Fraud Risk Management Guide Updated for Modern Threats
COSO and the Association of Certified Fraud Examiners (ACFE) are updating their Fraud Risk Management Guide. The revision will address the growing complexity of fraud, including interconnected risks related to suppliers, cybersecurity, and ESG (environmental, social, and governance) exposures.
- The second edition, released May 2, 2023, broadens the traditional "Fraud Triangle" (pressure, opportunity, rationalization) into a "Fraud Pentagon" by adding "competence" and "arrogance" as attributes of potential perpetrators. It also significantly expands guidance on using data analytics for fraud detection and prevention, adding a data analytics "Point of Focus" to each of its five core principles. - For the manufacturing sector specifically, the top three occupational fraud schemes are corruption (occurring in 55% of cases), non-cash asset misappropriation like inventory theft (29%), and billing schemes (27%). The median loss for manufacturers in these cases is $177,000, significantly higher than the overall median loss of $117,000 across all industries. - Supply chain threats, a key focus of the updated guide, are escalating, with total U.S. cargo theft events increasing by 59% in 2023. Fictitious pickups, where criminals use stolen motor carrier identities to steal loads, saw a 1,375% year-over-year increase in the first quarter of 2023 alone, highlighting a critical vulnerability for manufacturers. - The guide's new emphasis on ESG fraud aligns with emerging regulatory pressures, such as the SEC's climate disclosure rules adopted on March 6, 2024. These rules mandate that public manufacturers begin disclosing material climate-related risks, greenhouse gas emissions, and related financial impacts, with initial reporting for large filers starting in 2026 for the 2025 fiscal year. - Geopolitical risks in sourcing critical materials, a key concern for manufacturers, are intensifying due to ongoing trade policies and global competition. The U.S. remains heavily dependent on imports for minerals like cobalt, lithium, and rare earths, with China dominating the refining capacity for most. - Ongoing US-China trade tensions continue to directly impact manufacturers through Section 232 tariffs on steel (25%) and aluminum (10%), which affect the cost of raw materials. These tariffs target intermediate inputs and capital equipment used by U.S.-based companies, complicating supply chain cost management. - The guide's expanded focus on internal controls is critical as over half of all frauds in the manufacturing sector stem from either a lack of internal controls or a management override of existing ones. Common schemes exploit these weaknesses, including the creation of fake vendors, submission of inflated invoices, and theft of raw materials masked by fraudulent orders.