Assume that you have been hired as the Chief Risk Officer of this company to help develop the Fraud Risk Management Plan.

Select a publicly traded company for which an accounting and auditing enforcement action was published on the U.S. Securities and Exchange Commission (SEC) Web site in the past 2 years due to fraudulent financial reporting. After selecting your company and reviewing releases published by the SEC on this company, go to the investor section of the companys corporate Web site to review any additional information on the entity. In your research, examine documents for the following:

• Examples of earnings manipulation that resulted in financial statement fraud
• Specific facts of the case that caused SEC investigation
• Details on how the SEC handled the complaints
• How did the company react to the investigation?
• Were any sanctions imposed?
• What steps, if any, did the company take to rectify the situation?

Assume that you have been hired as the Chief Risk Officer of this company to help develop the Fraud Risk Management Plan.

Fraud Risk Governance Points of Focus and Our Organization's Response
Points of Focus	Our Organization's Response, Including Cross-References to Other Material and Documentation
Makes an Organizational Commitment to Fraud Risk Management The board of directors and senior management initiate the fraud risk management process by establishing an organizational commitment to deter, prevent, and detect fraud.
Supports Fraud Risk Governance The board of directors and senior management make an organizational commitment to fraud risk management as a key element of corporate governance.
Establishes a Comprehensive Fraud Risk Management Policy The board of directors and senior management provide a solid foundation of fraud risk management by establishing a comprehensive fraud risk management policy.
Establishes Fraud Risk Governance Roles and Responsibilities Throughout the Organization The board of directors and senior management identify the roles and responsibilities of all personnel as they relate to fraud risk governance.
Documents the Fraud Risk Management Program The board of directors and senior management ensure that the fraud risk management program is thoroughly documented and updated on a regular basis.
Communicates Fraud Risk Management at all Organizational Levels The board of directors and senior management support the ongoing effectiveness of the fraud risk management program by maintaining and communicating a continuous focus on fraud deterrence, prevention, and detection throughout the organization.