Time for a comprehensive fraud risk policy?

Given human nature, companies large and small will always face the risk of fraud by employees. Sarbanes Oxley can never be completely successful. One consultant thinks you ought to map out a strategy toward fraud that meets the following objectives: prevention, detection and response. Now most companies have codes of conduct and such. But not all have built in appropriate policies, especially at small companies. Some ideas are just common sense. Small companies that will have to comply with 404 are now facing such issues as segregating financial and accounting duties, duplicating sensitive tasks, reconciling bank accounts, requiring annual vacations for employees and the likes. Here are some tips.