ACFE CFE-Investigation - Certified Fraud Examiner (CFE) - Investigation

Benford’s Law applies to naturally occurring sets of numbers such as invoice amounts, expense reports, and transaction data. The Fraud Examiners Manual shows Benford’s Law tests applied to vendor payments to detect anomalies like duplicate or inflated invoices. Telephone numbers, employee IDs, and bank account numbers are assigned numbers and do not follow Benford’s distribution, so they are unsuitable for this test.

 “As a general rule, questioning should proceed from the general to the specific; it is best to seek general information before details. A variation… is to begin with known information and work towards unknown areas”【9:2014 International Fraud Examiners Manual.pdf†L39-L51】.

ï‚· Random order is not recommended and breaks the logical flow.

A memorandum recording a whistleblower tip is a written record. The Fraud Examiners Manual defines documentary evidence as evidence “presented in the form of documents such as memoranda, contracts, emails, or other records”. Testimonial evidence comes from oral statements; here, the memorandum itself is the evidence, so it is documentary.

The Fraud Examiners Manual warns against phrasing admissions as direct questions using emotive terms:

“The admission-seeking interview begins with a direct accusation… The accusation should be phrased as though the accused’s guilt has already been established. Emotive words such as steal, fraud, and crime should be avoided… Wrong: ‘Did you do this?’”.

Thus, phrasing the question as “Did you steal the money?” is least effective.

When obtaining a verbal confession, the fraud examiner should secure details such as: admission of wrongdoing, number of instances, amount involved, dates, involvement of others, residual assets, and motive. However, it does not matter whether the suspect claims the conduct was an accident; that is not necessary to record.

The Fraud Examiners Manual states:

“Records obtained from financial institutions are perhaps the single most important financial source available to a fraud examiner for tracing purposes”.

These records reveal deposits, withdrawals, transfers, and are essential in asset tracing.

“Metadata information can help determine who wrote a document, who received, opened, copied, edited, moved, or printed the document, and when these events occurred”.

Thus, metadata is the best source for creation date.

The Fraud Examiners Manual explains that before obtaining or cleansing data, the first step in using data analysis is the planning phase. This includes understanding the data, articulating objectives, and building a profile of potential frauds. Without this, examiners risk inefficient analysis and overlooking key fraud risks.

✅ Answer: C. Build a profile of potential frauds

The manual and CFE Prep list the main limitations:

Coverage varies by jurisdiction.

Searches are limited in area.

Records are often abstracts.

Information may be inaccurate or outdated.

Searches can be erratic.

Nowhere is “difficulty in finding database companies” mentioned.

Fraud examination reports are not written only for internal use. The 2014 International Fraud Examiners Manual clearly emphasizes:

“When drafting a report, fraud examiners must consider who might end up reading it. Fraud examiners should keep in mind that the fraud examination report will be read by the general public and adverse parties. Under no circumstances should the fraud examiner prepare a communication with the idea that the information will not be disclosed to adverse third parties. Fraud examiners should draft their reports with this caveat in mind.”

The manual further specifies the wide range of potential readers:

*“There are many individuals and groups that might end up reading a fraud examination report, including the following parties:

Company insiders (managers, board of directors, owners, investors, etc.)

Attorneys (legal counsel, prosecutors, regulators, and defense counsel)

Defendants and witnesses

Press and media outlets

Judges or juries”*

This aligns with the CFE Prep - Investigations study guide, which also confirms:

“There are many parties that might read a fraud examination report, including company insiders, attorneys, defendants and witnesses, press and media outlets, and judges or juries.”

📌 Interpretation:

The media may access the report through litigation disclosures or leaks.

Opposing legal counsel will review the report during discovery or trial.

Investors and owners (company insiders) are primary stakeholders.

Thus, the only correct choice is D. All of the above, because fraud examination reports must be written with all possible audiences in mind, ensuring accuracy, clarity, impartiality, and professionalism to withstand scrutiny from multiple directions.