ISA (UK) 240: The auditor's responsibilities relating to fraud in an audit of financial statements

 Financial statement misstatements can result from either fraud or human error. The difference between fraud and error is whether the underlying conduct that causes the financial statements to be misstated is deliberate and involves deception or is unintentional. Although fraud is a broad legal notion, the auditor is concerned with fraud or suspected fraud that produces a material misstatement in the financial statements for the purposes of the ISAs (UK). The auditor is concerned with two sorts of intentional misstatements: those resulting from dishonest financial reporting and those originating from asset misappropriation.

Members of the audit committee should take an active part in preventing fraud by challenging management and auditors to verify that enough is being done to prevent and identify fraud throughout the organization. When financial crises make the news, the most pressing question is who bears blame and who could have stopped it. The auditing standard ISA 240 governs the auditor's responsibilities in relation to fraud, and many amendments have taken effect in both the UK and Ireland. In May 2021, the FRC issued a revised ISA (UK) 240 in response to the Brydon Review's recommendations to clarify auditor roles.

For auditors, what has changed?

-       Professional skepticism is getting more attention.

-       The significance of keeping vigilant and investigating further if conditions indicate that material submitted to auditors may not be real or has been tampered with is emphasized.

-       The auditor must evaluate both qualitative and quantitative elements of the fraud when determining whether it is material.

-       To undertake a risk assessment, audit methods, or evaluate evidence obtained, the audit team must examine whether specialist skills are required.

-       The audit team is likely to have more discussions, including exchanging ideas about how management or others within the entity could commit or hide fraud.

The ISA 240 modification was made in response to recent complaints that auditors aren't doing enough to uncover substantial fraud. It aims to clarify auditor responsibilities and place a greater emphasis on the auditor's role to look for suspected fraud. The auditor's job is to design and conduct an audit so that he or she may have reasonable assurance that the financial statements are free of serious misstatement due to fraud. This is a welcome clarification that will help auditors identify and analyze the risk of a significant misstatement as a result of fraud, as well as design processes to manage those risks.

 

Practice:

Both those charged with governance and management bear major responsibilities for fraud prevention and detection. It is critical that management, under the supervision of those charged with governance, place a high emphasis on fraud prevention, which may minimize possibilities for fraud, and fraud deterrence, which may encourage individuals not to commit fraud due to the risk of detection and punishment. This necessitates a commitment to cultivating a culture of honesty and ethical behavior, which can be maintained through active governance supervision.

Reference:     

https://bit.ly/3JQ9h86

https://bit.ly/3JTIyaO

Audit Method: Fraud

Accounting fraud has long been the buzzword in the industry due to its wider and deeper implications on the company, industry and the economy at large. Window dressing is a term used in accounting for presenting financial statements in such a manner that disguise the actual financial transactions and present them in a more favorable way. According to PWC Economic crime survey the five most commonly reported types of economic crimes are asset misappropriation, procurement fraud, bribery and corruption, cybercrime and accounting fraud.

Auditors are required to keep themselves up to date about all these fraudulent practices and should apply professional skepticism while conducting the audit of financial statements.

ISA 240, The Auditor’s Responsibilities Relating to Fraud in an Audit of Financial Statements addresses all the issues which an auditor has to deal with while conducting the audit. Under ISA-240, auditors are now required to evaluate the effectiveness of an entity’s risk management framework (internal control) in preventing misstatements whether through fraud or otherwise, in all audits. Furthermore, auditors are now required to be more proactive in their search for fraud. The auditor is responsible for maintaining an attitude of professional skepticism throughout the audit, recognizing the possibility that a material misstatement due to fraud could exist, notwithstanding the auditor’s past experience of the honesty and integrity of the entity’s management and those charged with the governance. An overriding requirement of ISA 240 is that auditors are aware of the possibility of there being misstatements due to fraud.

The objectives of the auditor are:

a) To identify and assess the risks of material misstatement of the financial statements due to fraud;

b) To obtain sufficient appropriate audit evidence regarding the assessed risks of material misstatement due to fraud, through designing and implementing appropriate responses; and

c) To respond appropriately to fraud or suspected fraud identified during the audit.

The ISA, however, recognize the fact that owing to inherent limitation of an audit, there is an unavoidable risk that some material misstatements of the financial statements may not be detected, even though the audit is properly planned and performed in accordance with the ISAs.

Practice

 Misstatements in the financial statements can arise from either fraud or error. The distinguishing factor between fraud and error is whether the action that results in the misstatement of the financial statements is intentional or unintentional. In planning the audit, auditors must be alert to the possibility of fraud and assess the risk that fraud might occur. The auditor shall treat those assessed risks of material misstatement due to fraud as significant risks and accordingly, the auditor shall obtain an understanding of the entity’s related controls, including control activities, relevant to such risks.

Some Colour to Fraud Investigation

Lisa Weaver, the examiner of P7, wrote the article about forensic auditing in Student Accountant in 2008. I can not say it is the most jolly reading in the world, but I still  recommend it to all accountancy students for effective preparation to exam or job interview in forensic department.

In fact the fraud is highly tested area in all accountancy certification exams, in  ACCA (F8, P1,P7) and US CPA. I would like to add some “colour” to the considerations about fraud investigation engagements.

Types of Fraud

Ms Weaver kindly mentioned for us that there are three types of fraud:

·        corruption,

·        asset misappropriation,

·        financial statements fraud.

According to PwC’s report “Global Economic Crime Survey” her statement is very close to reality. I highly recommend to read that report, because it is quite interesting and practical product. PwC gives a table of the most popular economic crimes, which is in line with Weaver’s article:

Lets dive in financial statement fraud.

Financial Statement Fraud

Elliot and Elliot in their book state that inventory valuation gives lots of opportunities for creative accounting. Inferring from Treadway Comission Report they consider that ‘fraud often involved overstatement of revenues and assets with inventory fraud’ featuring understating bad debt allowances, overstating value of inventory. There are several groups of inventory related fraud: year-end manipulations, purchases not recorded (cut-off issues), fictitious transfers of non-existent inventory, carrying obsolete inventory at a cost, reducing cost of goods sold by adjusting journal entries.

Fraud and Bankruptcies

Gaughan, referring to Dun & Bradstreet research, noted than in 2000s number of bankruptcies related with fraud significantly increased. WorldCom, Enron, Adelfia, Refco, Parmalat were ‘brought down by management fraud’. He also mentioned BancruptcyData.com table of the largest bankruptcies. I have found it’s updated version since he has written his book, here it is:

As we already know accounting fraud (so called, ‘Repo 105’) was also involved in Lehman’s case. Though it was not the primary reason for their collapse, but still conceal of fraud contributed to the overall situation. This is how Sikka describes this case in his article:

‘Lehman’s own accounting personnel described Repo 105 transactions as an “accounting gimmick” and a “lazy way of managing the balance sheet as opposed to legitimately meeting balance sheet targets at quarter end”, but the bank received a clean bill of health from auditors Ernst & Young. The insolvency examiner was critical of auditors and protracted litigation will follow.’

By The Way

There is a special certification of specialists in fraud investigations which is carried out by Association of Certified Fraud Examiners. CFEs are the guys, just like us, accountants J However, additionally to common accountancy subjects they study things as criminology and have special training to present evidence in court.

By the way, have you ever been involved in fraud investigations or may be you performed fraud investigation procedures within audit engagements? Please share information. 

References

Elliot, B. and Elliot, J. (2007). Financial Accounting and Reporting. 11^th Edition. Pearson Education Ltd.

BankruptcyData.com (2010). Site Link:

 http://www.bankruptcydata.com/Research/Largest_Overall_All-Time.pdf

Gaughan, P.A. (2007). Mergers, Acquisitions and Corporate Restructurings. Forth Edition. John Wiley and Sons Inc.

PwC. (2009) Global Economic Crime Survey: Economic Crime in a Downturn. November 2009, PwC

Sikka, P. (2011).The EU man cometh. PQ Magazine. No. 1, p. 27.

Weaver, L. (2008). Forensic Auditing. Student Accountant. September 2008, p. 58-60.