ACCA Applied Skills · Audit and Assurance
Fraud, laws and regulations: formula sheet
Key formulas
- Fraud versus error
- Fraud = intentional misstatement; Error = unintentional misstatement
- Intent is the only difference. Both can be material.
- Fraud triangle
- Incentive/pressure + Opportunity + Rationalisation
- All three are normally present. Use it to classify fraud risk factors in a scenario.
- Two types of fraud
- Fraudulent financial reporting; Misappropriation of assets
- Name the type, then link it to the scenario facts.
- Responsibility split
- Management and TCWG: prevent and detect. Auditor: reasonable assurance on material misstatement.
- The auditor does not prevent fraud and does not give a guarantee.
- Presumed fraud risk in revenue and override
- Revenue recognition and management override of controls are treated as fraud risks
- ISA 240 requires the auditor to presume a fraud risk in revenue recognition and to always address management override.
- Fraud triangle
- Fraud = Incentive or pressure + Opportunity + Attitude or rationalisation
- Use it to organise fraud risk factors in a scenario. Name which side each factor falls under.
- Two types of fraud (ISA 240)
- Fraudulent financial reporting (misstating the financial statements) | Misappropriation of assets (theft)
- Say which type applies and who is likely to be responsible: usually management for the first, usually employees for the second.
- Mandatory responses to management override
- Test journals | Review accounting estimates for bias | Evaluate the business rationale of significant unusual transactions
- These are required on every audit regardless of the assessed risks.
- Revenue presumption
- Presumed fraud risk in revenue recognition, unless rebutted
- Treat revenue as a significant risk. The presumption can be rebutted only with a reason documented by the auditor.
- Responsibility
- Prevention and detection = management and those charged with governance | Reasonable assurance of no material misstatement = auditor
- The auditor is not responsible for preventing fraud. Material fraud can still go undetected.
- Fraud triangle
- Fraud risk = Incentive or pressure + Opportunity + Rationalisation
- Use it to explain why a fraud risk factor exists. Name all three parts.
- Presumed fraud risks
- Revenue recognition (presumed, rebuttable) + Management override of controls (always a significant risk)
- Management override cannot be rebutted. The revenue presumption can be rebutted only with a reason.
- Mandatory override procedures
- Test journals and adjustments + Review estimates for bias + Evaluate rationale for significant unusual transactions
- Required whatever the auditor's assessment of fraud risk.
- Overall responses
- Senior staff + Supervision + Unpredictability + Review of accounting policies
- Use these when the risk affects the financial statements as a whole.
- Who to tell first
- Fraud suspected → appropriate level of management (above those involved) → TCWG if management involved or integrity in doubt
- If management may be involved, go directly to TCWG. Do not tell the suspect.
- Matters to communicate to TCWG (ISA 240)
- Fraud by management, by employees with significant control roles, or any fraud causing material misstatement; plus concerns about management's fraud risk assessment and controls
- Communicate on a timely basis. Matters may be oral or written depending on significance.
- Confidentiality override
- Disclose externally only if: required by law, or permitted by law and in the public interest (or otherwise legally protected)
- Take legal advice. Disclose only to the proper authority and only what is relevant.
- Fraud written representations
- Management acknowledges responsibility for fraud prevention and detection; has disclosed fraud risk assessment results; has disclosed known or suspected fraud and allegations
- Obtain these in the representation letter dated at or near the audit report date.
- Effect on audit report
- Material misstatement uncorrected → qualified or adverse; unable to obtain evidence → qualified or disclaimer
- Choose between qualified and adverse/disclaimer by pervasiveness.
- Responsibility split
- Management and TCWG = ensure compliance; Auditor = reasonable assurance of no material misstatement from non-compliance
- The auditor does not prevent or detect all non-compliance.
- Direct laws
- Direct effect on material amounts or disclosures → obtain sufficient appropriate audit evidence about compliance
- Examples: tax, pensions, company law disclosures.
- Indirect (other) laws
- No direct effect → at least enquire of management and TCWG + inspect correspondence with regulators
- Examples: health and safety, environmental and licensing laws. These are the minimum procedures. The auditor must respond further if non-compliance is identified or suspected.
- Response to suspected non-compliance
- Understand → discuss with management/TCWG → evaluate effect → communicate → consider reporting and opinion
- Legal advice may be needed if management cannot give enough information.
- Written representations
- Obtain written representation that management has disclosed all known or suspected non-compliance
- This supports the audit work but is not a substitute for it.
- Three stages of laundering
- Placement → Layering → Integration
- Placement puts the money into the system, layering hides its trail, integration brings it back as clean.
- Reporting route
- Suspicion → report to firm's MLRO → MLRO decides → report to the appropriate authority
- The staff member's duty is normally met by reporting to the MLRO.
- Tipping off
- Tipping off = disclosing a report or investigation in a way that may prejudice it
- It is an offence. The auditor must not alert the client.
- Confidentiality override
- Legal duty to report > duty of confidentiality
- A report made in good faith in line with the law does not breach confidentiality.
- Main offences
- Laundering + Failure to report + Tipping off
- Check your jurisdiction's wording, but exam answers use these three.
Quick revision
- Fraud is intentional; error is unintentional.
- Management and those charged with governance are responsible for preventing and detecting fraud.
- The auditor obtains reasonable assurance, not absolute assurance, that the financial statements are free from material misstatement.
- Fraud risk factors fall under incentive or pressure, opportunity and rationalisation.
- Fraudulent financial reporting means misstating the accounts; misappropriation means stealing assets.
- Under ISA 240, management override of controls is always treated as a risk, so journal entries and estimates are tested.
- Revenue recognition is presumed to be a fraud risk unless the auditor concludes otherwise and documents why.
- Maintain professional scepticism and hold a team discussion about where fraud could occur.
- Written representations support other evidence but cannot replace it.
- Under ISA 250, the auditor is not responsible for preventing non-compliance and cannot be expected to detect all of it.
- Money laundering reporting is a legal duty, and tipping off the suspect is an offence in many jurisdictions.
- If fraud is suspected, the auditor communicates with the right level of management or those charged with governance, depending on who may be involved.
Common mistakes
- Saying the auditor is responsible for preventing and detecting fraud. Fix: Write that management and those charged with governance prevent and detect fraud. The auditor obtains reasonable assurance on material misstatement.
- Defining fraud by its size or by whether money was lost. Fix: Use intent as the test. A large honest mistake is still error, and a small deliberate misstatement is still fraud.
- Saying the auditor is responsible for preventing and detecting fraud. Fix: State that management and those charged with governance are responsible. The auditor obtains reasonable assurance that the financial statements are free from material misstatement, whether from fraud or error.
- Confusing fraud with error. Fix: Intent is the difference. Fraud is intentional. Error is unintentional. Use the word 'intentional' in definitions.
- Saying the auditor is responsible for preventing and detecting fraud. Fix: Say management and those charged with governance are responsible for prevention and detection. The auditor gets reasonable assurance on material misstatement.
- Giving generic procedures such as 'check invoices' for a fraud risk. Fix: Name the risk and the assertion. Then say what you test, such as cut-off on year-end sales or journals posted near year end.
- Saying the auditor must always report fraud to the police or regulator. Fix: Say external reporting depends on law or public interest. Confidentiality applies otherwise, and legal advice is sensible.
- Telling the suspected manager first. Fix: If management is implicated, go directly to TCWG, such as the audit committee.
- Saying the auditor is responsible for ensuring the client complies with laws. Fix: Write that management and TCWG are responsible. The auditor only obtains reasonable assurance about material misstatement.
- Treating all laws the same and listing full substantive testing for every law. Fix: Classify first. Direct laws need sufficient appropriate evidence about compliance. Other laws need at least enquiry and inspection of regulator correspondence, and further response if non-compliance is identified or suspected.
Exam tips
- Use the word intent whenever you separate fraud from error. Markers look for it.
- In scenario questions, quote the fact and then label it pressure, opportunity or rationalisation. Do not just list the triangle.
- Always state the responsibility split clearly and add that auditor assurance is reasonable, not absolute.
- For response questions, mention professional scepticism, team discussion, enquiries, journal testing and management override.
- In objective tests, watch for options that say the auditor 'prevents' or 'guarantees'. These are almost always wrong.
- In Section C, write each point as fact, risk factor and response. Examiners reward application to the scenario, not textbook lists.
- In OT questions, decide first whether the scenario points to management (financial reporting fraud) or employees (misappropriation). This usually removes two options.
- Always mention the three required management override procedures if the scenario shows management pressure or control dominance.