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March 2019 » The Risks of Fraud Collusion
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Yigal Rechtman, CPA, CFE, CITP, CISM
The Association of Certified Fraud Examiners (ACFE), in reporting on collusion in its 2018 Report to the Nations (http://bit.ly/2BIITfH), indicates that there is a direct correlation between collusion and the cost of a fraud incident, rising from an average of $74,000 for one perpetrator to $339,000 for three or more perpetrators. While this trend is alarming, there is a paucity of research on the causes and mitigation of fraud perpetrated by collusion. Beyond this observation, however, the ACFE does not correlate collusion to lax internal controls. Moreover, collusion can easily override the basic tenets of segregation of duties, which is the foundation of good internal controls.
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