Who owns transaction and controls monitoring?

Who monitors and oversees high-risk transactions in your organization? If it isn’t you — an anti-fraud professional — you should heavily ponder this question. In this article, I explore who owns transaction and controls monitoring for vendors, customers and employees. The variety of answers may surprise you.

A common challenge in midsize and large organizations is the false sense of security in thinking that “someone else” or “some other department” owns a particular fraud risk control and has it covered. In reality, the fraud risk perspective of Certified Fraud Examiners (CFEs) is often missing but desperately needed. Let’s use finance and accounts payable departments as examples. Who administers and monitors payments to the organization’s third parties? As the first line, those in accounts payable often base their risk concerns and perspectives on key internal controls and the presence of approvals, documentation and vendor qualifications required for invoice payment. Are they thinking about anti-corruption risks or fake vendor schemes, conflicts of interest or sanctions compliance? Some of them are, but most of the time accounting staff don’t have the bandwidth or background to spot trends, sensitive keywords or patterns indicative of a potentially improper payment or vendor. Oversight is frequently missing from employee travel and entertainment expenses administration. Controls can fall through the cracks in accounts receivable, as well, an area in which commissions, bonuses or discounts are prone to abuse. Are you confident that your organization’s financial processes for handling vendors, customers or employees could stop an improper payment or transaction? Let’s take a closer look at who owns transactions and controls monitoring in these high-risk areas of an organization.