An Analysis Of SAS No. 99 And Its Impact On The Big Fraud In Kentucky

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Thomas G. Noland
Kenneth M. Washer

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Abstract

Statement on Auditing Standards (SAS) No. 99 was implemented in 2002 and requires auditors to expand audit procedures to detect fraud.  This paper analyzes the impact the procedures outlined in SAS No. 99 would have made if they had been in effect at the time of one of the largest frauds in the history of Kentucky.  Wallace Wilkinson, former governor of Kentucky, was the target of FBI investigations at least seven times.  Wilkinson entangled such well-known names as the late Dave Thomas, founder of Wendy’s restaurants, in his fraud.  At the time of his death in July 2002, Wilkinson’s business empire was in bankruptcy after being kept afloat for years by one of the largest Ponzi schemes in the history of the state. 

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