ACFE CFE-Fraud-Prevention-and-Deterrence Certified Fraud Examiner - Fraud Prevention and Deterrence Exam Exam Practice Test

Elements of Routine Activities Theory:

This theory posits that crime occurs when three elements converge:

Availability of suitable targets.

Absence of capable guardians.

Presence of motivated offenders.

Analysis of Other Options:

A. Conditioning theory:Focuses on learned behaviors through reinforcement.

C. Rational choice theory:Examines decision-making processes of offenders.

D. Social control theory:Relates to societal bonds preventing deviant behavior.

Conclusion:Routine activities theory best explains the convergence of these elements leading to crime.

 Definition of Focus Groups:

Focus groups involve small groups of individuals discussing a specific topic under the guidance of a facilitator. This technique is used to gather qualitative insights through direct interaction and observation.

 Why A is Correct:

Observing employee interactions during a focus group provides rich, contextual data about attitudes, understanding, and engagement with fraud awareness training.

 Why Other Options are Incorrect:

B (Surveys):Collect quantitative data but lack interaction and observational opportunities.

C (Anonymous feedback mechanisms):Useful for confidentiality but do not allow observation.

D (Interviews):Individualized and do not involve group dynamics​​.

Findings from the 2020 Report to the Nations:

Asset misappropriation:Most common form of occupational fraud (e.g., theft of cash or inventory). It is frequent but less costly.

Financial statement fraud:Most costly, involving significant manipulation of financial data.

Analysis of Options:

A. Asset misappropriation; corruption:Corruption is less costly than financial statement fraud.

B. Corruption, asset misappropriation:Incorrect order and does not match the costliest scheme.

C. Financial statement fraud; corruption:Incorrect pairing.

Conclusion:Asset misappropriation is most common, and financial statement fraud is most costly.

Three General Approaches to Controlling Corporate Crime:

Government Intervention:Strong regulations and enforcement to ensure accountability.

Voluntary Corporate Changes:Encouraging ethical practices through organizational policies.

Consumer Action:Pressure from consumers demanding corporate responsibility.

Why D is Incorrect:

Media blacklisting is not a formal or systematic approach to controlling corporate crime. It is a consequence rather than a preventive or corrective measure.

 CFE Ethical Responsibilities:

As per the ACFE Code of Professional Ethics, fraud examiners must ensure transparency in their professional conduct. They cannot promise confidentiality if the information must be disclosed to management or other authorities as part of the investigation.

 Why D is Correct:

Agreeing to confidentiality in this situation would breach ethical and legal obligations, especially if the information pertains to fraud or misconduct that the organization needs to address.

 Why Other Options are Incorrect:

A and B:Attempting to maintain confidentiality is misleading and unprofessional.

C:Taking the request directly to management without clarification could breach trust prematurely​​.

Rationalization in the Fraud Triangle:

Rationalization refers to the justification an individual uses to make fraudulent behavior acceptable in their mind.

In this case, Jody justifies his theft by believing the company owes him for his loyalty and hard work.

Why B is Correct:

Jody’s reasoning aligns with the rationalization leg of the fraud triangle, as he convinces himself his actions are justified.

Why Other Options are Incorrect:

A (Perceived non-shareable financial need):Involves financial pressure, not justification.

C (Perceived opportunity):Refers to the ability to commit fraud.

D (Lack of personal integrity):Reflects a broader ethical deficiency, not a specific rationalization​​.

The ACFE has found that terminating the employee involved in fraud is the most common internal response to substantiated cases. While many fraud cases are handled internally without being referred to law enforcement, this is often due to concerns such as reputational damage or cost considerations rather than a lack of evidence.

onflicts of Interest Under the ACFE Code of Professional Ethics:

Fraud examiners must avoid situations that compromise their objectivity, independence, or professional duties.

Disclosure of ownership does not eliminate the conflict of interest if it could impair objectivity.

Analysis of Other Options:

A, C, and D:All are clear conflicts of interest explicitly prohibited under the ACFE Code.

Conclusion:Option B is not prohibited under the ACFE Code but remains problematic if disclosure does not adequately address independence concerns.

 Definition of Professional Skepticism:

Professional skepticism requires maintaining a questioning mindset and critically assessing evidence throughout the fraud examination process.

 Why D is Correct:

Professional skepticism ensures that fraud examiners remain vigilant and rely on evidence to conclude whether fraud has occurred or not. It is dispelled only when sufficient evidence supports a clear conclusion.

 Why Other Options are Incorrect:

A:While skepticism is critical, it does not mean refusing to acknowledge credible evidence.

B:Assuming no fraud occurred contradicts the principle of skepticism.

C:Hypotheses should consider the nature of the assignment and available information​​.

Purpose of the Task:

The team seeks candid feedback on ethical tone, which requires a confidential and direct interaction method.

Comparison of Techniques:

A. Interviews:Effective for obtaining one-on-one feedback in a private setting.

B. Focus groups:Group dynamics may inhibit candid responses due to peer pressure.

C. Anonymous feedback mechanisms:These provide insights but lack the depth and follow-up opportunities of interviews.

D. Surveys:While useful for broad input, surveys are less effective for detailed exploration of ethical tone.

Conclusion:Interviews are the most helpful technique for gathering one-on-one candid feedback.

 Corruption and Fraud Risks:

Corruption involves abuse of power for personal or organizational gain and includes bribery, kickbacks, and aiding vendor fraud.

 Why B is Correct:

Espionage by competitors is not typically classified as corruption, as it does not directly involve abuse of internal authority or a relationship of trust. It is instead an external threat.

 Other Options:

A, C, and D are classical examples of corruption-related fraud risks​​.

ISO 31000:2018 emphasizes that effective risk management must be integrated into all activities across the organization—not just high-risk ones.

“An effective and efficient risk management program... is integrated into all organizational activities, is structured and comprehensive, and is customized and proportionate to the organization’s operations and objectives.”

Employee background checks are considered a preventive control because they are designed to identify potentially risky hires before employment. The manual states that “background checks are a front-line preventive measure in combating fraud by screening out individuals who pose higher risk.”

Integration of Fraud Risk Assessment in Audits:

The fraud risk assessment provides valuable input but does not replace the auditor’s independent responsibility to identify and assess fraud risks.

Why B is Correct:

Professional auditing standards require auditors to perform their own risk assessments, and the fraud risk assessment is only a tool to enhance this process.

Why Other Options are Correct:

A, C, and D reflect appropriate uses of fraud risk assessments in the audit process, such as increasing awareness and designing effective audit tests​​.

References for All Questions:

ACFE Code of Professional Ethics and Fraud Examination Guide​​.

COSO frameworks for corporate governance and fraud risk management​​.

Standards for incorporating fraud risk assessments into the audit process​​.

Detective controls are designed to identify fraud or errors that have already occurred. Continuous audit techniques serve as a detective control by automatically monitoring transactions and flagging anomalies or irregularities for further investigation. On the other hand, preventive controls such as separation of duties, background checks, and hiring policies aim to stop fraud before it happens.

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The G20/OECD Principles call for a corporate governance framework that ensures “the equitable treatment of all shareholders including minority and foreign shareholders.” This principle reinforces fairness and equal rights in governance systems.

“The Principles… call for a corporate governance framework that protects the exercise of shareholders’ rights and supports the equal treatment of all shareholders including minority and foreign shareholders.”

Comprehensive and Detailed in Depth Explanation:

A key element of vendor due diligence is ensuring that third-party vendors have robust ethics and compliance programs. This helps align values, mitigate fraud risks, and establish clear expectations. While audits and questionnaires are good practices, they are not always mandatory or feasible before engagement. Moreover, transparency in seeking vendor information (unlike in A) is a norm in legitimate vetting practices.

Overview of Compliance Programs:An effective compliance program requires clear communication, enforcement, and promotion of ethical standards within an organization. Promoting compliance involves setting up positive incentives, such as rewards for ethical behavior, to encourage adherence to policies and regulations.

Role of Incentives:

Incentives serve as motivators for employees to align with the compliance culture. Examples include bonuses for meeting compliance goals, recognition for ethical behavior, and career advancement opportunities tied to compliance performance.

The U.S. Federal Sentencing Guidelines for Organizations emphasize that for a compliance program to be effective, it must include incentives to encourage proper behavior and discipline to deter violations.

Supporting Reference Materials:

The Association of Certified Fraud Examiners (ACFE) highlights the importance of integrating incentives into compliance programs. These incentives are seen as essential for fostering a culture of ethics and preventing fraud.

Industry standards and frameworks, such as COSO’s "Internal Control - Integrated Framework," also stress the integration of incentives to promote adherence to internal controls and compliance standards​​.

Importance of Positive Reinforcement:

Positive reinforcement through incentives leads to higher employee morale, enhanced commitment to ethical practices, and a reduced likelihood of non-compliance.

A compliance program that merely penalizes non-compliance without rewarding adherence can fail to motivate employees to prioritize compliance.

Application in Fraud Prevention:

By actively incentivizing compliance, organizations can proactively mitigate risks of fraud and unethical practices. This aligns employees’ personal goals with the organization’s ethical standards.

Routine activities theory identifies three main elements necessary for crime: a motivated offender, a suitable target, and the absence of capable guardians. The lack of accountability for misdeeds is not part of this theory, as it focuses on situational factors that facilitate criminal opportunities rather than broader social or institutional factors.

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Comprehensive and Detailed in Depth Explanation:

The Treadway Commission emphasized strengthening the internal audit function as a key fraud deterrent. This includes ensuring auditors have adequate resources, authority, and independence to carry out their duties. While formal structures like audit committee charters are useful, the commission specifically focused on functional empowerment of internal audit.

Privilege of Fraud Examination Reports:

Reports prepared by fraud examiners are not inherently privileged. Privilege depends on the legal framework, the purpose of the report, and whether the attorney-client privilege or work-product doctrine applies.

Without specific legal protection, reports may be subject to disclosure.

Conclusion:Fraud examination reports are not automatically privileged.

The ACFE manual notes that codes of conduct not only serve as a reference for guiding behavior but also enable enforcement and internal discipline within a profession.

“A code of ethical conduct serves as a reference and benchmark for ethical guidance… [and] facilitates practical enforcement and internal discipline throughout a profession.”

The COSO definition of internal control is:

“A process, effected by an entity’s board of directors, management, and other personnel, designed to provide reasonable assurance regarding the achievement of objectives relating to operations, reporting, and compliance.”

This is the formal and widely accepted COSO definition.

 Effectiveness of Consistent Punishment:

Consistent punishment demonstrates an organization's commitment to enforcing anti-fraud policies and serves as a deterrent to potential fraudsters.

 Why A is Correct:

When perpetrators are consistently punished, it sends a strong message about zero tolerance for fraud and reinforces the importance of compliance throughout the organization.

 References:

ACFE guidance on fraud deterrence emphasizes the role of consequences in preventing fraud​​.

Principles in the Fraud Risk Management Guide (COSO and ACFE):

Communicating expectations regarding fraud risk management.

Conducting comprehensive fraud risk assessments.

Implementing preventive and detective controls.

Monitoring and reporting the program’s effectiveness.

Analysis of Option D:

Fraud risk management requires ongoing evaluations, not one-time assessments, to adapt to evolving risks.

Conclusion:Option D is not included in the principles described in the Fraud Risk Management Guide.

Understanding Behaviorism and Punishment:

Behaviorists like B. F. Skinner argue that punishment temporarily suppresses undesired behaviors rather than eliminating them.

Once the punitive stimulus is removed, the behavior is likely to reappear unless it is replaced with a more desirable behavior through reinforcement.

Analysis of Options:

B. Permanently suppressed:This contradicts the principles of behaviorism, as punishment alone does not permanently modify behavior.

C. Occur more frequently:Punishment typically decreases behavior temporarily.

D. Not affected by punishment:Punishment impacts behavior, but the effect is often temporary.

Conclusion:The most likely outcome is that the behavior will return once the punishment ceases.

External auditors are required to report significant deficiencies and material weaknesses in internal control to those charged with governance. The ACFE manual states:

“Auditors must communicate in writing to those charged with governance all significant deficiencies and material weaknesses identified during the audit.”

Allowing employees to report fraud anonymously is a best practice in fraud reporting programs. This encourages whistleblowers to come forward without fear of retaliation or reprisal, increasing the likelihood of fraud detection. Transparency about confidentiality policies further supports employee trust in the reporting system.

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According to the ACFE Manual, in public-sector audits conducted under INTOSAI standards, “government auditors might not have the same level of discretion as private auditors to withdraw from engagements when fraud is detected.” INTOSAI standards focus more on reporting and public transparency rather than withdrawal.

ACFE research indicates that asset misappropriation schemes, such as theft of cash or inventory, are the most common type of occupational fraud. While they are frequent, they typically result in lower financial losses compared to corruption or financial statement fraud, which are less common but can cause greater financial damage.

Rational Choice Theory Overview:

This theory posits that individuals consciously weigh the benefits and risks of committing a crime and make calculated decisions to engage in criminal behavior if the perceived benefits outweigh the risks.

Deterrence Mechanism:

Crime can be deterred by reducing opportunities (e.g., strong internal controls) and increasing the likelihood of detection and punishment (e.g., effective monitoring systems).

Why Other Options are Incorrect:

A. Routine activities theory:Focuses on the convergence of motivated offenders, suitable targets, and lack of guardianship.

B. Differential association theory:Explains crime as learned behavior through interaction with others.

D. Social conflict theory:Suggests crime results from societal inequalities and power struggles.

Why C is Correct:

Rational choice theory explicitly addresses crime prevention through increased risks and reduced opportunities​​.

References for All Questions:

ACFE Fraud Examination Guide​​.

Criminological theories as applied to fraud prevention and deterrence​​.

Corporate governance frameworks and corruption-related risks​​.

A clearly defined organizational structure contributes to accountability and reduces fraud risks. According to the ACFE manual:

“An effectively documented and communicated structure helps prevent fraud by providing clear lines of authority and responsibility and ensuring appropriate oversight.”

 Principle Overview:

Responsibility pertains to the duty of an organization to act in the best interest of society, ensuring sustainable and ethical practices that benefit all stakeholders, including employees, customers, and the environment.

 Corporate Governance Definition:

Corporate governance frameworks emphasize corporate responsibility as a key pillar for maintaining societal trust and long-term value creation.

 Why Responsibility is Correct:

While transparency, fairness, and accountability are essential, responsibility uniquely emphasizes societal interests and ethical conduct​​.

Findings from the 2020 Report to the Nations:

A. Complaints about management:Not the most common red flag; lifestyle changes, such as living beyond means, are more common.

B. Gender of fraudsters:The report consistently shows that men commit more occupational frauds than women.

C. Median losses by executives vs. staff:Losses caused by executives are significantly higher.

D. Past offenses:Most fraudsters do not have a prior fraud-related disciplinary history.

Conclusion:Option B aligns with the findings of the 2020 Report to the Nations.

Understanding Fraud Risk Management Responses:

Risk mitigation refers to implementing controls or measures to reduce the likelihood or impact of a risk.

In this case, by implementing additional internal controls, management aims to mitigate the identified fraud risk.

Definition of Other Options:

A. Assuming the risk:This refers to accepting the risk without taking action to mitigate it. This is generally done when the risk is deemed tolerable.

C. Avoiding the risk:This involves changing business practices or ceasing activities to eliminate the risk entirely.

D. Transferring the risk:This occurs when the responsibility for the risk is shifted to another party, such as through insurance.

Conclusion:The described response clearly aligns with risk mitigation, as it focuses on reducing the risk through internal control measures.

Regulatory and Legal Misconduct:

This category includes practices that violate laws or regulations, such as anti-competitive behavior, insider trading, and conflicts of interest.

Why A is Correct:

Fraudulent customer payments are typically categorized under operational or financial fraud, not regulatory and legal misconduct.

Why Other Options are Incorrect:

B, C, and D:These practices involve violations of regulations or legal obligations, directly aligning with regulatory and legal misconduct​​.

References for All Questions:

ACFE Fraud Examination Guide and related professional standards​​.

International and jurisdictional auditing standards for public-sector auditors​​.

COSO and governance frameworks on fraud risk management​​.

The Treadway Commission emphasizes improving internal controls, which include strengthening the internal audit function. Providing adequate resources and authority to the internal audit function ensures that it operates independently and effectively, which is critical for preventing and detecting fraud. The internal audit function can evaluate financial reporting systems, detect irregularities, and provide valuable recommendations for improvement. This recommendation aligns with the goal of reducing fraud and ensuring reliable financial reporting.

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Analysis of Each Scenario:

A. Rodrigo:Reporting unrelated findings without a clear mandate violates principles of focus and relevance under the ACFE Code.

B. Vivian:Overlooking evidence demonstrates a lack of due diligence and professionalism.

C. Tom:Complying with a court order is permissible, but failure to safeguard client confidentiality before receiving the order constitutes a breach.

Ethical Standards:

Each scenario demonstrates a failure to meet the ethical and professional responsibilities outlined in the ACFE Code.

Conclusion:All scenarios represent violations of the ACFE Code of Professional Ethics.

The “Review and Revision” component is focused on evaluating how ERM practices contribute to organizational value and adapting them accordingly.

“As part of its ERM activities, the organization should review how well the ERM capabilities and practices have increased value over time and how they will continue to drive value.”

 Diane Vaughan's Theory on Organizational Crime:

Vaughan argued that organizational environments prone to crime exhibit a "normalization of deviance," often influenced by management decisions that misalign employee incentives with organizational objectives.

 Why C is Correct:

Misaligned goals create conflicting priorities, increasing the likelihood of unethical behavior to meet individual or team objectives.

 Why Other Options are Incorrect:

A:Challenging the status quo promotes innovation and ethical accountability.

B:Social functions fostering loyalty do not inherently encourage crime​​.

The G20/OECD Principles include:

“Guidance regarding board responsibilities, including establishing appropriate board structures, assigning clear responsibilities, and ensuring board accountability.”

Best Practices for Vendor Due Diligence:

Including a clause requiring vendors to report misconduct demonstrates a commitment to transparency and ethical standards.

This measure also ensures accountability and provides the organization with critical information about potential issues.

Analysis of Other Options:

A. Internal audits:While valuable, conducting internal audits of vendors before an agreement is impractical and costly.

B. Concealing due diligence efforts:Transparency in due diligence helps build trust with vendors.

C. Post-contract questionnaires:Due diligence must occur before contracts are signed.

Conclusion:Including a contractual clause about misconduct reporting is the most accurate recommendation.

 Fraud Prevention Methods:

Prevention strategies often focus on education, awareness, and robust controls rather than covert methods. While covert audits can detect fraud, they are not primarily preventive.

 Why D is False:

Covert audits are reactive and focused on identifying existing fraud, not preventing it.

 Why Other Options are True:

A, B, and C accurately describe key aspects of fraud prevention, such as the importance of perception of detection and the challenges of detecting fraud​​.

Fraud Triangle and Employee Support Programs:

The Fraud Triangle identifiespressure,opportunity, andrationalizationas the key elements contributing to fraud.

Employee support programs help alleviate pressures, such as financial stress or workplace dissatisfaction, which could lead employees to commit fraud.

Analysis of Options:

A. Rationalization:Not addressed directly by support programs.

B. Lack of integrity:Focuses on individual ethics, not pressures.

C. Opportunity:Mitigated through controls, not support programs.

Conclusion:Employee support programs address the pressure element of the Fraud Triangle.

Understanding Conflicts of Interest:

The ACFE Code of Professional Ethics prohibits any engagements that impair the fraud examiner's objectivity, even with disclosure.

Ownership interests in a client organization create significant potential for bias, compromising the integrity of the evaluation.

Analysis of Other Options:

A. Secret infiltration:This is a clear ethical violation.

B. Engagements reducing employer duties:This constitutes a conflict of interest.

D. Representing both sides:Prohibited under the ACFE Code due to conflicting responsibilities.

Conclusion:Option C is a prohibited conflict of interest under the ACFE Code.

 Criminogenic Nature of Organizations:

Research suggests that organizational culture and pressures can override an individual's personal values, especially when authority figures issue direct orders to engage in unethical behavior.

 Why B is Correct:

Strong personal values do not guarantee resistance to unethical orders, as obedience to authority is a powerful psychological force, as seen in studies like the Milgram experiment​​.

 Implication for Fraud Prevention:

Organizations must establish strong ethical environments to reduce the influence of authority pressure on employees

Comprehensive and Detailed in Depth Explanation:

Organizational crime refers to offenses committed by organizations or their agents to benefit the organization, rather than the individual alone. Price-fixing by a group of floral companies to manipulate market conditions is a classic example of organizational crime. The other options—fraudulent returns, theft of goods, and misuse of company funds—are examples of occupational or individual fraud, which benefit the perpetrator rather than the organization.

 Responsibilities of the Board of Directors:

The board is primarily responsible for oversight, governance, and ensuring the organization operates in the best interest of stakeholders. Key responsibilities include:

Acting as intermediaries between shareholders and management.

Safeguarding resources and assets.

Assessing management’s strategies and decisions.

 Why C is Correct:

Directing employees is a management responsibility, not a board function. The board focuses on oversight rather than operational execution.

 References:

ACFE governance principles emphasize the separation of oversight and operational roles​​.

Fraud Risk Management Program Requirements:

Effective fraud risk management programs ensure transparency, consistency, and fairness.

Sanctions for noncompliance should be transparent and communicated to demonstrate a commitment to accountability.

Analysis of Options:

A. Mechanisms for breaches:Necessary to address compliance issues.

B. Consistent and firm punishment:Ensures a deterrent effect.

D. Designated compliance monitors:Vital for program enforcement.

C. Enacted privately:This is false because transparency is essential to maintain trust and deter similar actions.

Conclusion:Option C is false as formal sanctions should be communicated appropriately to promote deterrence and accountability.

Integrity in Fraud Examination:

Integrity involves critical thinking, independence, and prioritizing ethical principles over personal gain. Healthy debate and differences of opinion are integral to maintaining objectivity.

Why Option D is Incorrect:

Avoiding differences of opinion contradicts the need for professional skepticism and robust analysis in fraud examination.

Conclusion:Integrity does not require the avoidance of differences of opinion, making D the correct answer.

Internal Auditor's Role in Fraud Risk Management:

Internal auditors are not directly responsible for establishing or maintaining anti-fraud controls (Option D). This responsibility lies with management.

They are also not responsible for obtaining reasonable assurance that financial statements are free of fraud (Option A). This is the role of external auditors.

Oversight of management's fraud risk actions (Option B) is primarily a governance role, not the auditor's direct responsibility.

Internal auditors focus on identifying and assessing fraud risks, evaluating controls, and recommending further action when necessary.

Conclusion:Option C aligns with the internal auditor's responsibilities as per the standards outlined in the ACFE's fraud risk management framework.

 Theory of Differential Association:

This theory suggests that criminal behavior is learned through interaction with others, primarily within intimate groups.

Principles of the theory include:

Learning through communication.

Acquiring criminal knowledge similarly to other forms of learning.

 Why A is Incorrect:

General needs and values, such as poverty or desire for wealth, do not directly explain criminal behavior under this theory. Instead, the behavior is attributed to learned influences from others.

 Clarification of Other Options:

B, C, and D accurately reflect the principles of differential association​​.

 Responsibility of Auditors:

Under International Standards on Auditing (ISA) 240, auditors are required to investigate any indications of fraud, regardless of the materiality of the misstatement.

Evidence of intentional misstatements indicates the potential for broader fraudulent activity, necessitating a reassessment of audit procedures.

 Importance of Fraud Indicators:

Even if the misstatement does not exceed the materiality threshold, it represents a significant risk factor that could compromise the reliability of the financial statements.

 Why B is Correct:

Adjusting audit procedures ensures that the audit team addresses the broader implications of the fraud risk while maintaining professional skepticism and compliance with auditing standards​​.

Professional Skepticism Defined:

Professional skepticism is an attitude that includes a questioning mind and a critical assessment of evidence. Fraud examiners must remain vigilant to indications of potential fraud throughout an engagement.

Consistent Application:

ACFE standards emphasize that skepticism should be applied consistently, even if initial findings do not indicate fraud, to avoid overlooking potential risks.

Why D is Correct:

Relaxing skepticism can lead to missed evidence or poor judgment, undermining the examination's effectiveness​​.

The ACFE manual emphasizes “tone at the top” as a foundational element of a strong ethical culture.

“Management must show employees through its words and actions that dishonest or unethical behavior will not be tolerated.”

The ACFE research consistently finds that the majority of occupational fraudsters are first-time offenders. Specifically, “85% of occupational fraud perpetrators had never been punished or terminated for fraud-related conduct prior to the crimes in this study.”

 Research Findings by Silk and Vogel:

Their research highlights that business leaders often justify non-compliance with regulations by arguing that adhering to such rules significantly increases operational costs and reduces profitability.

 Rationalization in Legal Violations:

This rationalization is consistent with the fraud triangle concept, where rationalization serves as a justification for unethical or illegal actions.

 Why A is Correct:

This accurately represents a common justification for regulatory non-compliance as documented in fraud and compliance research​​.