Forensic and Special Investigations Thought Leadership

Conducting and Internal Investigations F. Dean Driskell III, CPA

Performing forensic analyses can be some of the most rewarding, but also the most challenging, work for a professional . This discussion provides a practical guide to conducting forensic accounting and internal investigations. This discussion summarizes some of the real-world experiences of a seasoned .

ntroduction of forensic accounting is examination. Fraud I examinations may be conducted by either accoun- The term “forensic accounting” is often misused tants or nonaccountants (collectively referred to as and misunderstood. When I tell someone that I am “analysts” throughout this discussion). When foren- a forensic accountant, the response I typically get sic investigate allegations of miscon- 1 is, “So, like CSI on television!” And then I say, duct or fraud within businesses, those investigations “Yeah, sort of. But I investigate numbers instead are often referred to as internal investigations. of murders and dead bodies.” Then their excited This discussion provides summary information facial expression fades away and they change the related to a variety of forensic accounting and inter- subject. nal investigation engagements. The practice of forensic accounting can be fas- Sometime earlier than 400 BC, Sophocles, the cinating. In my 20-plus years of experience in the Greek tragedian, said that he would “rather fail with field, I have traced belonging to Holocaust honor than succeed by fraud.” Unfortunately, in victims, testified in litigation matters where the today’s time, that sentiment is becoming less com- continuance of the company was at stake, worked mon—especially in the corporate world. as a special master,2 investigated Ponzi schemes,3 managed teams involved in billion dollar litigations, A quick look at the business press over the past analyzed large bank , worked with the FBI and year produces numerous articles on financial state- the Department of Justice in white-collar criminal ment frauds, corporate investigations, misap- matters, and testified in a televised murder trial. propriations, public corruption, and a host of other occupational frauds.5 The American Institute of Certified Public Accountants (“AICPA”) (the governing body of pro- In fact, the Association of Certified Fraud fessional accountancy in the United States) defines Examiners (“ACFE”) reported in its 2018 Report to forensic accounting as “the application of special- the Nations: Global Study on Occupational Fraud ized knowledge and investigative skills possessed and Abuse, that the total global fraud loss could by CPAs to collect, analyze, and evaluate evidential be as high as $4 trillion U.S. dollars (or roughly matter, and to interpret and communicate find- 5 percent of gross world product) per year.6 And ings in the courtroom, boardroom or other legal or these numbers do not appear to be decreasing even administrative venue.”4 with the allocation of additional resources at the corporate level and the passing of 17 years since the Professional accountants, mostly CPAs, conduct Sarbanes-Oxley Act (“SOX”)7 became law. forensic accounting engagements. A subcategory

www .willamette .com INSIGHTS • AUTUMN 2019 3 This discussion makes no attempt to solve the Examples of fraud examinations include the fol- problems of corporate fraud and abuse. Rather, this lowing: discussion addresses what to do once you discover n Corruption, including conflicts of interest, an issue (or are retained to investigate an issue) bribery, illegal gratuities, and economic from the perspective of the forensic analyst. extortion This discussion identifies the best practices n Asset misappropriation, including theft, for conducting forensic accounting investigations, fraudulent disbursements, , and including the following: other assets n Beginning the engagement n fraud9 n Planning and communications during the engagement According to the ACFE, fraud examinations can n Executing the engagement also address other organizational objectives, such as 10 n Reporting findings the following: n Identifying improper conduct When executed properly, a forensic - n Identifying the persons responsible for ing investigation can accomplish several important improper conduct tasks. It may assist triers of fact along with financial n Stopping fraud victims. It may also root out corruption in govern- n Sending a message throughout the organiza- mental and business organizations. And, finally, it tion that fraud will not be tolerated may bring criminals to justice. n Determining the extent of political liabili- ties of losses that might exist n Helping to facilitate the recovery of losses Where to Start n Stopping future losses In most forensic engagements, an interested party n Mitigating other potential consequences wants an answer to two principal questions: n Strengthening internal control weaknesses n What happened? n Who is responsible? Types of Engagements And in many cases, the party looks to a forensic There are infinite types of forensic accounting specialist to assist in answering those questions. In engagements. These assignments are primarily clas- my experience, forensic accounting assignments sified as: generally begin in one of two ways. 1. accounting or nonaccounting, First, there is an issue in litigation that requires analysis. Examples of these types of assignment 2. litigation or nonlitigation, or include the following: 3. fraud or nonfraud. n Measurement of economic damages and lost profits While there is certainly overlap within the n of business interests, intellectual groups, the primary reason for the classification property, real estate, intangible assets, or system is to make certain that the assembled profes- other assets sional team is both qualified and has the specialized knowledge to complete the assignment. n Transfer pricing For example, if the assignment relates to finan- n Intellectual property infringement cial statement fraud, the team is going to require accounting expertise. And because of the fraud Second, a governmental agency or business component, the team will also require someone with has a suspicion (or in some cases a confirma- experience interviewing financial personnel. tion) that some type of fraud has occurred in the Finally, the analyst should assume that any organization. Forensic accountants or analysts are assignment may end in litigation and, therefore, frequently retained to assist in the investigation should consider whether he would make a credible of such frauds. In some instances, the analyst will witness in the case. If the answer to that question is be retained directly by the organization, while in no, the analyst should either reject the assignment other instances outside legal counsel retains the or add someone to the team who would serve as a specialists.8 potential .

4 INSIGHTS • AUTUMN 2019 www .willamette .com rofessional tandards Services Practice Aid 04-1: “Engagement Letters for P S Litigation Services.” The analyst should also consider which (if any) As soon as practicable, the analyst should devel- professional standards may apply to the assignment. op a scope of work for the assignment. At the Credentialed accountants, valuation analysts, and beginning of the assignment, a high-level work plan fraud professionals may belong to different profes- should suffice. This plan may be expanded and sional organizations with different sets of profes- refined as additional facts are discovered and analy- sional standards. CPAs should consider the following ses performed. processional standards: It is important to keep outside legal counsel n AICPA Code of Professional Conduct apprised (assuming the client heeded your advice n AICPA Statement on Standards of to hire outside counsel) of the progress of your Consulting Services work and informed of any changes in scope. This n AICPA Statement on Standards for communication should help create a team environ- Attestation Services ment and ease tensions when the invoices for your n AICPA Statement on Standards for Forensic services arrive. Services No. 111 Finally, the analyst should not allow the client or outside counsel to control the scope of the assign- ment and at the same time request a report of “no The valuation profession often follows the findings.” If you find yourself in this predicament, Uniform Standards of Professional Appraisal you should consider resigning from the assignment. Practice, which includes both ethical and devel- opment/reporting standards for various valuation Taking the time to understand the appropriate disciplines. Certified Fraud Examiners comply with professional standards, properly staff the assign- the Association of Certified Fraud Examiners Code ment, investigate potential conflicts, prepare effec- of Professional Ethics and Code of Professional tive engagement letters, develop efficient work Standards. It is the analyst’s responsibility to know plans, and communicate with outside counsel will which standards apply to any assignment. greatly increase the chances of conducting a suc- cessful forensic accounting assignment.

Other Considerations12 Practical Procedures Prior to accepting any assignment, the analyst More often than not, one of the first questions out of should make certain that he (or his firm) has no the client’s mouth is going to be, “How much is this conflicts of interest. Generally, the analyst should going to ?” And while estimating that number examine the company, key executives, and any is very difficult in litigation settings, it is virtually potential targets for conflicts. impossible in fraud investigations. Why? A couple The AICPA provides guidance on conflicts in of reasons. the Forensic and Valuation Services Section Special First, you do not know how deep the rabbit hole Report 08-1: “Independence and Integrity and goes. What starts with an anonymous tip13 from one Objectivity in Performing Forensic and Valuation employee about another employee may turn into Services.” collusion with multiple employees. All of which will It is always a best practice to have an engage- then need to be investigated. And collusion creates ment letter with the client (preferably with the other more significant problems. It overrides inter- outside legal counsel representing the organization). nal controls, systems access, and ordinarily solid It is also important, in general terms, to outline the process and procedures. nature and professional standards governing the Additionally, if the assignment is with a public assignment. If these issues are not addressed, the company and the fraud involves an employee that client may incorrectly assume that the forensic the outside auditors relied upon in conducting the accountant is providing some type of assurance or internal control review, the independent (such as an “audit” or a “review”). Unless such auditors are likely going to be concerned about the assurances are being provided, the analyst (even reliability of their audit and wish to conduct some if a nonaccountant) should avoid using attestation type of shadow investigation. Such an investigation terms like audit and review in engagement letters, is going to require periodic reporting, and additional working papers, and client correspondence. time, from the forensic accountant. The AICPA provides additional guidance on I once investigated a large manufacturing con- engagement letters in the Forensic and Valuation glomerate related to a financial statement fraud.

www .willamette .com INSIGHTS • AUTUMN 2019 5 Ultimately, I determined that the CFO conspired And even with computer tools, SQL databases, and with the division heads to falsify account records in structured data and computer analytics profession- order to maximize bonus pools. Collusion between als doing the work, this analysis takes time and is senior employees makes fraud investigations diffi- expensive. cult to solve and costly to complete. I once interviewed a woman who we believed was Second, people are going to lie to you and that will skimming money from her employer. She denied slow you down. I led investigations where employ- the allegations. I then reviewed her company emails ees lied to cover up office affairs, where assistants along with her voice mail messages, text messages, lied to cover for their bosses, and controllers lied and group chats from her company server. She to cover for their business units. The most effective obviously did not know that the company saved way to combat this lying is to analyze the evidence the metadata from the instant messages she sent and the data and to effectively interview employees. through her work computer. Those messages not This is because putting a piece of paper in front of only showed how she was skimming the money, but someone that refutes their lie is the quickest way to also showed she was spending a good bit of it on her get to the truth. Once the interviewee realizes you boss, with whom she was also having an affair. The have done your due diligence, you will receive much company terminated both employees and referred more truthful answers. the case to local law enforcement for prosecution. Several years ago, I interviewed the corporate My best recommendation to manage the client’s controller for a major division of a Fortune 500 expectations and engagement is to utilize a company. The company received a whistle-blower phased approach. I generally create an approach complaint from their internal fraud hotline stating memorandum (or work plan) at the beginning of each that the division was fraudulently overstating its forensic investigation. At a high level, the memoran- operating results. dum outlines the steps of the investigation and the On the morning of day one of the investigation, estimated cost of each step. At the end of every week, the controller sat in the conference room with me, I revise the memorandum, update the estimates, and lined with the leather-bound volumes of internal circulate the updates to counsel and/or the client. controls and process and procedures documents This process keeps everyone on the same page and required under SOX, and told me his books were minimizes any “sticker shock” for your billings. perfectly clean and accurate. On the afternoon of day three, after several interviews, the analysis of several hundred transac- What’s Next? tions, and a list of 30 or so written questions about certain end of the month journal entries, the same Preliminary Assessment controller walked into the same conference room and confessed to the fraud. Because of his title and It is generally appropriate to conduct some type his longevity in the organization, he was able to of preliminary assessment at the beginning of override any of the existing internal controls. The any forensics investigation. This assessment may SOX documents were worthless. include the following: When I asked him why he was confessing, he 1. Gaining an understanding of internal con- confided to me that he knew once I started ask- trols and processes ing the right questions and not accepting his first 2. Performing an analysis of records answers, that I was going to eventually find the 3. Conducting some preliminary discussions fraud—it was only a matter of how long it would with executives who are not a target14 of the take. And he said he could not sleep at night. Be investigation15 consistent and skeptical and you will eventually find the answers. In many instances, the assessment requires the Finally, electronic record keeping has made interaction of the forensic analyst with employees fraud investigations infinitely more complicated. of the accounting and finance department of the Twenty years ago, analysts might look through the company. Care should be taken during these inter- file cabinets located in an executive’s office or the actions as the accounting and finance departments office of his secretary. Today, analysts have file serv- are often the targets of the investigation—and news ers, email systems, shared drives, text messages, travels fast even in very large organizations. In this and chat rooms. type of environment, I will often introduce myself as And many businesses retain everything—for- a member of the independent audit team (with prior ever! So, all of it should be analyzed for relevancy. notification of counsel, of course).

6 INSIGHTS • AUTUMN 2019 www .willamette .com The AICPA provides the following questions that may assist with the assessment:16 n What data are available? Understanding (1) the type of financial information that is available and (2) the related time periods covered will help the analyst assess the level of work and the cost required to gather and analyze the information. n Are the data available in electronic format? Electronic data will make analysis more efficient and will provide for more compre- hensible procedures. It is also helpful to request data that are in a proper format and compatible with any tools that the forensic accountant will use to perform an analysis. content. It is permissible to quote the interviewee Including a specimen document request let- for particularly important details. ter may facilitate the accurate collection of In the event the analyst takes possession of electronic data. original documents, it is important that the proper n Will the information be complete? chain of custody be maintained to ensure preserva- Incomplete information will limit the prac- tion of the evidence.17 This is particularly important titioner’s ability to produce accurate con- for documents with original signatures or items like clusions. The time spent to fill in incom- cancelled checks, computer hard drives, and the like. plete data will also affect the cost of the investigation. Communications n Are there nonfinancial types of informa- Communication should be directed to your client, tion that could help with the investigation? be that outside legal counsel or company manage- Other types of information, such as phone ment. In some cases, the client may be the com- records, email, and building access logs pany’s board of directors or audit committee. As could assist the forensic accountant with noted above, it is always preferable for the client the assignment. It is important to inquire in forensic investigations to be legal counsel. That about what types of nonfinancial informa- way if the analyst determines there is collusion or tion are available. management involvement in the fraud, the analyst has an unbiased communication partner. If com- Subsequent to the preliminary assessment, I will pany management is the client, it is advisable to update the approach memorandum and consider have management involve the board of directors any necessary changes to the team structure. Team or audit committee early in the assignment for the changes are generally because of complex account- same reasons. ing issues, specific industry expertise requirements, Finally, at some point in the investigation, the and electronic data issues. analyst and the client will need to determine how to communicate the conclusions from the assignment. Working Papers This generally takes the form of a written report or an oral presentation. There are pros and cons It is imperative that the analyst retain a complete to each method. Written reports take time and are set of working papers prepared during the investi- expensive to write but provide high levels of detail. gation. That is not to say that all notes, schedules, Clients usually prefer written reports if they wish and other documents should be retained. The to refer the case to law enforcement or plan to seek analyst should determine whether notes or other reimbursement of costs from their carrier. materials are relevant to the investigation. If so, Oral reports can be prepared quickly, but only offer the notes should be formed into a memorandum summary information. Clients generally prefer oral or other document. If not, the materials should be reports if they are concerned with legal privilege discarded. and discovery issues—if there is no report, no report This is especially important for interview memo- can be produced. I have clients that requested oral randums. The purpose of the interview memoran- presentations, but written reports for recommenda- dum is not to transcribe everything said during the tions for internal controls as they wished to share interview, but rather to summarize the relevant the latter with their outside auditors.

www .willamette .com INSIGHTS • AUTUMN 2019 7 Executing the Engagement n Will outside legal counsel (for the company) attend the interview? If so, will they pro- Subsequent to the approval of the work plans by the vide Upjohn19 warnings, background of the client, the analyst should begin executing the plan. investigation, and or other privilege instruc- While every forensic accounting assignment will tions? If not, will the analyst perform this vary, there are a couple of execution categories that task? should remain the same. n The order of the interviews. Generally, you First, you will gather the relevant hard copy should interview the whistle-blower first and electronic documents. In some cases, the (if applicable) and the subject of the inves- hard copy documents may be voluminous. If so, tigation last. It is also a best practice to the engagement team should either keep the cop- interview lower-level employees first. This ies of the documents off site or work with the should provide a solid base of knowledge for client to obtain means to limit access to employ- the interview of senior personnel. ees. Electronic documents (emails, spreadsheets, n Site of the interviews. If you are interview- shared drives, etc.) are generally processed and ing an internal whistle-blower, it is better loaded into a review environment tool. The pro- to conduct the interview at an off-site loca- cessing of documents is complex and outside the tion. If on site, you will need a quiet and scope of this discussion. private location to conduct interviews so Second, depending on the type of assignment, that the interviewee will feel comfortable. the next step may involve the use of analytical pro- n What if the interviewee requests legal coun- cedures. These procedures may identify trends or sel? Generally, this means an immediate unusual transactions that would assist the analyst. halt to the interview until such time that Some examples of analytical procedures include the interviewee can discuss options with his or 18 following: her counsel. n Comparison of company financial data ver- sus operational data, such as production Generally, the interviewer should have one levels, number of employees, and square additional person in attendance to take notes dur- footage ing the interview. I find it best to place the person n Comparison of current company data ver- taking notes slightly out of the direct eyesight of sus historical periods the interviewee. This keeps the interviewee’s focus n Comparison of actual financial results ver- on the interviewer and not the notes that are being sus company , forecasts, or projec- taken. tions Interview memorandums should be prepared as n Comparison of company data versus indus- quickly as possible after the interviews. This keeps try and competitor data the details of the interview fresh in your mind and n Comparison of financial statement informa- significantly improves the quality of the memoran- tion with income tax returns dums. I have on occasion been asked by an inter- viewee for a copy of the interview memorandum. n Comparison of financial statements submit- I have always refused this request on the basis the ted to different parties or regulators document is legally privileged and a work product of n Comparison of subsets of company data the investigation. versus other subsets of company data (i.e., comparison of data on a disaggregated basis such as by division, product, location, or Practical Procedures employee) Conducting interviews is, by far, the most fun part of n Analyses of financial data in the context of forensic investigations. But to be fun, the interview external events (i.e., economic, political, must be successful and the only way to a successful etc.) or circumstances interview is through preparation. You need to walk into the interview knowing more than the interview- n Vertical, horizontal, financial statement, ee thinks you know. Do your homework and prepare and analyses an outline. But perhaps more importantly, listen to what the interviewee is telling you. Third, the analyst should begin scheduling inter- I have seen interviews where the interviewer views as quickly as practicable. Prior to any inter- was so intent on his next question that he did not view, the analyst should consider the following hear the response to the previous question. Be issues: flexible enough to deviate from your outline when

8 INSIGHTS • AUTUMN 2019 www .willamette .com the interviewee takes you in a fruitful direction, but return if you are not getting anywhere. If you feel like the interviewee is not being truth- ful, ask the question again and again but in slightly different ways. Return to topics and see if you get slightly different responses. Many times your per- sistence will pay off and you will get to the truth. And your last question should always be, “Is there anything else you would like to tell me?” You may be surprised at some of the responses you get. I once interviewed a woman who was the office manager of a large construction company. An inter- nal whistle-blower alleged that several construction executives at the company were paying political contributions to select local politicians and then receiving reimbursements for those payments from company funds. The reimbursements were alleged before undertaking these procedures (especially if to have been categorized as travel and other expens- the procedures were not part of your original work es in the company’s accounting system. plan). When I interviewed the whistle-blower, she told me that the office manager knew “everything that happened in this company” and that she was “close Reporting Findings friends” with the executives in question. So, I spent Documenting your findings is important and may several days going through the reports and be done in a variety of ways—both written and pulled every expense for the past three years catego- oral reports directly to the client are common. rized as “travel” or “other” and without supporting Additionally, the analyst may be asked to submit a documentation. report to a court or a law enforcement agency. Any I then scheduled the interview with the office investigative report should contain the following manager. I explained to her why I was there basic elements:20 and outlined the whistle-blower’s allegations. She n Identify the client denied any knowledge of the allegations. I spent n Include the analyst’s qualifications and the next several hours going through the expense background reports—I would cover 10 and then ask, “Do you n Describe the predication21 know anything about these.” She would deny knowledge. I would cover 10 more then add, n State in broad terms what the analyst was “Someone from an earlier interview said you were asked to do knowledgeable about this process.” She would n Describe the engagement scope, including deny knowledge. the time period examined At some point, she stopped me and said, “How n Include mention of any restriction as to long are we going to be here?” and I respond- distribution and use of the report ed, “Until we find the truth.” After several more n Identify the professional standards under examples, she paused and explained how the fraud which the work was conducted worked. She did not participate, but knew the n Identify exclusions in the reliance on the details. She was tired of answering questions and analyst’s report just wanted someone to know that she was not responsible for the fraud. In this case, persistence n State that the work should not be relied on paid off. to detect fraud Finally, the analyst may perform additional sub- n Include a list of the documents reviewed stantive procedures as necessary. These procedures and relied upon during the investigation may include things like observations of internal con- n Include the names, titles/organizations, and trol systems, asset tracing, analysis of access logs, dates of interviewees examination of metadata from electronic media, n Include the procedures performed and the selection of journal entries from the general , technical pronouncements relied upon and analysis of unusual or related party transac- n Describe the observations and identify the tions. It is wise to seek consensus with the client findings

www .willamette .com INSIGHTS • AUTUMN 2019 9 Finally, the analyst should not state definitive 7. SOX required corporate executives to certify conclusions of fraud. You may conclude there were the financial statements under penalty of pros- indications of fraud and you may even state that ecution. Additionally, companies were required to publish details of their internal accounting the subject of the investigation confessed to certain controls. The thought at the time was that these allegations, but the act of fraud is a legal conclusion processes would significantly decrease corporate and should be reserved for courts, judges, arbitra- fraud events. As of this writing, the success of tors, and juries. SOX is debatable. 8. I always recommend the retention of outside legal counsel in fraud examinations and that Summary and Conclusion outside legal counsel retain the specialist. This arrangement allows for confidentiality and legal Taking the time to properly plan and organize a foren- privilege of the investigation until such time the sic investigation will produce more efficient investiga- company wishes to disclose any findings to gov- tions and cost savings to your clients. This process ernmental or other regulatory agencies. involves communicating initial cost estimates, chang- 9. ACFE Report to the Nations, 11. Summarized from es in scope, and tentative findings with the client. Occupational Fraud and Abuse Classification System (the Fraud Tree). Other issues, especially the pros and cons of the 10. ACFE 2016 Fraud Examiners Manual, 3.101. various types of reports, should be discussed early 11. In June 2019, the AICPA issued SSFS 1, which in the engagement. If the client either intends to provides authoritative guidance for AICPA mem- seek reimbursement for the costs of the fraud and bers providing litigation and investigative servic- investigation for its insurance carrier or wishes to es. The statement defines litigation and investiga- refer the matter to a law enforcement agency for tion for accounting purposes, outlines key consid- prosecution, the analyst should prepare a written erations for client and provider relationships, and establishes boundaries on the services members report. If these issues are not important to the cli- can provide. The new standards take effect for ent, but there are concerns about confidentiality or new engagements accepted on or after January 1, legal privilege, an oral presentation may suffice. 2020. Early adoption is permitted. Finally, the success to the investigation very well 12. Summarized from AICPA Forensic and Valuation may depend on the forensic interviews. Analysts Section, “How to Organize a Forensic Accounting Investigation.” should thoroughly prepare for the interviews and 13. According to the ACFE 2014 Report to the walk in knowing more than the interviewee expects. Nations, more than 40 percent of all inter- Clients should expect that the analyst has experi- nal investigations originate with a tip from an ence with effective interview techniques and can employee, customer, or vendor. handle deceptive or confrontational interviewees. 14. Keep in mind potential collusion issues as dis- cussed above. Notes: 15. AICPA Forensic and Valuation Section, “How to Organize a Forensic Accounting Investigation,” 6. 1. CSI: Investigation is a proce- dural forensics crime drama television series 16. Ibid. which ran on CBS from October 2000 through 17. Ibid., 7. September 2015. 18. Ibid., 13. 2. A special master is appointed by a court to carry 19. Informally known as a corporate Miranda warn- out some sort of action on its behalf. Found at ing. Notifies an employee being interviewed that https://www.law.cornell.edu/wex/special_master. the legal counsel for the investigation represents 3. A Ponzi scheme is a fraudulent investing scam the company and NOT the employee. promising high rates of return with little risk to 20. AICPA Forensic and Valuation Section, “How to investors. The Ponzi scheme generates returns Organize a Forensic Accounting Investigation,” for early investors by acquiring new investors. 17. Found at https://www.investopedia.com/terms/p/ 21. “Predication” is the totality of circumstanc- ponzischeme.asp. es that would lead a reasonable, profession- 4. AICPA Practice Aid 10-1, “Serving as an Expert ally trained, and prudent individual to believe Witness or Consultant.” a fraud has occurred, is occurring, and/or will 5. The Association of Certified Fraud Examiners occur. ACFE 2016 Fraud defines occupational fraud as the use of one’s Examiners Manual, 3.105. occupation for personal enrichment through the deliberate misuse or misapplication of the employing organization’s resources or assets. 6. ACFE Report to the Nations: 2018 Global Study Dean Driskell is a managing direc- on Occupational Fraud and Abuse, 8. The tor in our Atlanta office. Dean can be report may be downloaded for free at https:// reached at (404) 475-2324 or at dean. www.acfe.com/report-to-the-nations/2018/. [email protected].

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