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Spending Risks Shift as the Pandemic Continues

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When Twitter offered permanent work-from-home status to all of its 4,600 employees in response to the COVID-19 pandemic, it did so with a $1,000 stipend per employee to furnish and set up functional home office spaces.

For many organizations, such a sweeping move would carry higher risk as more employees, especially those not trained in company spending policy, would be expensing items. During COVID-19, enterprises of all sizes contend with the changing financial implications of adjusting business practices.

Data scientists at Oversight—a global leader in spending management technology—saw out-of-pocket spending increase 17% from April to May and expected this number to rise further in June as more employees without a corporate card make COVID-related expenses. These findings are published in the company’s Spend Insights Report, which analyzed information derived from customer interviews, market observations and Oversight data.  

Several Oversight clients reported finding big-screen TVs and soundbars on expense reports for work-from-home setups. Any of these could ultimately be for personal use or resold for personal gain. One client found that one of its employees spent $7,000 in corporate funds to set up a new home office space.

The months since COVID-19 forced employers everywhere to pivot their office strategies and open expensing capabilities to a broader subset of the employee base. As a result, the fundamental assumptions about spending and risk management in finance operations no longer apply.

New patterns of risk are emerging from these new transactions. However, finance operations teams that take the time to analyze these patterns can develop best practices.

Five key lessons enterprises should understand about spending risk in the 2020 business environment are:

1. Good and Bad Spending Have Reversed Roles

When the rapid shutdown of normal business operations forced the global workforce to shelter in place, travel discontinued abruptly. Airline and transportation activity plummeted in both March and April, as did hotel spending. But purchasing activity was higher than expected in the high-risk categories of mail/phone orders and miscellaneous stores (including merchants such as Amazon, Best Buy and Apple), while out-of-pocket expenditures in the name of business continuity increased dramatically. The result was a business scenario in which much of the historically “good” spending, like travel expenses, was suddenly deemed wasteful to the organization. In contrast, much of the traditionally categorized “bad spending” was now necessary.

2. The Pattern of Risk is Shifting, As is Mitigation Collaboration

Because the risk looks significantly different than it did before the pandemic, finance operations teams are applying more scrutiny to employee spending, and collaborating more. Operations teams are engaging more than ever with counterparts in forecasting, tax and audit to navigate the nuances of risk during the crisis, creating a new best practice that makes identifying and mitigating spending risk easier.

3. Rising Miscellaneous and Out-of-Pocket Costs Cause Payment Platform Risk

Third-party payments increased 40% year-over-year in April according to the Spend Insights Report, as the pandemic drove a significant increase in online shopping activity. That shift to online—as reflected in rising miscellaneous and out-of-pocket spending—was often processed using third-party payment platforms like PayPal and Stripe. When employees spend using these platforms, organizations are exposed to greater risk due to limited visibility into transaction and vendor data.

4. New People Spending is New Risk

Regardless of COVID-19’s impact on an organization, one good rule is that risk is a function of people. According to Oversight data, 70% of employees are good stewards of corporate funds. An additional 25% may make errors or act out-of-policy in certain circumstances, but these individuals are not intentionally involved in waste or fraud. The remaining 5% of employees could use opportunities like COVID-19 to spend maliciously or otherwise act outside of corporate compliance guidelines. Every organization’s goal should be to engender visibility into the 5% of bad actors, while simultaneously seeking to better inform the remaining 25% about the steps they can take to adhere to policy. 

5. Align your Teams and Tools to Ensure Visibility into Spending

By quickly understanding as an organization what employees are spending on today, and at what frequency, leaders will be better suited to manage and mitigate risk. While the profile may be different than before the pandemic, the same tools that guided visibility into spending and risk are available to help organizations understand and analyze spend in the new business climate.

The situation at most organizations is fluid. The essential take-away is to develop a framework and process for near-real-time awareness of employee spending and the associated risks. By recalibrating your sense of the necessary expenditures now, organizations can ultimately ensure continuous control over risks as they emerge.

Most Organizations Deny Prevalence of Fraud

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At a loss of more than $6 billion annually, experts have found fraud occurs in most organizations, but 80% of respondents to a recent survey by ACL believe their organization has “medium to no” exposure.

The 2017 Fraud Survey of more than 500 professionals in the United States and Canada found that “alternative facts” extend to the mentality among many businesses.

“As the phenomena of ‘fake news’ and ‘alternative facts’ permeate the U.

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S. landscape, it is interesting to see how disconnected many executives are from the true prevalence of fraud and corruption in their organizations,” said Dan Zitting, chief product officer at ACL, a risk management software provider. He added that companies increasingly discover they have had “numerous instances of potential fraud” that need to be investigated.

Almost two-thirds of respondents (63%) also said that most instances of fraud committed in their organizations are not detected, and more than 75% said that at least some of the fraud that is detected goes unreported.

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Respondents noted that a company’s fraud experts can feel pressure from senior leaders, direct managers and even peers to suppress or alter their fraud findings. While the existence of internal pressure is no surprise to most, the survey confirmed that pressure from all sides makes fraud harder to overcome.

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“As long as companies refuse to admit that fraud exists, the fraud will continue,” Zitting said. “As unscrupulous employees and vendors realize the company’s ignorance, the problem has great potential to grow.”

According to ACL:
2017 Fraud Survey Results

Wells Fargo: What Should Have Happened

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When Wells Fargo fired 5,300 employees in September for inappropriate sales practices, then-CEO John Stumpf approached the scandal with an outdated playbook. In response to the $185 million in fines levied by regulators, he first denied any knowledge of the illegitimate accounts. Attempting to mitigate press fallout by distancing the company from a group of “bad eggs” acting independently is not the answer, however. Even if Stumpf had maintained this assertion of innocence, changes in the risk environment over the past few years demand a proactive approach.

Rather than simply deflecting responsibility in these situations, executives must be able to accomplish two things:

• Provide historical evidence of due diligence and risk management (if such a program was actually used)
• Demonstrate how the company is adjusting its policies and/or implementing new policies to ensure a similar incident doesn’t happen in the future

In 2010, the SEC’s Proxy Disclosure Enhancement (rule 33-9089) explicitly made boards of directors responsible for assessing and disclosing risk management effectiveness to shareholders. It mandates the use of risk monitoring systems to demonstrate that existing controls (mitigation activities) are effective. Under this rule, “not knowing” about an activity performed by employees is considered negligence.

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This is a crucial development; negligence carries the same penalty as fraud, but it does not require proof of intent. The Yates Memo (2015) gave the SEC ruling more “teeth” by requiring organizations to provide the Department of Justice with all the facts related to responsible individuals.

As a result, many companies have suffered significant penalties and frequently criminal charges, even though their executives were allegedly unaware of illicit activities. Consider the emissions scandal at Volkswagen and fines paid (to the SEC) by global health science company Nordion Inc. In both instances, deceptions were perpetrated by individuals below the executive level, but senior management’s inability to detect/prevent the incidents came back to bite them.

How to Prevent Risk Management Failures at Your Organization

John Stumpf’s approach should have started with an admission of Wells Fargo’s failure in risk management processes across the enterprise, followed by evidence that a more effective, formal enterprise risk management process is being implemented. For example, risk assessments must cascade from senior management down to the front lines and across all business silos. This ensures that the personnel most familiar with operational risks (and how to mitigate them) can keep the board informed.

In other words, instead of simply apologizing and attempting to provide restitution, Stumpf should have demonstrated that Wells Fargo is taking proactive risk management measures to protect its many stakeholders.

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It is the company’s duty to ensure that something like this never happens again.

The scandal is predictably following the same track as have previous failures in risk management: it starts with regulatory penalties, then leads to punitive damages, class action lawsuits, and finally, criminal charges and individual liability, depending on the particular case.

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The key to this pattern is the absence of adequate risk management, which means negligence under the new enterprise risk management laws, regulations and mandates passed since 2010.

The good news is that avoiding serious, long-term consequences is possible if proper actions are taken. For example, by providing a historical record of risk management practices, Morgan Stanley avoided regulatory penalties when an employee evaded existing internal controls. Other corporations that can provide evidence of an effective risk management program (risk assessments, internal controls that address risks, monitoring activities over these internal controls, and an electronic due-diligence trail) are largely exempt from punitive damages, class-action lawsuits, and possible jail time.

When implemented proactively, effective risk management systems have and will continue to prevent scandals, regulatory fines, litigation and imprisonment. For a more in-depth analysis of the Wells Fargo scandal, read the LogicManager blog post “The Walls Fargo Scandal is a Failure in Risk Management.”