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Fraud Risk FrameworksACFE

Anti-Fraud Programme Framework

A framework for an organization-wide anti-fraud programme aligned with ACFE and IIA guidance.

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.

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