A billing scheme is a fraud aimed at the
payments system of a business. Its main purpose is to manipulate
that system and cause the business to make a fraudulent payment to
the employee. Though it is a payment to an employee, the business
still records it as a legitimate business expense in its records.
The employee will normally have some sort of influence on a false
bill being approved for payment. Since the payment is recorded as a
legitimate business expense, it is effectively hidden in the
business’s records.
Types of
Billing Schemes
Shell company schemes – a fake entity is
established by a dishonest employee to bill a company for goods or
services it does not receive. The employee converts the payment to
his or her own benefit.
Pass-through schemes – a shell company is
established by an employee to purchase goods or services for the
employer. The goods or services purchased by the employee’s shell
company are then marked up and sold to the employer and the
employee converts the mark-up to his or her own benefit.
Pay-and-return schemes – an employee
purposely causes an overpayment to a vendor to occur, and when the
vendor returns the overpayment to the company, the employee
embezzles the refund.
Personal-purchase schemes – an employee
orders personal merchandise and charges it to the company. The
employee will then either keep the merchandise, or return it for a
cash refund.
These types of billing schemes could be detected with
some of the following techniques:
- Analyze disbursements, looking for many large round amounts, or
amounts falling just below a threshold that requires additional
approval for payment.
- Look for unusually large expenses, unexplained variances in
expenses between years, or expenses that exceed budgeted amounts.
Billing schemes may inflate expenses enough to cause one or all of
these comparisons to yield questionable results.
- Examine the financial statements for variances in expenses that
should track predictably with revenue. Cost of goods sold is a
popular account in which to conceal theft via billing schemes
because of the high level of activity in this account. If the
account varies significantly from expected values when compared to
revenue, however, this might indicate a billing scheme.
- Cross-check addresses of employees and vendors, looking for
exact matches or close matches.
- Verify ownership of vendors that are suspected shell companies.
While many fraudsters will use fictitious names to disguise the
ownership of the shell companies, sometimes real names are used and
can offer clues in cases of suspected fraud.
- Collusion between employees will make such schemes much more
difficult to detect. Normal checks and balances that are carried
out by multiple employees may be thwarted if those employees decide
to team up to commit fraud.
- Abnormal levels of purchases from a particular supplier. The
supplier’s name may be being used by the fraudster to submit false
invoices. Checking the details on the invoices may show that some
of the invoices are different from the others or suspicious in some
manner. Verifying invoices with the real supplier will highlight
false invoices.
- Missing documentation. The employee may destroy the
documentation used to generate a payment once the payment has been
made. It may later be assumed that the document has just been lost.
The lack of documents will frustrate investigations into suspicious
payments.
SOME BASIC CONTROLS
- Purchases should be done with pre-numbered purchase orders. All
suppliers should be given authorized orders and invoices should not
be authorized for payment unless they match authorized orders.
- Random checks on invoices may locate fictitious entities being
used for billing schemes.
- The use of electronic payments to pre-approved bank accounts
will stop cheques being diverted to fraudulent entities.
- Audit purchases with pre-approved suppliers to look for
payments to similarly named suppliers. An approved supplier’s name,
or a very similar name, may be used by a fraudster without their
knowledge.
- Randomly check the name and addresses of suppliers,
particularly when the only address on the invoices is a postal
address.