COSO Fraud Management Guide

By: David L Cotton, CPA, CFE, CGFMChairman, Cotton & Company LLP; Sandra Johnigan, CPA/CFF, CFEOwner, Johnigan, P.C.; Leslye Givarz, CPATechnical Editor, Public Company Accounting Oversight Board (Retired)

The Committee of Sponsoring Organizations of the Treadway Commission (COSO), an organization cosponsored by IMA, released the Fraud Management Guide, a report that offers a detailed blueprint for helping organizations establish an overall fraud risk management program. The new guide is intended to support and complement previously released COSO publications including the 1992 Internal Control – Integrated Framework and its 2013 revision which introduced 17 principles associated with internal controls.

The Fraud Management Guide provides information on key items including:

• Establishing fraud risk governance policies
• Performing a fraud risk assessment
• Designing and deploying fraud preventive and detective control activities
• Conducting investigations, and
• Monitoring and evaluating the total fraud risk management program

The guide also addresses fraud risk management roles and responsibilities, utilizing data analytics in risk management, and fraud risk management in government. Additionally, the guide provides references for users to tailor and develop a comprehensive fraud risk management program regardless of status as public, private, academic institution, not-for-profit, government; or its size, location, or industry.