3 Tips to Help Prevent and Detect Fraudulent Travel Expense Activity

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Misty Carter, CFE, CIA, CISA
ACFE Research Specialist

Have you ever wondered, “Are my travel expenses being reviewed?” Fraudsters who have been successful at defrauding companies through the submission of fictitious travel expenses most likely have. If management, though, has never considered this question from the employee’s perspective, they might unknowingly be paying out thousands of dollars to fund a fraudster’s lifestyle — that fraudster being one of their own employees.

Unfortunately, this was the case with New York State Assemblyman William Boyland, Jr. Boyland, indicted on charges of allegedly filing tens of thousands of dollars’ worth of fraudulent travel expenses, claimed he had been traveling on legislative business in Albany, New York, between January 2007 and December 2011 when he allegedly was not (as reported in Metropolis, a Wall Street Journal blog). In fact, in some of the instances where he allegedly claimed he was traveling to Albany, he was in New York City meeting with undercover investigators who were building an unrelated bribery case against him.

While the exact dollar amount falsely claimed by Boyland is still uncertain, an audit found no record of him being in Albany 609 of the 975 days he claimed he had traveled there. Based on these audit findings, Boyland is required to repay the state $67,497 in mileage reimbursement and per-diem payments. In addition to the indictment for submitting fraudulent travel expenses, Boyland has two other pending charges against him related to bribery and mail fraud.

This is just one example of many where employees abuse company or tax-payer dollars through expense reimbursement schemes. According to the 2016 Report to the Nations, expense reimbursement fraud schemes made up 14 percent of the asset misappropriation schemes with an average loss of $40,000. The report also noted that these frauds lasted a median of 24 months before being detected, as was the case with Boyland.

Even though the detection and prevention of fraudulent employee expenses can seem overwhelming, there are controls that management can put in place to mitigate risk in this area. The following tips can aid in the detection, prevention and deterrence of this type of fraud:

• Implement continuous control monitoring software. This software is automated and can review 100 percent of expense data. It can be configured to identify outliers or areas where fraud and noncompliance are most likely to be detected. Data reported from these monitoring solutions can help decrease fraudulent expense activity through trend reviews of anomalies. Employees might also be deterred from attempting a fraud if they know that a tool is in place to review all expenses submitted. 
• Implement a formal travel and entertainment expense policy. It is important for management to develop a clear travel and entertainment expense policy and communicate it to their employees. Management should also ensure employees are aware of their expectations toward policy adherence and establish consequences for failure to comply with policy requirements. 
• Hold management accountable. Management might be lax in its review and approval of employee expenses, but if held accountable for approving fraudulent expenses, they might spend more time reviewing them. Approving managers should also consider occasionally questioning employees about expenses they submitted. This practice can actually have a deterrent effect: if employees know someone is actually reviewing what they submit, they are less likely to submit a fraudulent expense. 

Although expense reimbursement fraud is rampant, it can be minimized if the proper action is taken. Management must be proactive and implement the necessary controls to help deter employees from committing schemes and detect if they do occur. Failing to take action can be detrimental to the company and leave it exposed to this and other types of fraud schemes.

What to Do When the Authorities Just Aren’t Interested

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Mary Breslin, CFE, CIA
President, Empower Audit

Sometimes stopping a fraud and terminating an employee are all you can do. Even though those are two accomplishments in themselves, they can leave you wondering, “What do I do when the authorities are not interested in criminally prosecuting an internal fraud?”

One of the easiest fraud cases I ever worked was also one of the most frustrating. My team and I did solid work and had iron-clad evidence, but we couldn’t convince the local authorities to do anything with the information. Unfortunately, it was one of those scenarios where the executives really wanted to prosecute and make a clear example of the situation.

As the chief audit executive, I reported to the general counsel for my organization. It was a great arrangement in my opinion, and I enjoyed working for him. We were a large international organization with operations in many developing nations. My team was routinely involved in fraud investigations, often on multiple continents simultaneously. But this fraud — this fraud was close to home. Literally in the office next door. The general counsel’s paralegal had been committing expense reimbursement fraud for two years, and the general counsel took it personally. Wouldn’t you?

A perceptive accounts payable clerk noticed some issues with the paralegal’s expenses and informed us of the inconsistencies. After a little research and some data analytics, we quickly found tens of thousands of dollars in purchase card (pcard) and expense reimbursement fraud. She had two major schemes. First, she paid for things with her pcard and then listed the items for cash reimbursement on her personal expenses. She always had a receipt! The opportunity had presented itself to her when she realized the general counsel did not closely review her expenses. Second, she charged a considerable amount of personal items to her company pcard. I won’t get into details, but I do believe she had everything ever made by Victoria's Secret.

Understandably, the general counsel felt a lot of things —anger, frustration, betrayal and a little foolishness for trusting her and not reviewing her expenses in detail. As a result, he wanted her charged criminally. She was not getting special treatment — we wanted to follow our normal process to prosecute for internal fraud. However, while there was approximately $30,000 in fraud, the local authorities were not interested in prosecuting. Why? Like most things in life, it was mostly about timing. At that particular moment in time, the local authorities had bigger cases they were concerned with and did not believe they could spare the resources to deal with our fraudster.

The final outcomes of even successfully executed investigations can be very frustrating and less than satisfactory. So how can this be prevented? It is always a potential problem, but if you do the following you are less likely to run into this issue:

• Make sure your case is ready to hand over to the authorities, including ensuring that you have solid evidence that was properly handled.
• Use experts. Bring in external assistance if you do not have fraud investigation and examination experts in-house.
•  If the authorities feel they are too busy, remember you have time. Understand what the statute of limitations is for the crime. Ask the authorities if it would be acceptable to check in periodically to see if their schedules allow your case to be addressed at a later time.
• You can initiate a civil suit to recover losses.

Remember: Catching the fraudster and ending the fraud is a deterrent to other fraudsters, so do not allow yourself to get too frustrated. Stop fraud and carry on!