Approval workflows

Use system workflows to make sure all requests, claims or activities are approved only by the appropriate decision maker.

This control targets both internal and external fraud risks. 

Examples

Examples of this control include: 

  • a system automatically assigning requests to the correct decision maker for approval
  • requiring all travel spending to be approved by the appropriate decision maker
  • a system automatically assigning higher-value claims to a specified approver, e.g. a central delegate
  • the finance system automatically assigning purchase orders to the procurement team and spending approvers.

Risks from control gap 

Allowing requests, claims or activities to be approved by someone other than the appropriate decision maker can lead to:

  • employees processing fraudulent requests or claims for themselves or another person
  • employee entitlements, e.g. leave or overtime, being approved without the knowledge or approval of the manager or delegate
  • processes becoming uncertain or not working properly
  • poor management of decision making and risk.

Assessing effectiveness

Methods to evaluate the effectiveness of this control include:

  • confirming the existence of approval workflows within the system
  • consulting employees about approval processes to confirm they have a correct understanding
  • identifying how approval requirements are communicated to employees
  • reviewing procedures or guidance to confirm they clearly specify approval processes
  • reviewing requirements on how approvals are obtained
  • confirming approval processes are consistently applied
  • confirming that someone cannot override or bypass approval processes, even when pressure or coercion is applied
  • reviewing a sample of completed requests or claims to confirm appropriate approval was obtained on all occasions
  • reviewing reports of completed requests, claims or activities to confirm approval is obtained on all occasions
  • undertaking fraud control testing or a process walkthrough to confirm that approval processes are enforced
  • confirming the existence of a review and reconciliation process and reviewing the reports
  • reviewing any past fraud cases to identify how they were allowed to occur. 

Complementary controls

Other capability, prevention, detection and response controls that can enhance this control’s effectiveness:

Related fraudster personas

Types of behaviour this control is designed to mitigate:

The corrupt

The enabler

 The exploiter

 

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