Statement On Auditing Standards No. 99: Consideration of Fraud - Criticisms of SAS 99

Criticisms of SAS 99

The primary criticism of the standard is that many procedures are suggested rather than required. For example, it is suggested that auditors consider surprise procedures like showing up unannounced for an inventory count. In actual practice auditors often tell clients which inventory locations they are going to ‘observe.’ Telling clients which locations are going to be audited makes it easier to commit inventory fraud. A similar criticism is that SAS 99 doesn’t close expectation gaps. The guidelines and suggestions provided in the standard increase expectations on the profession. As a result, auditors must consider the requirements of SAS 99 as the minimum level of work required to detect fraud. They must be prepared to defend any decision not to pursue one of the recommended procedures listed in SAS 99.

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