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July 16, 2009 

William H Black, CPA, PC   
7040 Hunters Knoll   
Sandy Springs, Georgia 30328   
telephone 770.698.8020   
fax 770.399.6731   
whb@billblackcpa.com   

 

Building an Analytical Database
Lessons from a $600 Million Ponzi scheme

Copyright © 2005, William H. Black


Building an Analytical Database

What do you do when confronted with filing cabinets full of paper (accounting records, purchase orders, sales reports) and you can’t follow the natural human inclination to walk away or hand it to someone else? One answer is to build a database, to capture and cross-reference data for pattern identification and summarization. We faced this situation in investigating a $600 million Ponzi scheme which generated enough documents to fill a 15’ by 10’ room to the ceiling. Our database design and review guidelines may be useful to you in your document-intensive challenges.

Categorize the available information

What documents do you have? What do they purport to represent? Where did they originate? Are there totals, summaries, or reconciliations to indicate when all items have been captured? Is any information available on magnetic media, or will it need to be keyed in?

Identify relevant items of information

What are the issues under review? How do the documents relate to those issues? How can you maintain an audit trail? What is the expected end product, and where will it be used? How is it likely to be challenged?

Design and implement a structure to capture information

Even if all documents are imaged to optical storage (increasingly common in document-intensive cases), optical character recognition and full-text retrieval do not substitute for a well-designed database. When totals, averages, or counts of particular items are needed, entering data elements into a database supports useful analysis. The data structure needs to capture all potentially relevant items – what might take a short time to enter on the first pass through the documents may require mammoth efforts to add missing data later on.

Use all the information available

For example, in addition to accounting information, we captured phone numbers for purchasers and sellers. We then obtained long distance telephone call records and matched numbers called per the phone bill against calls purportedly authorizing transactions. Comparison to a phone directory database showed several anomalies. In one instance, numbers which the transaction logs indicated belonged to two different groceries were actually listed to an auto towing service in a different city. That anomaly might not be conclusive by itself, but it provides a powerful indicator that something was wrong with the transaction.

Establish validation routines to promote confidence in the data

Validation can range from monotonous (manually checking data entered against source documents) to accounting-intensive (comparing totals to transactions reflected in bank records) to high-tech (computerized comparison of source document data to valid data obtained from external sources. For example, this fraud involved grocery arbitrage, so we obtained a file of valid Universal Product Codes (UPC) and compared UPCs reflected on purchase orders against that valid file.

Standardize and expedite data entry

Set up a table of commonly used terms (names of banks, product names and descriptions, frequent customer, standard comments, etc.) to speed up data entry as operators select from a list of choices. But, make sure that valuable information is not lost in the process. For example, consistent misspellings in documents for fraudulent transactions could be hidden by the use of a data table and "cleaning up" the database, possibly hiding potential indicators of fraud.

Use the database to search for patterns

After compiling data on thousands of purchase orders and related documents, we reviewed summaries of data elements in various combinations. We noted that legitimate transactions were generally paid by a grocery company check within 30 days of delivery, while bogus deals were settled by wire transfers from a known confederate company 85 days after purported delivery. Other patterns (geographic location, reciprocal trading, size of transactions, person authorizing) became clear through study, aiding in development of an effective checklist to test whether or not a transaction was genuine.

Back up your data frequently

Our data entry teams worked for months against tight deadlines and at great cost. Losing even a portion of the database to system crashes, operator error, or deliberate incursion could mean the failure of the entire project, as we needed to control data integrity throughout the process. We couldn’t afford to waste more than a day in recovering from a data disruption, so we made comprehensive daily backups, with even more frequent attention paid to "mission-critical" files, and kept copies of backups securely off-site.


For More Information Contact:

Bill Black
William H. Black, PC
Tel: 770.698.8020
FAX: 770.399.6731
Internet: http//billblackcpa.com

Email: whb@billblackcpa.com


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