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Beyond the

Fraud Triangle
Enhancing Deterrence of
By
Ja

Economic Crimes
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he Association of Certified Fraud Examiners (ACFE) 2010 Report to the Nation

T (www.acfe.com/rttn/rttn-2010.pdf) estimates the cost of fraud to be 5% of businesses


annual revenues. Globally, this translates to approximately $2.9 trillion of economic
losses due to fraud. In response, antifraud efforts have attracted the attention of a wide
group of professionals: internal and external auditors, members of boards of directors and
audit committees, management, and regulators.
To understand why people commit fraud, many professionals refer to the fraud triangle, which
was developed in the mid-20th century. The significance of the fraud triangle in understanding moti-
vation and its importance is most evident in Statement on Auditing Standards (SAS) 99, Consideration
of Fraud in a Financial Statement Audit, which makes the concept central. Nevertheless, since the
1950s, professionals and academics have offered important insights that have gone beyond the fraud
triangle. These extensions have enhanced professionals ability to prevent, deter, detect, investigate,
and remediate fraud. Research beyond the fraud trianglesummarized in Exhibit 1can help to
better understand this societal phenomenon.

JULY 2010 / THE CPA JOURNAL 17


Seminal Efforts in Fraud Research whose points represent the causal factors The idea never entered my head.
Much of the current understanding of of perceived pressure (or nonshareable I thought it was dishonest then, but
why perpetrators commit fraud is ground- financial need), perceived opportunity, and this time it did not seem dishonest at first.
ed in the fraud triangle. The concept of a rationalization (Exhibit 2). Furthermore, the fraudster had con-
fraud triangle dates back to the work of cluded that his financial problem could not
Edwin Sutherland, who coined the term Perceived (Nonshareable) Financial be shared with other individuals who might
white-collar crime, and Donald Cressey, Pressures have aided in solving the problem. Some
who wrote Other Peoples Money As documented in Other Peoples nonshareable financial pressures include
(Patterson Smith, 1973). Cressey, a PhD Money, when Cressey asked individuals sudden financial shortfalls,
student of Sutherland in the 1940s, con- who had violated a trust why they had living beyond ones means,
centrated his research on the circumstances not exploited previous fraud opportuni- greed,
that led fraudsters to initially violate ethi- ties, those who responded gave one or poor credit standing and inability to
cal standards and engage in their first fraud- more of the following reasons: obtain credit,
ulent act. Over the years, his research find- There was no need for it like there unexpected significant medical
ings became known as the fraud triangle, was this time. expenditures,

EXHIBIT 1
Summary of Fraud Triangle and Model Extensions

Definition Shortcomings Extension Benefit of Extension


The Fraud Convergence of perceived Fraud triangle is from the fraudsters Fraud Diamond: Add an Capability is generally a
Triangle pressure, perceived perspective, so two attributes assessment of capability more observable
opportunity, and rationali- (pressure and rationalization) are (see the discussion of attribute than pressure
zation to facilitate fraud. generally nonobservable. pressure and rationali- or rationalization.
zation in the text).
Does not adequately explain the Recognize that predators Understanding predators
actions of pathological fraudsters: seek only opportunity better prepares antifraud
predators who are better organized, and enhance a professionals for dealing
have better concealment schemes, commitment to with more deliberate
and are better at interacting with professional skepticism, and nefarious fraudsters.
auditors and antifraud professionals. brainstorming, and
critical thinking.
Attributes
Perceived Nonsharable financial need. Perceived pressure is an Expand the set of MICE provides a broader
Pressure incomplete descriptor of a fraudsters motivations set of fraud motivations
fraudsters motivations. using MICE: money, beyond nonshareable
ideology, coercion and financial need.
ego (entitlement).
Perceived Opportunity to commit and Does not address collusive Focus on an antifraud Understanding collusive
Opportunity conceal the fraud act. behavior or management override. environment, such as behaviors better
culture, tone at the top, prepares antifraud .
and engaged corporate professionals for the
governance, in addition challenges of
to traditional internal management override,
controls. corruption, and abuse.
Rationali- Morally defensible Nonobservable. Fraud Scale: Substituting More visible than
zation justification for actions integrity for rationalization. rationalization by
seemingly out of character observing decisions
for the fraud perpetrator. and decision-making
processes to assess a
persons integrity.

18 JULY 2010 / THE CPA JOURNAL


large education expenditures, A Recipe for Fraud The Other Fraud Triangle
family or peer pressure, A fundamental observation of the Because the original fraud triangle lacks
gambling losses, Cressey study is that it takes the presence objective criteria for identifying pressure
cost and lack of productivity due to of all three elementspressure, opportu- and rationalization, many experts refer to
drugs or alcohol, and nity, and rationalizationfor the violation a second fraud triangle, consisting of the
cost of extramarital affairs. of trust to occur. The fraud triangle high- act, concealment, and conversion. This
From the perspective of a fraud inves- lights what we witness in society: An indi- triangle focuses on proving that the act con-
tigator, however, pressure is generally vidual facing a nonshareable financial chal- stitutes fraud by gathering evidence of the
nonobservable. This is particularly true for lenge with perceived opportunity and a intent to deceive (i.e., concealment) and by
auditors who may not recognize the symp- morally defensible excuse may commit causing the victim economic damages (i.e.,
toms associated with pressure, because they fraud. Cresseys fraud triangle is a strong conversion).
often have limited interactions with explanatory model that identifies the core
potential perpetrators and lack a baseline elements that make a fraudulent act appear The Fraud Scale
from which to evaluate current behavior. benign to the fraudster. The fraud scale was introduced by Steve
In a relatively simple and under- Albrecht, Keith Howe, and Marshall
Perceived Opportunity standable model, Sutherland and Cressey Romney in Deterring Fraud: The Internal
The second required attribute is oppor- were able to help antifraud professionals Auditors Perspective (Institute of Internal
tunity: The employee must perceive a understand the motivations and actions Auditors Research Foundation, 1984).
chance to commit the fraud without being of good people who make bad choices. Albrecht and his colleagues believed that
detected. This opportunity can arise from The fraud triangle has also become an fraud is difficult to predict because a reli-
several sources, including integral part of SAS 99. Nevertheless, able profile of occupational fraud perpe-
poor internal controls; the triangle alone is an inadequate tool trators does not exist. They suggested that
poor training; for deterring, preventing, and detecting the likelihood of a fraudulent act could be
poor supervision; fraud because two of the characteris- assessed by evaluating the relative forces
lack of prosecution of perpetrators; ticspressure and rationalizationcan- of pressure, opportunity, and personal
ineffective antifraud programs, policies, not be observed. As a result, other integrity. Pressure and opportunity are both
and procedures; and fraud models have been developed to components of the fraud triangle, but the
weak ethical culture (e.g., poor tone provide an alternative view of the fraud fraud scale substitutes personal integrity for
at the top). act that may aid in deterrence, preven- rationalization.
Traditionally, opportunity has been tion, and detection where the fraud tri- The fraud scale is particularly applicable
examined solely within the context of poor angle has fallen short. to financial statement fraud, where sources
internal controls, especially with respect to
the segregation of duties, which have gar-
nered close scrutiny in recent years (e.g., EXHIBIT 2
in Sarbanes-Oxley section 404 require- The Fraud Triangle
ments). More recently, the other elements
of opportunity have also attracted attention
from the profession.

Rationalization
Cressey indicated that a morally
acceptable rationalization is necessary Perceived
before the crime takes place. Because a
fraudster does not view himself as a crim-
Opportunity
inal, he must justify his misdeeds to him-
self before he ever commits them. For
example, the perpetrator may rationalize
his actions by thinking, This is just a loan The Fraud
and Ill pay it back after my next pay- Triangle
check. The rationalization allows the
perpetrator to view illegal behavior as
acceptable, thus preserving his self-image
as a trustworthy person. Of course, in fraud, Perceived
the payback of that loan does not Rationalization
occur. Like pressure, rationalization is not Pressure
a readily observable characteristic, because
it is impossible to see what someone may
be thinking.

JULY 2010 / THE CPA JOURNAL 19


of pressure (e.g., analysts forecasts, man- may be able to assess integrity and thus the four observable traits for committing fraud,
agements earnings guidance, a history of relative likelihood of an individual commit- especially when it involves large sums of
sales and earnings growth) are more observ- ting fraud. money or it continues for an extended peri-
able. With that in mind, the fraud scale od of time:
posits that when the three attributes of The Fraud Diamond: Authoritative position or function with-
pressure, opportunity, and integrity are con- Adding the Fraudsters Capabilities in the organization;
sidered at the same time, one can determine In The Fraud Diamond: Considering Capacity to understand and exploit
whether a situation possesses a higher prob- the Four Elements of Fraud, (The CPA accounting systems and internal control
ability of fraud (Exhibit 3). Journal, December 2004), David T. Wolfe weaknesses, possibly leveraging responsi-
The benefit of using personal integrity is and Dana R. Hermanson present a four-sided bility and abusing authority to complete
that it may be a readily observable charac- fraud diamond that extends the fraud trian- and conceal the fraud;
teristic than rationalization. By observing gle to incorporate an individuals capabili- Confidence (ego) that she will not be
both a persons decisions as well as the deci- ty: personal traits and abilities that play a detected, or, if caught, that she will talk
sion-making processes, his commitment to major role in whether fraud will actually herself out of trouble;
ethical decision making can be gauged. As occur given the presence of pressure, oppor- Capability to deal with the stress cre-
noted by Zabihollah Rezaee and Richard tunity, and rationalization. The authors sug- ated within an otherwise good person when
A. Riley, Jr., in Financial Statement Fraud: gest that many frauds, especially some of the she commits bad acts. (See Exhibit 4.)
Prevention and Detection (Wiley, 2010), multibillion-dollar financial statement frauds, Focusing on capability requires organi-
central to the idea of deterrence is the reliance would not have occurred without the right zations and their auditors to observe, assess,
on personal decision making and responsi- person with the right capabilities imple- and document the capabilities of top
bility. Violations of ethics, trust, and respon- menting the details of the fraud. Opportunity executives, key personnel, and employees
sibility are at the heart of fraudulent activi- opens the door, and incentive and rational- who have the capability to perpetrate and
ties. Ethics addresses the rationalization and, ization draw the potential fraudster toward conceal fraud acts.
to a certain extent, the pressure associated the open doorway, but the individual must
with fraud by considering the conditions have the capability to walk through that The MICE Model
under which a potential fraudster might con- opening. Accordingly, the critical question Another challenge for the fraud triangle
sider an action right or wrong. By consid- is: Who could turn an opportunity for fraud is that it does not explain every fraud act.
ering the ethics of a decision, professionals into reality? Wolfe and Hermanson suggest Consider the example of Thomas M.
Coughlin as presented by James Bandler
and Ann Zimmerman in A Wal-Mart
EXHIBIT 3 Legends Trail of Deceit (Wall Street
The Fraud Scale Journal, April 5, 2005). On January 24,
2005, Coughlin, vice chairman of Wal-
Mart, resigned from Wal-Marts board of
Probability of Fraud Higher Lower directors amid allegations of fraud and
Observed Pressure High Low deceit. Documents reviewed by the Wall
Street Journal
Opportunity High Low suggest that Mr. Coughlin periodically had
Integrity Low High subordinates create false invoices to get
Wal-Mart to pay for his personal
expenses. The questionable activity, span-
ning a period of more than five years,
appears to involve dozens of transactions
High Pressure Low Pressure
Fraud including hunting vacations, a $1,359 pair
Scale of alligator boots custom made for
Mr. Coughlin, and a $2,590 dog pen
for Mr. Coughlins Arkansas home.
Greater Opportunity Lesser Opportunity According to the article, Wal-Mart found
questionable transactions totaling between
$100,000 and $500,000 over three to five
years. What is particularly interesting is
Low Personal Integrity High Personal Integrity that in the year immediately prior to his
resignation, Coughlins compensation
totaled more than $6 million. Risking
Conditions Suggesting Conditions Suggesting
$6 million in annual compensation and rep-
Higher Fraud Risk Lower Fraud Risk utation for a $500,000 payoff does not
appear to make sense. Nonetheless, the
risks taken by Coughlin were similar to

20 JULY 2010 / THE CPA JOURNAL


those taken by other millionaire CEOs and The Predator Versus the Accidental sters, or even just as earnings managers,
CFOs who chose to perpetrate financial Fraudster and sooner or later become predators.
statement fraud. The common fraudster is usually depict- Predators focused on criminal activities
With financial reporting fraud, the first leg ed as having the following characteristics: exist, and they can be individuals or orga-
of the fraud triangle has been adjusted from first-time offender; middle-aged; well-edu- nizations. Predators are far more deliber-
pressure to focus on motivators such as mon- cated; trusted employee; in a position of ate than the accidental fraudster; they are
etary incentives, bonuses, or stock options. responsibility; and considered a good citi- better organized, have better concealment
While top executives clearly feel pressure to zen through service works at the office, in schemes, and are better prepared to deal
deliver solid financial results, such pressure the community, or at a charitable organi- with auditors and other oversight mecha-
is not the same as the nonshareable individ- zation. This individual succumbs to pres- nisms. With regard to the fraud triangle,
ual pressure described by Cressey. sure; develops one or more fraud schemes, all the predator seeks is opportunity. The
To address this issuepresented in and commits some fraud act. In Forensic predator requires no pressure and needs no
Forensic Accounting and Fraud Accounting and Fraud Examination, rationalization. The antifraud professional
Examination by Mary-Jo Kranacher, Kranacher, Riley, and Wells characterize can address this concern by recognizing
Richard A. Riley, Jr., and Joseph T. Wells, that predators existprofessional skepti-
(Wiley, 2010)Professor Jason Thomas cism, brainstorming, and critical thinking
suggests that the motivations of fraud per- are essential tools for exposing the preda-
petrators may be more appropriately tory fraudster.
expanded and identified with the acronym
MICE: money, ideology, coercion, and ego Concerns of Collusive Fraud
(entitlement).
Enron, WorldCom, Adelphia, Phar-Mor,
With regard to the fraud triangle, all and Management Override
Because the fraud triangle generally con-
and ZZZZ Best provide good examples siders individuals acting alone, it does not
where the convicted perpetrators appeared
to be motivated by money, ego, and enti-
the predator seeks is opportunity. provide a good basis for assessing the like-
lihood of fraud under conditions of collu-
tlement. Less frequently, individuals may sion. Yet this is one of the central elements
be unwillingly pulled into a fraud scheme
(i.e., coercion). In the Wal-Mart case,
The predator requires no pressure of complex frauds and financial crimes.
Collusion may take place among individ-
Coughlin was sued by Patsy Stephens, who uals within an organization or across orga-
claimed that she was coerced into submit-
ting vouchers and laundering the money
and needs no rationalization. nizations. According to data collected
during the ACFEs recent study, when col-
through her own bank account (Brian lusion is involved, the sizes of fraud loss-
White, Former Wal-Mart Manager Sues es increase dramatically, from $100,000 to
Tom Coughlinfor Her Own Misdeeds, $366,000 per incident. The losses caused
www.bloggingstocks.com, April 1, 2008). by individual predators can be substantial,
Low-level or unwilling individuals can but when those individuals work in con-
become whistleblowers, and they often pro- this type of perpetrator as the accidental cert with others, the damage can be dev-
vide testimony against fraud ringleaders. fraudster. Notwithstanding the fraud act, astating and far more pervasive.
Ideology is most often associated with the accidental fraudster is considered to In cases of collusion, internal controls
frauds like tax evasion and, more recent- be a good, law-abiding person, who centered on segregation of duties are gen-
ly, terrorist financing. For example, a tax under normal circumstances would never erally ineffective in preventing fraud and
evader may believe the government is not consider theft, breaking the law, or harm- other financial crimes. Although internal
entitled to his money, and terrorists may ing others. The fraud triangle was created controls cannot prevent collusive fraud acts,
feel justified in committing credit card with the accidental fraudster in mind. they can assist in the detection of such
fraud to finance their activities. Ideological What if an individual had committed an activities. For example, independent mon-
motivators allow the end to justify the act of fraud at a prior organization? Illegal itoring may reveal that internal controls
means; perpetrators steal money or partic- acts tend to be followed by more illegal acts, have been circumvented through collusion.
ipate in a fraud act or financial crime to and a continuum of illegal acts defines the Management override is not inherently col-
achieve some perceived greater good that pathological fraudster or predator: lusive, but most acts of management
is consistent with their beliefs. Predators seek out organizations where override involve collusion.
While the MICE heuristic oversimpli- they can start to scheme almost immedi- Proactive fraud detection includes a
fies fraudulent motivations, and some moti- ately upon being hired. search for collusion and management over-
vations fit several categories, it is easily At some point, many accidental fraud- ride. Fraud from management override can
remembered. In addition, it provides pro- sters, if not caught beforehand, will move be very difficult to detect. Ultimately, the
fessionals with a broader framework beyond from the behavior characteristic of an acci- board of directors and audit committee
pressure and rationalization within which to dental fraudster to that of a predator. have an obligation and responsibility to
consider the likelihood of fraud by consid- Financial statement fraud perpetrators shareholders to police management. The
ering an expanded set of motivators. often appear to start as accidental fraud- AICPA guide, Management Override of

JULY 2010 / THE CPA JOURNAL 21


Internal Controls: The Achilles Heel of Maintaining skepticism, Ensuring the entity cultivates a vigor-
Fraud PreventionThe Audit Committee Strengthening committee understand- ous whistleblower program, and
and Oversight of Financial Reporting, ing of the business, Developing a broad information and
identifies six key actions that the audit Brainstorming to identify fraud risks, feedback network.
committee should consider in performing Using the code of conduct to assess the In the article, Preventing and Detecting
these duties: financial reporting culture, Collusive Management Fraud (The CPA
Journal, October 2008), Stephen E. Silver,
Arron Scott Fleming, and Richard A. Riley,
Jr., suggest that, beyond the review of man-
EXHIBIT 4 agements fraud risk assessment, an audit
The Fraud Diamond committee should consider the following
questions:
Do the internal auditors and the audit

The Fraud Diamond committee have the knowledge, education,


and awareness of the various fraudulent man-
agement override and collusive schemes that
may be perpetrated by management?
Has the audit committee reviewed a
Incentive Opportunity
comprehensive fraud risk assessment,
including how collusive fraud and man-
agement override schemes are mitigated
and detected?
Have audit committee members par-
ticipated in continuing education programs
that can prepare them for appraising man-
agements fraud risk assessment?
Did the audit committee assist in the col-
Rationalization Capability lusive and management override fraud
risk assessment process, or did it rely
solely on the internal or external audit group?
Does the audit committee have direct
Source: David T. Wolfe and Dana R. Hermanson, The Fraud Diamond: oversight of the internal audit (as required
by the New York Stock Exchange), or do
Considering the Four Elements of Fraud, The CPA Journal, December 2004
the internal auditors report to management?
A proactive approach by the audit com-
mittee reinforces the tone at the top, sends
EXHIBIT 5 a positive signal to all levels of management,
Fraud Assessment Tools by Fraudster Type and acts as a deterrent to those contemplat-
ing a collusive fraud scheme. The percep-
tion of available collusive fraud opportuni-
Collusion ties and the likelihood of being detected in
Accidental (Management such a proactive environment may, in fact,
Antifraud Assessments Fraudster Predator Override) reduce the occurrence of most costly frauds
The Fraud Triangle: within an organization. One can use this
knowledge of collusive frauds and manage-
Perceived Pressure Effective Not Effective Not Effective ment override to evaluate different environ-
Perceived Opportunity Effective Effective Effective ments for the likelihood of fraud acts that
would be undetected by traditional corporate
Rationalization Effective Not Effective Not Effective governance mechanisms. To further assist
The Fraud Scale: Integrity Effective Effective Effective professionals, Exhibit 5 presents the impact
of predators, collusion, and override in con-
The Fraud Diamond: Capability Effective Effective Effective
trast to the lone fraud perpetrator.
MICE Effective Effective Effective
Professional Skepticism Effective Effective Effective A Basis for Fraud Deterrence
Fraud deterrence refers to creating an envi-
Brainstorming Effective Effective Effective ronment in which people are discouraged
Critical Thinking Effective Effective Effective from committing fraud, although it is still
possible. Because opportunity involves

22 JULY 2010 / THE CPA JOURNAL


both access to commit the fraud and the per- The notion of deterrence tends to address grams and a strong corporate culture that
ception that the fraudster can get away with two aspects of the fraud triangle: opportu- commands a high ethical standard.
it, one aspect of deterrence is the fear of get- Importantly for professionals, deterrence
ting caught. In Theft by Employees (Simon efforts are observable and can be used to
& Schuster, 1983), Richard C. Hollinger and assess the likelihood of fraud. Exhibit 6 pro-
John P. Clark found that the perceived cer- vides a checklist to assess antifraud efforts
tainty of detection is inversely related to Importantly for professionals, aimed at addressing opportunity and ratio-
employee theftthat is, the stronger the per- nalization. Understanding who commits
ception that theft will be detected, the less fraudand how and why it is committed
likely it is that an employee will steal. deterrence efforts are observable will enhance a professionals ability to pre-
The second aspect of deterrence is fear vent, deter, detect, and investigate fraud.
of punishment. The 2005 Federal Sentencing
Guidelines Manual defines deterrence as a and can be used to assess
clear message sent to society that repeated Jack W. Dorminey, PhD, and Arron Scott
criminal behavior will increase the severity Fleming, PhD, CPA, CMA, are assistant
of punishment with each recurrence. the likelihood of fraud. professors of accounting at West Virginia
In addition, Sutherland suggests that University, Morgantown, W.V. Mary-Jo
employees, particularly those in senior Kranacher, MBA, CPA, CFE, is editor-
positions, set the ethical tone for the in-chief of The CPA Journal and ACFE
entire organization. When leaders model nity and rationalization. When controls and endowed professor of fraud examination at
questionable, unethical, or fraudulent antifraud programs are introduced as a York College of the City of New York
behavior, normally honest employees are deterrent, the fraudster perceives that the (CUNY), Jamaica, N.Y. Richard A. Riley,
more likely to rationalize fraud. opportunity to commit and conceal fraud Jr., PhD, CPA, CFE, CFF, is the Louis
Conversely, Sutherlands theory also sug- has been reduced or eliminated. F. Tanner Distinguished Professor of
gests that ethical employees might influ- The fraudsters rationalization may be Public Accounting, also at West Virginia
ence those who have fraudulent tendencies. deterred or reduced through training pro- University.
As a result of these concepts, deterrence
is usually accomplished through a variety of
efforts associated with internal controls and EXHIBIT 6
antifraud programs that create a workplace Fraud Deterrence Checklist Focusing on Fear
of integrity and encourage employees to of Getting Caught and Fear of Punishment
report potential wrongdoing. Such actions
increase the perceived likelihood that an act Antifraud controls to increase fear of getting caught
of fraud will be detected and reported. (reduce perceptions of opportunity)
Fraud deterrence can also be achieved
through the use of continuous monitoring Proper controls design 
and auditing software tools. It is enhanced Controls operational as designed 
when the perception of detection is present
and when potential perpetrators recognize Continuous monitoring 
that they will be caught and punished. Auditing software tools 
Antifraud techniques and controls Punishment protocol 
include
an ethical tone at the top; Open communications with employees, vendors, suppliers, and customers 
a meaningful code of conduct; Proper employee activity monitoring 
open communications with employees,
vendors, suppliers, and customers; Effective tip hotlines 
employee activity monitoring; Whistleblower protections 
hotlines;
Monitoring of contractual parties 
whistleblower protection;
a protocol for punishing perpetrators; Antifraud environment to deflate possible rationalizations
the monitoring of contractual parties; and
Proper tone at the top 
proactive fraud auditing.
These items are included as part of a Strong, ethical corporate culture 
checklist shown in Exhibit 6. The deter- Workplace of integrity 
rence fabric includes all corporate gover-
nance professionals, including the board of Meaningful code of conduct 
directors, audit committee, top manage- Antifraud training programs 
ment, and external and internal auditors.

JULY 2010 / THE CPA JOURNAL 23


vol. LXXX/no.7

6 PERSPECTIVES 16 IN FOCUS
6 Perspectives 16 Beyond the Fraud Triangle:
The Journey Toward IFRS in the United States Enhancing Deterrence of Economic Crimes
Publishers Column: Is There a CPA in the House? By Jack W. Dorminey, Arron Scott Fleming,
Mary-Jo Kranacher, and Richard A. Riley, Jr.
Developments in Accounting Education
Fraud is a big problem for business: The costs are estimated
Accounting Associations Foster Development at 5% of businesses annual revenues, representing economic
losses of $2.9 trillion globally. To understand why people
A New Type of Engagement commit fraud, many professionals refer to the fraud triangle.
Developed in the mid-20th century, its points represent the
causal factors of perceived pressure, perceived opportunity,
74 Classified Ads and rationalization. Although the concept has become
central to the literature, professionals and academics
79 Economic & Market Data have offered important insights beyond the fraud triangle.
Using these models to better understand who commits fraud,
80 Editorial how, and why, will enhance a professionals ability to
Self-funding for the SEC? prevent, deter, detect, and investigate fraud.

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