & Albrecht,
n.d.)

Eliminating fraud opportunities generally include:

1. Maintaining a good system of internal controls
2. Implementing ways to discourage conspiracy between employees and others
3. Notifying vendors, customers and contractors about company purchasing and sales
policies
 4. Monitoring employees and establishing an effective whistleblowing system
5. Creating an expectation of enforcement within the company
6. Conducting fraud auditing proactively (Albrecht, Kranacher & Albrecht, n.d.)

Detection of Asset Misappropriation

Fraud detection involves identifying and and looking up into warning signals of fraud.
The warning signals of asset misappropriation are broken down into six categories:
1. Accounting irregularities, such as faulty journal entries, inaccurate ledgers, or fake
documents
2. Overriding and breaking down of internal controls
3. Analytical fraud symptoms, which include procedures or relationships that don’t make
sense or that appear to be unreasonable
4. Lifestyle symptoms (people who commit fraud gradually start to live beyond their means)
5. Behavioral symptoms (people who are engaged in fraud exhibit certain behavioral traits
or characteristics, such as stress)
6. Tips and complaints about suspicions of fraud (Albrecht, Kranacher & Albrecht, n.d.)

Prevention of Fraud through Effective Internal Control

According to the 2014 Report to the Nations published by the Association of Certified
Fraud Examiners (“ACFE”) , a typical organization approximately loses 5 percent of its revenue
to fraud every year. Because fraud involves schemes of concealing it, many cases of it will never
be detected. Although asset misappropriation produces the lowest average losses, it still accounts
for the vast majority of fraud activity. According to ACFE’s study, companies that had
implemented these anti-fraud controls experienced lower losses than companies that had not
implemented them:

1. Implementation of a fraud hotline or web-based portal

 Internal and external sources may unidentifiedly and confidentially report fraudulent or
suspicious behavior. In order to promote and encourage the use of the hotline, management
should publicize its policies and procedures. In implementing a fraud hotline, associated
especially with an anti-retaliation policy and/or whistleblower reward program, the company’s
control environment will improve through increasing fraud awareness (Prevention of fraud
through effective internal controls, n.d.).

2. Segregation of duties involving custody of assets, authorization of transactions, and

recording of transactions
An employee should not be in a position where he can both commit and conceal fraud.
The Institute of Internal Auditors suggests that there should be an adequate segregation of
responsibilities among those who have the custody of assets, those who authorize transactions,
and those who report transactions. The flow of internal processes should be structured in such a
way that one person’s work serves as check and balance of another person’s work. A system
designed this way will reduce the risk of errors not being detected and limit opportunities to
commit misappropriation of assets or concealment of intentional misstatements in the financial
statements (Prevention of fraud through effective internal controls, n.d.).

3. Reconciliation of bank accounts and management review of periodic account

reconciliations and bank statements

Bank reconciliations provide insight into the differences between a company’s

company’s cash balance per ledger and per bank statement and prove the completeness and
accuracy of the data recorded in the company’s cash ledger. Bank reconciliations may be done
from a daily to monthly basis depending on the size of the company and the volume of cash
transactions. There should be adequate segregation of duties in the bank reconciliation process.
Cash bookkeeping, bank reconciliation, and check signer functions should be separated
(Prevention of fraud through effective internal controls, n.d.).

4. Review and authorization of expense reimbursements by supervisors and management on

a timely basis
 A vast majority of asset misappropriation schemes involve situations in which an
employee commits expense reimbursement fraud. Management should first ensure that all
policies and procedures, including those related to expense and travel reimbursements, are
communicated to employee and notify them for relevant updates. Expense reports submitted by
employees, including underlying support, such as credit card bills, receipts, telephone bills, etc.,
should be reviewed by the employee’s immediate supervisor and the company’s payroll
department. Expense reports submitted by members of management should be reviewed by other
members of management (Prevention of fraud through effective internal controls, n.d.).

5. Safeguarding and reconciliation of petty cash funds on a periodic basis by authorized

employees

Although petty cash funds represent an immaterial amount of cash held by a company,
generally used for small daily expenses, petty cash irregularities may be red flag of broader
issues regarding management’s approach to the company’s internal controls and control
environment. Sequentially numbered vouchers should be kept as well as disbursement receipts
with the disbursement date, amount, purpose, and employee name to strengthen the processes
surrounding the petty cash fund. Also, the custodian of petty cash should maintain a
reconciliation of the petty cash fund, reconciling total cash on hand plus outstanding receipts to
the total petty cash maximum. There should also be limited access to the petty cash fund, with
the funds kept in a locked box. Management may ask for a periodic independent audit of petty
cash fund to test compliance with company policies and procedures (Prevention of fraud through
effective internal controls, n.d.).

Reaction

When I read this news, I’m not really that surprised that the two employees committed
fraud. Because they have access to the bank’s cash and the clients’ accounts, they have great
opportunities and are more prone to commit fraud.
 Banks are susceptible to fraud because these are where large volumes of money are kept.
Fraudsters are now craftier in designing their methods or procedures to circumvent the controls.
The main incentive of fraudsters is the monetary gain they can obtain.

I learned that monitoring transactions is very important in banks. Banks should design
processes that trigger an alert in the case of unusual transactions in order to improve their ability
to prevent and detect fraud.

I also learned that reconciling bank accounts and transactions on a timely basis is very
important in banks. This will help the bank detect transactions that are suspicious and that didn’t
really occur.

I also learned that monitoring employees is very important in banks. Monitoring

employees and taking corrective actions on a timely basis will help track employee performance
and activity and reduce the risk of not being able to prevent or detect and correct fraud.
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