On February 14, 2013, former city comptroller and treasurer of Dixon, IL, Rita Crundwell was sentenced to 19½ years in prison for diverting $53 million from city funds for her own benefit. It appears that the fraud began in 1990 at a relatively small amount, but the level of her embezzlements increased significantly in the last years of the embezzlement (e.g., in 2008 she embezzled $5.8 million). Crundwell used the proceeds to finance her horse breeding business and her lavish lifestyle. She purchased 400 horses, farms, trucks, a $2 million RV, and jewelry. Her position as city treasurer paid about $80,000 a year at the time of her arrest.
Rita Crundwell was one of the most trusted people in Dixon, IL's city government. She started working for the finance department for the city while still in high school in 1970. In 1983, she was appointed as the comptroller/treasurer. As comptroller, Crundwell handled all of the finances for the city of Dixon. Crundwell participated in budget meetings for the city with other city council members and voiced a need for Dixon to make spending cuts due to a lack of sufficient funds. Many of the city officials who held elected position were not full-time employees of the city.
The process by which Crundwell was able to obtain the funds was not extremely complicated. According to the indictment, Crundwell opened a bank account at Fifth Third Bank in 1990 in the name of the city of Dixon and RSCDA (Reserve Sewer Development Account). That account appeared to be for the benefit of the city of Dixon, but Crundwell was the only signatory and the only person who wrote checks from that account. Crundwell was able to deposit city funds from other sources into the Capital Development Fund account. After she created false invoices, Crundwell would write checks from that fund payable to "Treasurer." She then deposited those checks directly into the RSCDA account. The Fifth Third Bank assumed the money in the RSCDA account was for the city. Crundwell repeatedly transferred city funds into the RSCDA account and used the money to pay for her own personal and private business expenses.
In October 2011, when Crundwell was away from work, another individual employed by the city of Dixon, requested Fifth Third Bank to forward all of the city's bank statements. This employee realized that the account appeared to be inappropriate and informed Mayor James Burke of the account. Burke determined that the account did not relate to any legitimate business of the city. Burke then notified the Federal Bureau of Investigation.
In September 2013, the city announced it settled its lawsuit against the auditors and bank for $40 million. During the time of the fraud, Dixon's financial statements were audited by CliftonLarsonAllen (formerly Clifton Gunderson LLP). The firm agreed to pay $35.15 million and Fifth Third Bank agreed to pay $3.85 million. CliftonLarsonAllen conceded it shared in the "responsibility for the fact that the fraud was not detected." The attorney for the city stated Mayor Bruce also faulted Fifth Third Bank for violating banking standards by allowing Crundwell to open a city account in 1990 without proper documentation, even if employees knew she worked for the city.
Required:
a. Identify the internal control deficiencies that allowed the fraud to occur and to continue for such a long period of time.
b. Speculate on why the auditors did not detect the fraud.