Senior Management, Audit Committees and Regulators expect, if not require, fact-based and objective reporting on investigation findings, when a system or control override, or weakness, may have contributed to a fraud (or other loss) event.
A Fraud Response Plan usually includes guidance on minimum requirements for investigation planning. Senior management oversight is key to ensuring clarity of investigation scope and objectives, as well as the 'who by', 'what focus' and how an investigation is undertaken; and the mechanics for ensuring that senior management is appraised on progress.
Poor planning can contribute to evidence loss or damage, reputation risk and increased regulatory concern:
Appropriately skilled resource with the requisite technical capability should be used - suspected insider involvement or complicity may benefit from independent review and challenge of the facts
Consideration should be afforded to obtaining legal advice and specialist support at the outset of investigation planning
Try to minimise business disruption whilst securing evidence and identifying opportunities for: (i) identifying the person(s) responsible; (ii) improving internal controls; and (iii) obtaining recoveries and/or tracing misappropriated assets
When investigating suspected fraud:
Identify relevant sources of intelligence/evidence (e.g. from people, documents, data and systems)
Assess/evaluate information identified from sources to inform any change required in investigation scope and objectives
Be prepared to employ specialist resource, tools or techniques, where necessary, in order to make progress
Ensure objectivity and experience-based consideration of controls risk assessment
Produce a report of findings and recommendations, the content of which should reflect relevant standards of proof (e.g. for use in disciplinary, regulatory, civil or criminal proceedings)
How we can help you
FCRM conducts UK and international fraud and asset tracing investigations.
On international assignments (where practicable) we use experienced investigators with knowledge of local language, culture and business practice.
We deliver robust reviews and investigations, often in challenging circumstances. Reports include fact-based findings, objective commentary on internal systems and where required, practical recommendations to improve/enhance fraud controls.