In the wake of a constantly evolving fraud landscape, the Committee of Sponsoring Organizations of the Treadway Commission (COSO), of which IMA® (Institute of Management Accountants) is a member organization, and the Association of Certified Fraud Examiners (ACFE) recently initiated an effort to refresh the landmark Fraud Risk Management Guide (FRMG). The aim: to make it more current and more relevant to the changed and changing fraud environment. Since it was developed by COSO and the ACFE five years ago, the FRMG has quickly gained widespread recognition as a source for best practices for preventing, detecting, and deterring fraud. 

A “refresh task force” is currently seeking recommendations from practitioners on how and where the FRMG can be improved. Specifically, the task force is seeking suggestions on the following elements of the guide:

  • Explaining how fraud risk management relates to and supports fraud deterrence.
  • Updating and expanding information related to the use of data analytics as integral parts of each of the five fraud risk management principles.
  • Explaining how internal control and fraud risk management are related and support each other but are different in some important respects.
  • Adding updated information with respect to recent legal and regulatory developments pertaining to fraud and fraud risk management, including:
    • The Department of Justice’s Evaluation of Corporate Compliance Programs
    • The Government Accountability Office’s A Framework for Managing Fraud Risks in Federal Programs
    • The Fraud Reduction and Data Analytics Act of 2015
  • Expanding and updating information related to the importance of fraud reporting
    systems (hotlines) in detecting, preventing, and thus deterring fraud.
  • Adding information pertaining to emerging fraud risk arenas, including:
    • Cybersecurity and cyberfraud
    • Blockchain and cryptocurrency
    • Ransomware
    • COVID-19 response efforts, CARES Act, and related programs
    • Remote working and hybrid working environments
  • Expanding the FRMG’s list of fraud exposures.

IMA members with suggestions on how to improve the FRMG publication on the above topics are encouraged to send their comments to