The June 2004 issue of Journal of Forensic Accounting includes a Letter From The Publisher entitled "Audit Committees: The Last Best Hope," where an Enterprise Risk Management (ERM) perspective is used to specifically consider Executive Management Fraudulent Financial Reporting (EMFFR) in public companies.
EMFFR is determined to be a catastrophic risk beyond the scope of SOA/COSO internal controls. A simplified EMFFR risk model incorporates the “fraud triangle” into an enterprise perspective and offers an alternative approach to application of risk response interventions. Public company
audit committees are presented as both owning EMFFR risk and as being “the party bestplaced to manage the risk response effectively.”
Current influences on corporate governance within the U.S. are reviewed, management of EMFFR risk is recognized as a non-discretionary, non-delegatable function of the audit committee, and a structure for the audit committee
to effectively manage EMFFR risk is introduced. The EMFFR risk management structure has three components:
1) forensic accountants as professional audit advisors to the audit committee;
2) use, by the audit committee, of the external auditor as a tool to obtain quality financial reporting from management through insistence upon neutral reporting; and,
3) forensic accountants embedded within the integrated internal controls/financial statement audit and focused exclusively upon active detection of EMFFR. A testable heuristic intended to improve the efficiency of peremptory EMFFR detection is offered.
An overview of the Letter is available here.
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