Opinion & Analysis

Transferring the Needle on Fraud

James Tebbs and Kassem Younes, Senior Managing Administrators at Ankura, take an in-depth have a look at fraud prevention on this article, presenting an intuitive ‘cycle’ that any organisation can use to pressure trade in its resilience towards fraud.

Fraud – it’s a scorching subject.” No longer an overly inspiring or unique headline.

At any time, and in nearly anyplace, the anti-fraud schedule may also be heard connected to world crises, nationwide agendas, company imperatives or just private safety – sure, it impacts us all. The COVID-19 pandemic: fraud is on the upward push. Larger use of virtual instruments: fraud is on the upward push. Running from house: fraud is on the upward push.

What are we to make of this if truth be told? Indisputably there’s some ‘numbing’ impact right here. We turn into so used to listening to that there’s a drawback that the danger turns into a background attention, or worse, the price of fraud turns into an operational danger quite than one thing we will truly get our tooth into.

This poses the most obvious query: for the entire technological building, development of methods, coaching systems, fraud consciousness weeks, regulatory fines and the transparent prices of those actions, how a lot fraud has if truth be told been avoided, detected, or prosecuted above what would possibly another way had been the case? How do you calculate the real ‘price’ of those actions to the person, organisation, state or world schedule?

It is a query that has plagued anti-fraud and certainly anti-financial crime[1] practitioners and menace pros for years. Believe additionally the similar query of the prevention of cash laundering, terrorism financing or proliferation financing continuously levied of monetary establishments. The ever-repeated word ‘value of compliance’ is balanced with the calculation of any relief in exact criminality coming up particularly from those preventive and detective actions. While we can’t supply a quantified solution, we firmly imagine that anti-fraud is a vital value-adding job, and it begins on the organisational point.

We turn into so used to listening to that there’s a drawback that the danger turns into a background attention

How are organisations transferring to deal with this?

In a prior article on this newsletter, our colleague Peter Glanville supplied readability at the new panorama of fraud investigation[2] and the collaborative efforts of criminal pros and investigators. Investigation is a basic – and extremely efficient – software within the prevention of fraud. It actively demonstrates 0 tolerance for incidents of fraud, each inside and exterior, and is the ‘tooth’ of any anti-fraud program. It sends a transparent message that if wrongdoing is suspected, it is going to be adopted up completely and professionally and handled accordingly.

On this article we discover the sensible steps organisations will have to take to forestall fraud from going down. Our enjoy is that any organisation, of any dimension and price range, can discover a answer via those steps and will recognise that there truly is a receive advantages to this, and it could be more than you suppose.

The cycle beneath makes an attempt to turn how this steady loop may well be seen in observe:

Cyclical fraud prevention diagram.

Working out the cycle

The primary level of word is that fraud prevention is a cycle. It will have to no longer be seen as a sequence of impartial actions. To focus on this, check with the ACFE and COSO paintings on Fraud Possibility Control, together with the Anti-Fraud Playbook[3], which give precious insights connected to the COSO framework, a founding foundation for inside controls.

Lately, the tendency to concentrate on compliance actions during the lens of a regulatory crucial (together with mitigating the danger of a advantageous) has created ‘swimming pools’ of job which aren’t all the time effectively synchronised. For instance, believe the ‘Governance’ element as ‘tone of the highest’ – in our enjoy there’s continuously a disconnect between the senior executives/Board Administrators concerned or knowledgeable at this level, and the tracking (together with MI) and reporting that follows later. Possession on the most sensible is very important.

Making sure the hyperlink between anti-fraud steps no longer simplest supplies a greater view of total menace however facilitates extra environment friendly and efficient use of sources.

What will have to an organisation prioritise in its anti-fraud technique?

Every step of the cycle is an inherent element of the total technique, and the tactic fails with out every step enjoying its section.

Governance and Possibility Overview

Environment the anti-fraud schedule on the outset is essential. The Board is answerable for figuring out company technique and menace urge for food, and the anti-fraud schedule stems from those business imperatives. As soon as the danger urge for food is about, a menace review is key in figuring out the way to construct efficient controls. In the end, how can any machine of regulate be well-designed if it’s not knowledgeable of the hazards it’s meant to mitigate?

To behavior an efficient menace review, have interaction the industry without delay and steer clear of enterprise the method as an educational compliance workout. Attempt to put your self within the sneakers of a would-be legal, and even believe attractive probably the most new breed of specialists who’ve themselves up to now been fraudsters, for actual perception.

Controls Design

We continuously see instances of organisation controls evolved ‘after the truth’ – this is with none right kind review of menace. The danger review does no longer need to be pricey and overly time-consuming, but it surely drives well-designed and correctly centered controls which carry much-needed potency and effectiveness.

Every step of the cycle is an inherent element of the total technique, and the tactic fails with out every step enjoying its section.

A big quantity of literature is publicly to be had to fortify this[4], however take into account there is not any such factor as a fraud regulate, simplest controls. Segregation of tasks, efficient passwords, authority limits, approvals, impartial critiques and different regulate teams save you mistakes and stay actions on price range and on track, and so they additionally occur to forestall fraud. Don’t permit this workout to overshadow broader operational controls.

Tracking and Detection

Those constitute the actions of the controls in observe. Correct KPIs and reporting information will have to be generated to assist the ones charged with governance to decide whether or not the controls are efficient and to spot early when a possible fraud or different anomaly could also be happening in order that those may also be right away adopted up.

If designed as it should be, this data will have to be totally aligned with business targets and supply greater than fraud tracking by myself.


Most often controlled through an impartial group inside both Interior Audit or some other menace serve as, and in lots of instances with fortify from exterior investigators and criminal suggest, thorough investigation supplies a wealth of data on particular person instances and the crystallisation of perceived dangers, continuously permitting senior leaders to peer their organisations from a brand new viewpoint.

Advice and Reporting

No investigation may also be whole with out detailed and transparent reporting and transparent suggestions. All the time believe two key outputs: what controls have failed (or been circumvented) in permitting this fraud to occur, and the place else within the organisation the similar scheme could be imaginable. Actively answering either one of those questions can then whole the ‘cycle’ and feed again into enhanced controls design and tracking.

The above steps truly do practice to any industry, of any dimension. The cycle is designed to not call for extra sources, however to make certain that sources are successfully allotted and targeted at the maximum related actions. As highlighted, while that is introduced via an anti-fraud lens, the effects will have to supply way more business price.

What are we able to be expecting to peer one day?

As a sensible colleague as soon as identified, there was no ‘outbreak of honesty’. The human psychology of fraud is definitely documented and can most probably no longer trade. Our recommendation due to this fact is obvious – center of attention in your menace review and concentrate on the cycle.

There are, alternatively, traits in anti-fraud which can be bearing fruit. Most likely probably the greatest of those, outdoor of particular person organisations, is the rising tendency for cooperation among private and non-private sector organisations. Examples of this come with:

  • Within the Kingdom of Saudi Arabia, the central financial institution has lately inaugurated its Joint Operations Centre to struggle economic fraud, involving all Saudi banks, tasked with following up and tracking instances of monetary fraud[5].
  • Within the UAE, the Monetary Intelligence Unit has revealed helpful steerage on fraud typologies and tendencies which gives particular data organisations can incorporate into their very own menace checks.

Those examples display the willingness and talent of presidency our bodies to interact with the personal sector to struggle fraud. While additional cooperation is unquestionably obligatory, those tasks display a state- and global-level dedication to operating in combination to struggle fraud.


What will have to we take from this? While fraud does proceed, and new assault vectors increase each day, anti-fraud actions may also be environment friendly and efficient and reach extra than simply anti-fraud on the organisational point. With the correct collaboration at an organisation and state-level, transferring the needle on fraud may not be to this point from our seize.

© Copyright 2022. The perspectives expressed herein are the ones of the creator(s) and no longer essentially the perspectives of Ankura Consulting Team, LLC., its control, its subsidiaries, its associates, or its different pros. Ankura isn’t a legislation company and can’t supply criminal recommendation.


James Tebbs

Senior Managing Spouse, Dubai

T: +971 (0) 4 381 9000 Major


Kassem Younes

Senior Managing Director, Riyadh

T: +966 11 261 1522


James Tebbs is a Senior Managing Director at Ankura and leads the company’s menace, forensics and compliance group within the Center East. He has over twenty years’ enjoy in fraud prevention, detection and investigation, together with 10 years within the Center East.

Kassem Younes is a Senior Managing Director at Ankura in Riyadh. Kassem’s enjoy covers various instances together with corruption, cash laundering and asset misappropriation and he has gave the impression on a number of events as knowledgeable witness.

Ankura is an impartial world professional services and products and advisory company that delivers services and products and end-to-end answers to assist shoppers at important inflection issues associated with warfare, disaster, efficiency, menace, technique and transformation.


[1] For the needs of this text, we check with anti-financial crime as a narrower thought associated with AML, CFT, Sanctions compliance and the financing of proliferation.

[2] What’s the Reshaped Panorama of Fraud Investigation? (lawyer-monthly.com)

[3] https://www.acfe.com/fraud-resources/fraud-risk-tools—coso

[4] Together with the ACFE/COSO anti-fraud framework referenced above

[5] Saudi Central Financial institution governor launches operations heart to struggle economic fraud (arabnews.com)

Supply By way of https://www.lawyer-monthly.com/2022/11/moving-the-needle-on-fraud/