Anti-Fraud Programme Framework
A framework for an organization-wide anti-fraud programme aligned with ACFE and IIA guidance.
Components
- Tone from the top. Visible commitment to integrity and zero tolerance for fraud.
- Code of conduct and policies. Clear expectations, conflicts of interest and gifts/hospitality rules.
- Fraud risk assessment. Identification of schemes and residual risk (see companion framework).
- Preventive controls. Segregation of duties, approvals, system access and fraud-aware design.
- Detective controls. Continuous monitoring, analytics and management review.
- Reporting channel. A confidential, trusted whistleblower mechanism.
- Investigation capability. Independent, evidenced response using ACFE methodologies.
- Response and remediation. Disciplinary action, recovery and root-cause remediation.
- Training and awareness. Tailored to roles and fraud schemes.
Governance and assurance
- The audit committee oversees the programme
- Internal audit provides assurance over design and operation
- Results and incidents are reported to the board
Effectiveness indicators
- Reporting channel usage and case outcomes
- Time to detection and time to resolution
- Repeat incidents by type
A programme is only as strong as its weakest component.