CRI Group™ and its ABAC™ Center of Excellence were featured in Financier Worldwide’s InDepth Feature: Corporate fraud and corruption 2021. In this edition, CRI Group’s CEO Zafar Anjum and ABAC Group’s Scheme Manager Huma Khalid talk about how corporate fraud and corruption affect businesses not only in the UK and UAE, but across the globe, and provide solutions and insights for businesses to become better protected from corporate fraud, bribery and corruption.

Q. To What Extent have you seen a Notable Rise in the Level of Corporate Fraud, Bribery and Corruption Uncovered in the UAE?

A. The United Arab Emirates (UAE) remains the least corrupt country in the Middle East and North Africa region. It was perhaps fitting that the United Nations (UN) held its anti-corruption conference in the UAE just over a year ago. At the conference, delegates drafted anti-corruption resolutions and discussed asset recovery, international cooperation, and other topics in preparation for an upcoming special session of the UN General Assembly against corruption. Of course, there is still much work to be done. Fraud, bribery and money laundering are still problems in the UAE that require a united focus to overcome. Of special concern is the real estate sector, which some have called a haven for stashing and laundering cash. In some cases, these funds are linked to terrorist financing, raising the alarm beyond just the balance sheet for typical financial or corporate fraud.

Q. Have there been any Legal and Regulatory Changes Implemented in the UAE Designed to Combat Fraud and Corruption? What Penalties do Companies Face for Failure to Comply?

A. The recent Anti-Commercial Fraud Law in the UAE strengthened rules around counterfeiting and intellectual property (IP) theft, among other areas. In addition, lawmakers and regulators are applying an anti-fraud focus to other laws. A perfect example is the UAE’s Insolvency Law 2020. The Ministry of Finance announced that penalties will be imposed on those who fraudulently abuse the law. This could include making a fake claim or a sham debt against a debtor or illegally increasing a debt amount. Such offences are punishable by jail time and fines. An awareness campaign by the UAE Banks Federation (UBF), the Central Bank of the UAE (CBUAE), Abu Dhabi Police, and Dubai Police was the first such collaboration in the UAE and it comes as both corporate and consumer fraud have increased. Companies are expected to protect their stakeholders’ investments, and failure to do so can lead to regulatory and legal punishments.

Q. In your Opinion, do Regulators in the UAE have Sufficient Resources to Enforce the law in this area? Are they Making Inroads?

A. There are at least two daunting tasks facing regulators in the UAE at present: detecting and preventing money laundering and stemming the growing threat of cyber crime. While these problems are not unique to the UAE, they do require significant investment and increased investigation and enforcement efforts. Recent reports allege that illicit funds flow through ‘free trade zones’ and into real estate deals, such as luxurious properties in Dubai and other locations. The laws are in place to punish such crimes, but more inroads will need to be made to bring this under control in a country that largely succeeds at fighting fraud in other areas. Cyber crime is also a constant challenge that has been exacerbated by the COVID-19 pandemic. Many fraudsters have sought to take advantage of companies having to transition to different employment models, such as remote working. Fraud fighters are working hard to stay ahead of the curve in this regard.

Q. If a Company Finds itself Subject to a Government Investigation or Dawn Raid, How Should it Respond?

A. If a company finds itself under investigation, one of the first things it must do is mandate down the chain of command that employees cooperate fully with investigators. Any efforts to the contrary may be considered obstruction, and lead to more punishments or a higher likelihood of penalties at the end. In contrast, engaging in a good-faith effort to assist an investigation may weigh in the company’s favour.

Questions will arise, such as: Was this a surprise? What are the facts of the case? How did this occur? Legal counsel must be engaged immediately, but it is also important to speak with compliance officers, risk management, executives and the board in a transparent way to help the company move forward. Communicate a zero-tolerance policy toward fraud, and if employees are proven to have engaged in such behaviour, they should be terminated and prosecuted.

Q. What Role are Whistleblowers Playing in the Fight Against Corporate Fraud and Corruption? How Important is it to Train Staff to Identify and Report Potentially Fraudulent Activity?

A. Some business leaders falsely believe that audits, account reconciliation and other procedures offer the best protection against fraud. They are important functions, but they are not the most effective detection method. Fraud is often uncovered by tips, according to the ACFE’s Report to the Nations on Occupational Fraud and Abuse. Employees are truly the front line of defence for companies, and the first to throw up warning flags about unethical behaviour. The question is whether companies listen to their employees. And is there an easy, anonymous way for employees to submit tips, without fear of retaliation? Companies should educate employees about the red flags of fraud, and then make sure they know they can and should report it.

Q. What Advice can you Offer to Companies on Conducting an Internal Investigation to Follow up on Suspicions of Fraud or Corruption?

A. If the company does not have an experienced team of anti-fraud professionals on staff, it is crucial to enlist the help of an outside firm with experts who specialise in this area. There are mistakes companies make at the beginning of an investigation that can haunt them later. For example, most countries, including the UAE, have laws that govern the proper collecting and handling of evidence. With most evidence in a digital format, following the right protocols is more important than ever. There are also important guidelines for interviewing witnesses and those suspected of fraud which, when disregarded, could lead to a failed investigation. The bottom line is: do not go it alone – get expert professional help. And if criminal conduct is discovered, contact the authorities.

Q. What General Steps can Companies take to Proactively Prevent Corruption and Fraud within their Organisation?

A. Preventing and detecting fraud starts with a company’s employees, so training and communication are key. First, employees must be trained on what constitutes fraud, bribery and corruption, how to recognise it, and how to report it. Second, the company must communicate that fraud will not be tolerated on any level, and those who commit fraud will be terminated and prosecuted if they are found to have broken the law. Companies should also have anti-corruption and anti-fraud controls in place, including an employee code of conduct, regular and surprise audits, and a fraud reporting system available to employees, contractors and even customers. Achieving certification in internationally recognised standards, such as ISO 37001 ABMS, is a good practice too. When it comes to fraud and corruption, an ounce of prevention is worth a pound of cure. Being proactive is truly the only practical option for protecting the business and its assets.


Meet HUMA KHALID,  Scheme Manager

Huma Khalid, as scheme manager, is responsible for leading ABAC. Ms Khalid’s responsibilities include planning and overseeing all aspects of the ABAC programme, which include certification and training. Additionally, she oversees the compliance department for the implementation, management and internal audit of CRI Group’s and ABAC compliance programmes

ABAC™ Center of Excellence Limited | t: +44 (0)777 652 4355 | e:

About CRI Group™

CRI GROUP™ works with companies across the Americas, Europe, Africa, Middle East and Asia-Pacific as a one-stop international risk management, employee background screening, business intelligence, due diligence, compliance solutions and other professional investigative research solutions provider. CRI Group™ has the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Its global presence ensures that no matter how international your operations are, the company has the network needed to provide you with all you need, wherever you happen to be. For more on our Risk Management solutions just check out our brochure:

View Risk Management Solutions Brochure