Forensic Accountant: Reliability & admissibility as Expert Witness

Forensic Accountingtrade practices like synchronized share trading,
Forensic accounting is a rapidly growing area ofmanipulate and fabricate the books of accounts
accounting concerned with the detection andand cheat the gullible investors. Regulation 11 C of
prevention of financial fraud and white-collarthe SEBI Act, 1992 empowers the SEBI to direct
criminal activities. George A. Manning in his bookany person to investigate the affairs of
"Financial Investigation and Forensic Accounting"intermediaries or brokers associated with the
defines Forensic Accounting as the science ofsecurities market whose transactions in securities
gathering and presenting financial information in aare being dealt with in a manner detrimental to
form that will be accepted by a court ofthe investors or the securities market. Thus
jurisprudence against perpetrators of economicfraudulent and unfair trade practices of the
crimes. The integration of accounting, auditing, andbrokers or market intermediaries are investigated
investigative skills yields the specialty known asby the investigator appointed by SEBI which
Forensic Accounting which focuses very closelyrequire the broker or market intermediary to
on detecting or preventing accounting fraud.furnish information, books of accounts, registers,
"Forensic", according to the Webster's Dictionarydocuments or records etc. which is analyzed by
means, "Belonging to, used in or suitable to courtsthe investigator to find out any manipulation,
of judicature or to public discussion andfraudulent practice or otherwise of the broker.
debate." The word accounting is defined as "aThus, Forensic Accountant can play a lead role in
system of recording and summarizing businessassisting the SEBI to unearth the complex share
and financial transactions and analyzing, verifying,related frauds perpetrated by the brokers.
and recording the results." The term ‘forensic3) The Insurance Act, 1938:
accounting' refers to financial fraud investigationSection 33 of the said Act empowers the IRDA
which includes the analysis of accounting recordsto direct any person ("Investigating Authority") to
to prove or disprove financial fraud and serving asinvestigate the affairs of any insurer. The
an expert witness in Court to prove or disproveinvestigating authority may seek assistance of the
the same. Thus, basically, the forensic accountingauditor (or actuary or both) who shall be the
is the use of accounting for legal purposes.Chartered Accountant within the meaning of
Chartered Accountant Act, 1949 for the purpose
The forensic accounting can be traced back asof assisting him in any investigation. The books of
far as 1817 to Meyer v. Sefton, a Canadian caseaccount, registers and other documents are taken
that allowed an ‘expert witness' to testify inby the investigating authority in its custody to
court. The term ‘forensic accounting' was firstanalyze it to find out the manipulations or
published in an article in 1946 "Forensic Accounting-fabrication in the books of accounts. Thus,
Its Place in Today's Economy" authored byChartered Accountants plays a front role as an
Maurice E. Peloubet, a partner in Price Waterhouse.Forensic Accountant and aid in the investigation
He stated that, "during the war both the publicconducted into the affairs of the insurer as per
and industrial accountant have been and nowthe provisions of Insurance Act, 1938.
engaged in the practice of forensic accounting".4)  The Prevention of Money-Laundering Act,
Many scholars have traced the roots of2002:
investigative accounting to his work. Interest inSection 3 of the Prevention of Money Laundering
forensic accounting spread through the UnitedAct, 2002 defines the offence of money
States and England early in the twentieth century.laundering as involvement of a person in any
One of the first institutions to use the services ofprocess or activity connected with the proceeds
such investigative accountants was the IRS. Theof crime and projecting it as untainted property.
story of Al Capone the famous mobster beingThe three important stages in the money
caught on a tax evasion scheme is well-known.laundering process are:
The FBI decided to use forensic accountants and· Placement: Physical disposal of cash acquired
employed nearly 500 such agents during Worldfrom illegal sources by depositing the cash in
War II. As a profession, forensic accountingdomestic banks or other kinds of financial
continued to grow during the latter half of theinstitutions.
century, as GAAP and tax laws became· Layering: Working through complex layers of
widespread and mandatory.financial transactions to distance the illicit proceeds
The need for Forensic Accountingfrom their source and disguise the audit trail.
Forensic Accounting is a fast emerging field in the· Integration: Making the wealth derived from
"World of Accounting". Although it has beencrime appears legitimate.
around for a long time, it has become increasinglyForensic Accountant can often be involved in the
popular and much relevant today in view of globalfollowing antimony laundering activities:
financial crisis due to the downfall of the Lehman· Investigating and analyzing financial evidence to
Brothers and its ripples felt across the globe.establish a suspicious transaction;
Thus, a new avatar of Accountant has emerged· Developing computerized applications to assist
known as Forensic Accountant. Althoughin the analysis and presentation of financial
Investigative Accounting has been around forevidence;
years, it has only recently begun to transform· Communicating their findings in the form of
into a new branch of accounting, hence Forensicreports, exhibits and collections of documents that
Accounting. Forensic accountants unlike traditionalassist the banks in submission of the suspicious
accountants, look beyond the numbers, put theirtransaction reports to the regulator; and
nose and eye deep into the financial books,· Assisting in legal proceedings, including testifying
records and data to uncover fraud, hidden assets,in court as an expert witness and preparing visual
siphoned funds and the like. The word forensic isaids to support trial evidence.
defined as the application of scientific knowledge5)  The Companies (Auditor's Report) Order,
to legal problems and legal proceedings. The word2003:
accounting is defined as "a system of recordingCARO, 2003 requires the auditor to report to the
and summarizing business and financial transactionseffect that if a substantial part of fixed assets
and analyzing, verifying, and recording thehave been disposed off during the year, whether
results." By combining these two definitions it canit has affected the going concern status. In order
be concluded that forensic accounting utilizes histo carry out the duties, the auditor has to draw a
regular accounting principles & practices incorollary and reference to the section 293
legal situations. Forensic Accounting is like theCompanies Act, 1956, AS 24 ('Discontinuing
bridge which connects accounting system to legalOperations') and to AAS 16 (Going Concern) and
system. Thus, we can say that the forensicthereafter make his observations on this matter.
accounting is an accounting that is used in a courtIt also requires the auditor to report on Frauds i.e.;
of law. One of the most notable legal situations inif any fraud on or by the company has been
the recent past would be the Enron scandals;noticed or reported during the year.
where large numbers of American forensicExpert forensic accounting evidence
accountants were employed. The wave ofWho is an expert witness?
financial crisis primarily caused by corporateAn expert witness is a witness, who by virtue of
malfeasance and fraudulent financial activitieseducation, training, skill, or experience, is believed
eroded public trust and investor confidence into have knowledge in a particular subject beyond
financial reports and audit services and need wasthat of the average person, sufficient that others
felt to look beyond the conventional accountingmay officially (and legally) rely upon the witness's
function which only fulfilled the compliancespecialized (scientific, technical or other) opinion
requirements i.e. company's books of accountsabout an evidence or fact issue within the scope
are kept in accordance with rules &of their expertise, referred to as the expert
regulations. In view of the increasing number ofopinion, as an assistance to the fact-finder. Expert
financial frauds committed by conspiracy withevidence is evidence given to a court or tribunal
complex accounting records manipulation, it wasby a person, skilled and experienced in some
felt that a new tribe of Accountant is needed toprofessional or technical sphere, of the conclusions
detect the financial fraud in companies with hishe has reached on the basis of his knowledge,
accounting, auditing, and investigative skills and alsofrom facts reported to him or discovered by him
assist in legal matters. This area of accountingby tests, measurements or similar means. It is
came to be known as ‘forensic accounting'.commonly given by, for example, doctors,
There is a global awareness to fight the cases ofchemists, surveyors, architects, accountants and
financial frauds. Though many strategies havethe like. In a Scottish case, Davie v Edinburgh
been formulated and many actions have beenMagistrates (1953) , it was said that the function
taking to fight against it, the problem still persists.of an expert witness "…is to furnish the judge
One of the major hindrances in fighting financialwith the necessary scientific criteria for testing
crime cases is lack of quality forensic analysis ofthe accuracy of his conclusions, so as to enable
the financial statements and records due to lackthe judge to form his own independent judgment
of forensic accounting professionals. This authorby the application of those criteria to the facts
who had been an investigating officer during hisproved in evidence" .
tenure with Delhi Police in number of major casesAn expert witness is different from ordinary
of financial crimes have faced this dearth ofwitness
quality forensic accounting experts who couldExpert witnesses have a different status from
have come handy in timely & accurateordinary witnesses when giving evidence at a
investigation of the intricate financial crimes andCourt or other judicial or quasi-judicial tribunals.
unearth the complex modus operandi adopted byThe evidence of the "expert" differs from that of
the fraudsters who are themselves in somethe ordinary witness who testifies as to facts
cases highly qualified financial professionals. Theobserved, in that the expert is permitted to
reason why there has been rampant increase inexpress his/her opinion on a matter that has
white collar financial crimes because they thinkoccurred in the past, or may occur in the future
that they can get away with it with impunity andwhich have not been actually observed by the
the greatest deterrent to thwart the criminal actexpert, who is providing evidence. The relevance
is law enforcement. However, the conviction rateand weight which the Court or tribunal will
in the financial fraud cases was very low due toattribute to such an opinion within the total
weak law enforcement which is attributable toevidence which is adduced is a matter for the
weak litigation support in prosecution process.Court or tribunal.
Without full support of accounting expert,An expert, unlike other witnesses, is allowed,
prosecutors often fail to prove and providebecause of his special qualifications and/or
strong evidence to put fraudsters behind bar.experience, to give opinion evidence. It is for his
Here, the Forensic accounting can play anopinion evidence that he is called, not for his view
important role here by providing accounting orof the facts or circumstances of the dispute,
financial information or other evidentiary inputs foralthough his interpretation of the facts is often
legal purposes. To achieve the aim, forensicnecessary in order to explain and/or justify his
accountant besides having financial accountingconclusions.
expertise, should also have proven skill in law,Forensic Accountant as an Expert Witness:
scientific investigative technique, interpersonal andThe tradition and law relating to the status of the
communication skills etc.experts as witnesses dates back to English
Growth of Forensic AccountingCourts around 1550. However, the first recorded
The Western Countries are utilizing the forensicuse of an accountant as an expert witness was in
accounting expertise to address the financial fraudMeyer V. Sefton, 2 Stark. 274 (1817). The use of
cases. United States and Canada are pioneers inForensic Accountant testifying as an expert
development & implementation of Forensicwitness in the Court of law is becoming
Accounting. The Canadian Institute of Charteredincreasingly prevalent today in view of the rapid
Accountant recently recognized Investigative andincrease in the financial fraud cases. In court cases
Forensic Accounting as an accounting specialty.where the knowledge of an expert can help to
The CICA has started granting its members tobetter explain the facts in issue or relevant facts,
use the designation initials CAIFA who completean "expert witness" may be called upon to give
three years post qualification experience as a CAexpert testimony.
with Diploma in Investigative and ForensicSection 45 of the Evidence Act which makes
Accounting (DIFA) from the University ofopinion of experts admissible, lays down that
Toronto. The CA-designated specialist inwhen the Court has to form an opinion upon a
investigative and forensic accounting (CAIFA)point of foreign law, or of science, or art, or as to
combines the well-recognized and respectedidentity of handwriting or finger impressions, the
attributes of the CA – in particular integrity,opinions upon that point of persons specially skilled
understanding of business, and financial acumenin such foreign law, science or art, or in questions
– with an in-depth knowledge and experienceas to identity of handwriting, or finger impressions
in investigative and forensic accounting. Theare relevant facts. However, neither the Indian
CA-designated specialist in investigative andEvidence Act nor there is any seminal judicial
forensic accounting (CAIFA) combines thepronouncements which clarifies as to when, how
well-recognized and respected attributes of theand under what circumstances, the testimony of
CA – in particular integrity, understanding ofForensic Accounting Expert would be admissible or
business, and financial acumen – with aninadmissible.
in-depth knowledge and experience in investigativeIn order, to bring the evidence of a witness as
and forensic accounting. This is accomplishedthat of an expert it has to be shown that he has
through a profession-endorsed certificationmade a special study of the subject or acquired a
process that has ongoing experience andspecial experience therein or in other words that
education requirements. The CAIFA tells litigationhe is skilled and has adequate knowledge of the
lawyers, law enforcement professionals, thesubject. The Cost Accountant or Chartered
courts and other legal forums that the designatedAccountant can be considered as an expert to
holder is well positioned to practise in areas suchgive testimony within the meaning of Section 45
as fraud and economic loss quantification, including:of the Evidence Act. Moreover, the draft of "The
· investigating and analyzing financial evidence;Companies Bill, 2008" includes the definition u/s 2
· testifying as an expert witness ;(1) (zn) which interalia includes Cost Accountant
· becoming involved in criminal investigations andand Chartered Accountant in the definition of
uncovering financial evidence in employee or"Expert" which can be also considered/extended
insurance fraud cases;for relying upon their testimony in the Criminal/civil
· Investigating in the rapidly evolving area ofcases by the court.
computer and Internet fraud.In USA, however, the admissibility of the Forensic
Forensic Accounting implementation in IndiaAccounting Expert testimony is supported by the
However in India, this branch of accounting hasJudicial Pronouncements and Federal Rule of
not got its due recognition even after alarmingEvidence. Over the years, the US Supreme Court
increase in the complex financial crimes and lackhas delivered several decisions clarifying its
of adequately trained professionals to investigatestandards for the admission of expert testimony:
and report on the complex financial crimes. TheIn Frye v. U.S., the Court stated that expert
task of Forensic Accountants is handled bytestimony will be admitted if based on a
Chartered Accountants who apart from handlingmethodology "generally accepted" by the scientific
traditional practice of auditing as required undercommunity.
the Companies Act, 1956 or Income Tax Act areIn Daubert v. Merrell Dow Pharmaceuticals, Inc.,
called upon by the law enforcement agencies or509 U.S. 579 (1993) the Court concluded that the
the companies or private individuals to assist intrial judge must act as a gatekeeper for expert
investigating the financial crime or scam. The CAtestimony, considering several nonexclusive
or CWAs in India are best suited for thisfactors applicableto the testimony's reliability and
profession due to their financial acumen acquiredrelevance, including:
during their rigorous training which can be further· Whether the theory or technique has been or
honed by introducing post qualification degree orcan be tested,
diploma in Investigating and Forensic Accounting· Whether the theory or technique has been
similar to one introduced by CICA. The CA orsubjected to peer review or publication,
CWA who acquire post qualification in· The known or potential rate of error, and
Investigative & Forensic Accounting can use· Whether the theory or technique is generally
the designation CA-IFA or CWA-IFA and be legallyaccepted in the relevant scientific community.
recognized as the Forensic Accounting Experts toAlthough Daubert focused on the admissibility of
handle the investigation of financial crimes andscientific expert testimony, its progeny have had
give expert testimony in the Court of Law.a great impact on Financial Expert testimony. In
However, no efforts has so far been made byKumho Tire Co. V. Carmichael, 526 U.S. 137
the ICAI and ICWAI, the two leading statutory(1999), the Court made clear that the gatekeeper
accounting professional bodies to move in thisfunction applies to all expert testimony, not just
direction and set up a institute which can offerscientifically-based testimony.
the post qualification diploma in Investigative andRule 702 of the Federal Rules of Evidence
Forensic Accounting to its members.effectively codifies the Supreme Court's decisions
However, growing financial fraud cases, recentin "Daubert" and "Kumho". Rule 702 provides that
stock marker scams, failure of non financialif the Court finds that scientific, technical or other
banking companies, phenomena of vanishingspecialized knowledge "will assist the trier of fact
companies and plantation companies and failure ofto understand the evidence or to determine a
the regulatory mechanism to curb it has forcedfact in issue," and if the Court finds that the
the Government of India to form Serious Fraudwitness is qualified as an expert "by knowledge,
Investigation Office (SFIO) under Ministry ofskill, experience, training, or education," then the
Corporate Affairs which can be regarded the firstCourt may permit the witness to testify — so
step of Government of India to recognize thelong as the witness' testimony is based on
importance and advance the profession of"sufficient facts or data," the testimony "is the
forensic accountants. The SFIO is aproduct of reliable principles and methods," and
multidisciplinary organization having experts fromthe witness has "applied the principles and
financial sector, capital market, accountancy,methodology reliably to the facts of the case.
forensic audit, taxation, law, informationFurther, concerning determinations of nonscientific
technology, company law, customs andexpert testimony reliability, financial expert
investigation. These experts have been takentestimony (which includes Forensic Accountant
from various organizations like banks, SecuritiesTestimony) in particular, the Advisory Committee
& Exchange Board of India, Comptroller andon the Federal Rules of Evidence and the Standing
Auditor General and concerned organizations andCommittee on Rules of Practice and Procedure
departments of the Government. However, the("Committee") which proposed amendments to
main important law enforcement agency involvedthe texts of Rules 701, 702, and 703, specifically
directly in combating white-collar crimes is theobserved:
Police, CBI, DRI etc. There is a total lack on the"Some types of expert testimony will not rely on
part of these law enforcement agencies to trainanything like a scientific method, and so will have
their investigators in this specialized part ofto be evaluated by reference to other standard
investigating white-collar crimes involving forensicprinciples attendant to the particular area of
accounting. The investigation of the major financialexpertise. . . . The expert's testimony must be
crimes is handled by ordinary investigating officersgrounded in an accepted body of learning or
who after spending some time in investigation ofexperience in the expert's field, and the expert
conventional crimes are shunted to the economicmust explain how the conclusion is so grounded.
offence wing and they are expected to handle"Whether the testimony concerns economic
the financial crime cases involving complex &principles, accounting standards, property valuation
intricate financial records which is required to beor other non-scientific subjects, it should be
analyzed to unearth crime or unique MO adoptedevaluated by reference to the ‘knowledge
by the white collar criminal. The result is obvious,and experience' of that particular field."
the case dies its natural death and the criminalsTherefore, under the Federal Rules of Evidence, a
roam free as the IO given his lack of specializedjudge will permit an accountant to testify as an
knowledge & qualification fails to properlyexpert witness only if the judge decides that:
investigate the financial crime to its logicalThe accountant's testimony will help the jurors or
conclusion. On the other hand if we look at thejudge understand the evidence or determine a
western countries particularly USA, the lawfact in issue.
enforcement agencies of which like DEA, FBI, CIAThe accountant is qualified as an expert by
has well marshaled its pool of special agentsknowledge, skill, experience, training, or education.
having forensic accounting backgrounds that areThe accountant can show that his or her
the backbone of the bureau's financial crimes andtestimony (a) will be based on sufficient facts or
terrorism financing units and investigate withdata and (b) will be the product of reliable
professional acumen, the complex financial crimeprinciples and methods that have been applied
like money laundering, internet crimes, financialreliably to the facts of the case. (These
institution fraud and other economic crimes.requirements are often referred to in shorthand
Today, there are more than 600 FBI agents withas "qualification, reliability, and fit.")
accounting backgrounds. Thus, it is highlyThus, under the rule announced in Daubert v.
imperative on the part of law enforcementMerrill-Dow Pharmaceuticals, Inc., 509 U.S. 579
agencies in India that they follow the suit and(1993) and expanded in Kumho Tire Co. v.
engage specialist forensic accountant on its rollCarmichael, 526 U.S. 137 (1999), the courts must
whose engagements relating to criminal mattersensure that experts-scientific and otherwise-will
typically arise in the aftermath of financial fraud.offer testimony that is methodologically sound and
The Indian Law which refers to Forensicrelevant to the facts of the case before
Accounting:admitting their expert testimony.
1) The Companies Act, 1956:a) Section 235 andQualifying as an Expert Witness
237: There are provisions in Companies ActChallenges to financial expert testimony have
(Section 235 and 237) which empowers theskyrocketed in recent years. Since Daubert v.
Central Government to inspect the books ofMerrell Dow Pharmaceuticals, Inc. (1993), an
accounts of a company, to direct special audit, toincreasing number of testifying experts have been
order investigation into the affairs of a companysubjected to challenges by opposing counsel in an
and to launch prosecution for violation of theattempt to prevent the experts from testifying
Companies Act, 1956. Books of accounts and(Journal of Forensic Accounting: 1524-5586
other documents of the companies are inspectedVol.IV(2003), Page-113). Figlewicz and Sprohge in
by the officers of the Directorate of Inspectiontheir article, "The CPA's Expert Witness Role in
and Investigation and the Registrars ofLitigation Services: A Maze of Legal and
Companies. These inspections are designed to findAccounting Standards," offer ten guidelines to help
out whether the companies conduct their affairsavoid legal challenges:
in accordance with the provisions of the1. Know the relevant professional standards.
Companies Act, 1956 to see whether any unfair2. Apply the relevant professional standards.
practices prejudicial to the public interest are being3. Know the relevant professional literature.
resorted to by any company or a group of4. Know the relevant professional organizations.
companies and to examine whether there is any5. Use generally accepted analytical methods.
mismanagement which may adversely affect any6. Use multiple analytical methods.
interest of the shareholders, creditors, employees7. Synthesize the conclusions of the multiple
and others. Wherever inspection reports discloseanalytical methods.
any information that may be of interest to other8. Disclose all significant analytical assumptions and
Departments or agencies like the Ministry ofvariables.
Commerce and Industry, Central Board of Direct9. Subject the analysis to peer review.
Taxes, Enforcement Directorate, State10. Test the analysis-and the conclusions-for
Government or Provident Fund Authorities, suchreasonableness.
information is passed on to them. If an inspectionNow the various investigation agencies such as
discloses a prima facie case of fraud or cheating,Police, CBI etc. are taking the help of CA/CWA as
action is initiated under provisions of thea Forensic Accountant and using their report as
Companies Act, 1956 or the same is referred toevidence in the cases of criminal/civil nature.
the Central Bureau of Investigation.b) ProvisionsWhether the aforesaid principles/guidelines laid
of Sick Industrial Companies Act incorporated intodown by the two US Supreme Court Judgments
the Companies Act, 1956: The Section 424A(5)incorporated into Federal Rules of Evidence would
of the Companies Act, 1956 empowers Nationalbe followed by Indian Courts or not will become
Company Law Tribunal (NCLT) to examine asclear in the due course of time.
preliminary issue whether the company is a sickHowever, the fact is that though till today there is
industrial company u\s 2(46AA). Thus evengeneral acceptance of admissibility of scientific
before examining the viability of the scheme ofevidence and expert's opinion in Indian Courts,
revival proposed by the company, NCLT canthere is no special law with respect to this which
check the genuineness of the reference made tolays down criteria, principles or guidelines in clear
it. Thus, inquiry by operating agency will only be toterms with regard to when the expert opinion
enable NCLT to decide the viability of the schemewould be admissible and when it will not as is the
and to assess whether the company has thecase under the US federal law. Section 45 of the
ability to revive on its own. Further, Section 424BIndian Evidence Act is insufficient in this regard.
of the Companies Act, 1956 empowers theHowever, in case of doubt, the principles laid
tribunal to make such inquiry as it may deem fitdown by US Supreme Court can be adhered to.
for determining whether any industrial companyIn conclusion, one should understand that it is
has become a sick industrial company. Further, theultimately for the Court Of Law to decide as to
Tribunal may, if it deems necessary or expedientwho is qualified as an expert by knowledge, skill,
so to do for the expeditious disposal of an inquiry,experience, training or education, who may testify
require by order any operating agency to enquirethereto in the form of an opinion or otherwise if:
into the scheme for revival and make a report1. The testimony is based upon sufficient facts or
with respect to such matter as may be specifieddata,
in the order. Operating agency is group of experts2. The test is the product of reliable principles and
consisting of persons having special knowledge inmethods, and
banking & industry in which sick industrial3. The witness has applied the principles and
company is engaged and includes public financialmethods reliably to the facts of the case
institution, State level institution, scheduled bank orHowever, no doubt, with the rapid increase in the
any other any other person as may be specifiedcases involving misappropriation of funds,
by general or special order as its agency by themanipulation of books of accounts, banking fraud
Board. Thus, Forensic Accountant can be part ofcases, Securities scams etc. involving complex
operating agency and investigate whether thefinancial transactions, the Forensic Accountants
reference made by the company is genuine orand admissibility of their testimony needs to be
the accounts are manipulated or fabricated to suitelucidated and these would be determining factors
the scheme of reference made to NCLT tofor deciding the fate of these cases. The
declare it as sick company and thereby siphoninvolvement of Forensic Accountant in financial
public funds.fraud cases and his testimony will not only take
2) SEBI Act, 1992:these cases to logical conclusion but also will go a
The share market is highly volatile and thelong way ahead to put a curb on these menace
brokers indulge into various unfair and fraudulentof white collar offences.