Background:

Companies subject to Sarbanes-Oxley must now implement antifraud programs and controls that are evaluated annually during the integrated audit6. Although most of these companies have already implemented components of an anti-fraud program such as codes of ethics and conduct, they may need to enhance their programs to meet the requirements of the new law and to avoid an auditors finding of a significant deficiency or material weakness in internal controls7. Private companies should also have an understanding of effective fraud management, particularly if their strategy contemplates a public debt offering, IPO or sale to a public company. Apart from mitigating legal and regulatory risk, fraud management provides significant cost savings opportunities, which directly affect the bottom line.

The COSO Internal Control Framework Management must base its assessment of the effectiveness of the companys internal control over financial reporting on a suitable recognized control framework established by a body of experts. In the United States, the Committee of Sponsoring Organizations (COSO) of the Treadway Commission has published Internal Control Integrated Framework9, which has emerged as the framework that management and auditors use to evaluate internal controls. Accordingly, we apply the COSO framework because most companies and auditors in the United States use it to assert and audit the effectiveness of internal controls.

Applying the five components of the COSO internal control framework (control environment, risk

assessment, control activities, information and communications, and ongoing monitoring), this white

paper (1) enumerates the attributes of good program design and operating effectiveness and (2)

provides guidance regarding the kinds of deficiencies that typically result when one or more of these

key elements are absent or ineffective.

Although antifraud programs and controls must include all five components of the COSO

framework, special emphasis is on the control environment, the tone set at the top of an

organization that influences the control consciousness of its people.

Now back to main issues:

What is The Anti-fraud programs and Controls, what is their effective elements, and "talk in details about the Elements of effective antifraud programs and controls,"?