ICC launches an Anti-corruption Third Party Due Diligence guide for small and medium size entities
International Chamber of Commerce (ICC) has launched an Anti-corruption Third Party Due Diligence guide for small and medium size entities. SMEs are often on the receiving end of burdensome due diligence procedures of large multi-national companies. These requirements can be overwhelming and often companies feel they do not have sufficient resources to meet them. This Guide aims to address these concerns and inspire Small and Medium size Enterprises (SMEs) to engage in due diligence by creating achievable and manageable due diligence goals. Following the Guide a company can:
- Know and have confidence in their counterparties;
- Through such knowledge and confidence meet the conditions for responsible investment;
- Avoid prosecution/reputational/financial damage from being implicated in an anti-corruption issue;
- Develop an ethical brand;
- Provide assurance to business partners, in particular larger organisations that they are an ethical
company.
SMEs must also develop robust anti-corruption ethics and compliance procedures to ensure they minimise the risk of corruption and adhere to international anti-corruption standards. Understandably, many SMEs are overwhelmed by the extensive international anti-corruption legislation and the complex ethics and compliance procedures in place in larger, multi-national companies. However, ethics and compliance does not necessarily need to be on a grand scale and supported by a dedicated legal department. There are manageable ways in which smaller companies can protect themselves by better managing corruption risks. A key element to a simple but effective ethics and compliance programme is due diligence. This is the focus of this Guide which sets out what due diligence is, why it is necessary, when it is necessary and how it can be implemented to protect a company from the risk of corruption as much as possible.
It provides practical advice on how SMEs can cost-effectively conduct due diligence on third parties they engage to perform services on their behalf. It focuses on corruption risks associated with engaging third party suppliers, contractors and consultants in an international and domestic setting and how those risks can be managed. This tool will also assist SMEs create an effective due diligence procedure that fits into an overall ethics and compliance programme. For SMEs that do not have any ethics and compliance procedures in place, it can be considered a good starting point. The Guide can be used by any SME, of any size (even very small companies) or industry and it can be adapted so that the due diligence programme is tailored to the specifics needs and industry in which the company operates.
ICC is the institutional representative of more than 45 million companies in over 100 countries. Through a unique mix of advocacy, solutions and standard setting, ICC promotes international trade, responsible business conduct and a global approach to regulation, in addition to providing market-leading dispute resolution services. ICC members include many of the world’s leading companies, SMEs, business associations and local chambers of commerce. Read more about ICC here!
Adoption of this Guide by SMEs will provide reassurance to prospective customers and can be used as evidence of an overall compliance commitment; the commercial benefits of which should not be underestimated.
GET THE DOCUMENT HERE
This guide is also available in:
- Spanish version: CCI AUDITORÍA LEGAL ANTI-CORRUPCIÓN SOBRE TERCEROS: GUÍA PARA PEQUEÑAS Y MEDIANAS EMPRESAS
- Swedish version: Anti-korruption Due diligence på externa aktörer
[/vc_column_text][vc_empty_space][accordion_father][accordion_son title=”Speak up – report any illegal, unethical, or improper behaviour” clr=”#ffffff” bgclr=”#1e73be”]Ethics and Compliance Hotline is an anonymous reporting mechanism that facilitates reporting of possible illegal, unethical, or improper conduct when the normal channels of communication have proven ineffective, or are impractical under the circumstances. At CRI Group, we are committed to having an open dialogue on ethical dilemmas regardless.
REPORT HERE!
We would like to introduce a new Ethics & Compliance Hotline. This hotline is available to all employees, as well as clients, contractors, vendors and others in a business relationship with CRI Group and ABAC Group. If you find yourself in an ethical dilemma or suspect inappropriate or illegal conduct, and you feel uncomfortable reporting through normal channels of communication, or wish to raise the issue anonymously, use CRI Group’s Compliance Hotline in below mentioned ways or provide us with your complaint online on the form below. The Compliance Hotline is a secure and confidential reporting channel managed by an independent provider. When reporting a concern in good faith, you will be protected by CRI Group’s Non-Retaliation Policy.
READ MORE!
[/accordion_son][accordion_son title=”Prove that your business is ethical.” clr=”#ffffff” bgclr=”#1e73be”]Complete ABAC® FREE Highest Ethical Business Assessment (HEBA) and evaluate your current Corporate Compliance Program. Find out if your organisation’s compliance program is in the line with worldwide Compliance, Business Ethics, Anti-Bribery and Anti-Corruption Frameworks. Let ABAC® (powered by CRI Group) experts prepare a complimentary gap analysis of your compliance program to evaluate if it meets “adequate procedures” requirements under UK Bribery Act, DOJ’s Evaluation of Corporate Compliance Programs Guidance and Malaysian Anti-Corruption Commission.
The HEBA survey is designed to evaluate your compliance with the adequate procedures to prevent bribery and corruption across the organisation. This survey is monitored and evaluated by qualified ABAC® professionals with Business Ethics, Legal and Compliance background. The questions are open-ended to encourage a qualitative analysis of your Compliance Program and to facilitate the gap analysis process.
The survey takes around 10 minutes to complete. TAKE THE SURVEY NOW!
[/accordion_son][accordion_son title=”About CRI Group” clr=”#ffffff” bgclr=”#1e73be”]Based in London, 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. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.[/accordion_son][/accordion_father]
Have you read…
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ISO 37001 Solutions for all industries (Part 2)
In part 1, we discussed how ISO 37001 ABMS can help companies across a wide range of industries, including automotive, aviation and insurance. In this part, we look at how pharma and healthcare, property, IT and telecommunications, financial, oil and energy organisations can benefit from Anti-Bribery solutions as well.
Pharma and Healthcare
Corruption involving pharmaceutical companies and healthcare providers is a major concern around the world. With varied layers and a complicated supply change, corruption can easily gain a foothold even among the most well-meaning healthcare providers and their companies, especially with the industry overburdened with inflating costs and increasing fraud schemes. The World Health Organisation (WHO) estimates that, where losses have been measured and the types of health expenditure have been covered, the average annual cost of fraud totals 7.29 per cent of healthcare budgets (Gee and Button, 2014). For fraudsters, big pharma and healthcare represent a target-rich environment.
Take global pharmaceutical giant GlaxoSmithKline. The company was accused in China of a large-scale bribery scandal, charged with systematically paying bribes and “gratuities” to doctors and hospitals in return for favourable product use and promotion. China was in the midst of an emerging anti-graft campaign and imposed tough penalties against GSK and its executives: In the end, various company leaders were arrested and eventually given suspended prison sentences; GSK was fined $490 million; and the corporation published a statement of apology to the Chinese government and its citizens (BBC, 2014). Read more about pharma and healthcare fraud in “Pharma and Healthcare Companies can Benefit from ISO 37001.”[/vc_column_text][vc_hoverbox image=”8517″ primary_title=”” hover_title=”Pharma and Healthcare Companies can Benefit from ISO 37001″ hover_btn_title=”TAKE ME TO CASE STUDY” hover_add_button=”true” hover_btn_link=”url:https%3A%2F%2Fcrigroup.com%2Fokatsukr%2F2020%2F09%2Febook_Pharma-case-studies-uncovered-due-diligence-lessons-learned.pdf||target:%20_blank|”]CRI Group investigates: Pharma corruption case included CFO[/vc_hoverbox][vc_empty_space height=”45px”]
Property
Property and real estate provide ample opportunity for bribery and corruption, unfortunately. Every step of the process, from zoning and permits to construction and sale or resale represent vulnerabilities and risk. Unfortunately, for as long as there has been a market for buying and selling land, property and resources, there have been schemes that aim to defraud.
Property fraud can be difficult to detect and prevent. Fraudsters often produce fake or forged documents, and there is likely to be collusion involved. For example, a crooked investor might provide kickbacks to an appraiser in return for inflating the value of a property, or he/she may sell a property to a “straw buyer” at an inflated price, with the straw buyer intentionally going into default (and splitting the proceeds of the loan with the fraudulent investor). There are “handshake deals” and “facilitation payments” ready to be made, many in direct contradiction to ethics and the law.
IT and Telecommunications
Internet technology (IT) and telecommunications providers are the engines that help power commerce on a global scale. This massive industry includes companies that provide the infrastructure for communication across multiple countries and continents, including phone and internet providers. Given their role and the technology on which they (and all of us) depend, these services must always be on guard for vulnerabilities to fraud. There is a high risk, however, for bribery and corruption in such a massive market.
In one example, Sweden-based telecommunications provider Telia Company AB agreed to pay $965 million in a global settlement with the Securities and Exchange Commission, U.S. Department of Justice, and Dutch and Swedish law enforcement to resolve charges related to violations of the Foreign Corrupt Practices Act (FCPA) to win business in Uzbekistan. According to the SEC’s order, Telia entered the Uzbek telecommunications market by offering and paying at least $330 million in bribes to a shell company under the guise of payments for lobbying and consulting services that never actually occurred. In another case, Cinergy Telecommunications (based in Miami) pleaded guilty to violating the FCPA after admitting to a role in a bribery scheme aimed at locking down a contract with the state-owned telecommunications company in Haiti. The case included large fines and criminal prison sentences for the key players.[/vc_column_text][vc_empty_space height=”45px”]
Food and beverage
This industry is one of the fastest-moving industry in regards to changes. Consumer tastes, preferences, packaging, manufacturing, storage
and transportation is constantly changing and challenging the industry. It has been years since the news of the horsemeat scandal first broke and rocked
the industry. It is not immune to bribery and corruption either. In recent years, the food and beverage industry was shaken by the scandal, when British confectionary company Cadbury Limited and its owner, Mondelez International, Inc., agreed to pay $13 million to settle charges of violating the internal controls and books-and-records provisions of the FCPA. According to the order from the SEC, the FCPA violations arose from payments their subsidiary in India made to a consultant to obtain government licenses and approvals for a chocolate factory in Baddi, India.
An SEC investigation found that in February 2010, Mondelez, formerly known as Kraft Foods, Inc., acquired Cadbury and its subsidiaries, including Cadbury India Limited, which manufactures and sells chocolate products in India. Cadbury India retained and made payments to an agent to interact with Indian government officials to obtain licenses and approvals for a chocolate factory in Baddi, India. Cadbury India failed to conduct appropriate due diligence on, and monitor the activities of, the agent.
To find out more, click below to read our e-book on how ISO 37001 provides solutions to British companies exposed by Brexit challenges:[/vc_column_text][vc_hoverbox image=”7902″ primary_title=”” hover_title=”Brexit poses bribery challenges but ISO 37001 provides solutions” hover_btn_title=”TAKE ME TO CASE STUDY” hover_add_button=”true” hover_btn_link=”url:https%3A%2F%2Fcrigroup.com%2Fcase-study%2Fbrexit-poses-new-bribery-challenges%2F||target:%20_blank|”]With Brexit posing challenges through new, untested trade deals in various markets, organisations need ISO 37001 – Anti-Bribery Management Systems standard as a comprehensive approach to mitigating risk.[/vc_hoverbox]
Stay updated
Stay tuned for Part 2 or follow us on LinkedIn, Facebook or Twitter for more industry news and insights.
[/vc_column_text][/vc_column][/vc_row][vc_cta h2=”Subscribe to our monthly newsletter now!”]Sign up for risk management, compliance, corporate and background investigations, business intelligence and due diligence related news, solutions, events and publications.[/vc_cta][/vc_column][/vc_row][accordion_father][accordion_son title=”Who is CRI Group?”]Based in London, 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. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.[/accordion_son][/accordion_father][/vc_column][/vc_row]
CRI Group™’s ABAC™ anniversary: 4 years of achievements
CRI Group™’s ABAC™ Center of Excellence Limited is excited to be celebrating the 4 years anniversary since its formation back in 2016.
At ABAC™, we are committed to helping businesses fight bribery and corruption inside and outside their organisations. Every day, we work extensively to promote transparent business relations across the world and spread knowledge about the negative impact of bribery and corruption.
For the last four years, we educated, equipped and supported the world’s leading business organisations with the latest best-in-practice risk assessments, performance assessments, systems improvement and standards certification.
To commit with our promise to ensure the highest quality of certification and training services, ABAC™is affiliated with leading certification and accreditation bodies around the world. These affiliations and accreditations help demonstrate the high level of experience, knowledge and credibility we provide in anti-bribery, risk and ISO 37301 Compliance Management Systems management to our clients on a daily basis. That’s why ABAC® has achieved essential accreditations from the United Kingdom Accreditation Service (UKAS), Emirates International Accreditation Center (EIAC) for ISO 37001 Certification, and membership in the Association of British Certification Bodies (ABCB).
ABAC™ is also a member of the “Partner in Corporate Governance” programme with the Malaysian Institute of Corporate Governance (MICG) and a Corporate Member of Transparency International Malaysia (TI-M). From the last year, ABAC™ became a registered vendor of the Ministry of Finance Malaysia, got registered with Malaysia External Trade Development Corporation under the Malaysia Ministry of International Trade and Industry, has been accepted as an Alliance Partner of Business Integrity Alliance, Malaysia, and became an Observing Member of Association of Anti-Bribery Management System Practitioner, Malaysia. Learn more about our affiliations and accreditations here.
The past year has helped ABAC™ to expand our network even more and establish core business relationship across different regions. The bigger ABAC™ team is thankful to all clients, partners and global teams for being together in this journey and wishes for many more years of continuous partnerships.
See below our timelines.
Who is CRI Group™ & ABAC™?
Based in London, 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. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC™) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC™ operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC™ for more on ISO Certification and training.[/accordion_son][accordion_son clr=”#ffffff” bgclr=”#1e73be” title=”2 Years Anniversary”]ABAC celebrates 2 years since the formation of the CRI Certification, now re-branded as the ABAC™ Center of Excellence, back in October 2016. For two years we have gone from strength to strength, having hosted two ABAC Summits in both Pakistan and Malaysia, with plans for more to come.
2018 has seen great advances for us. This year CRI Group™ has been granted accreditation by the Emirates International Accreditation Center – EIAC (formerly known as Dubai Accreditation Center – DAC) for the scope of ISO 37001:2016 Anti-Bribery Management System Conformity Assessment Body. The accreditation is the first of its kind awarded to a certification body specialising in global anti-bribery and anti-corruption, risk and compliance standards.
Similarly, our application for UKAS has now been accepted and we are working hard towards achieving this further accreditation, thus giving us that greater credibility edge. We are excited to see where the next two years moving forward will take us.
Let’s stay connected!
3 Years Anniversary
CRI Group’s ABAC® Center of Excellence is proud to be celebrating three-years anniversary since its formation back in 2016. For three years, ABAC has gone from strength to strength, having hosted three ABAC® Summits in Karachi, Islamabad and Kuala Lumpur, with plans for more to come. During this time, ABAC® was accredited by EIAC for administering ISO 37001 certification, audited and awarded clients with ISO 37001 ABMS certifications, collaborated with Malaysian Anti-Corruption Commission, Transparency International, The Malaysian Youth Council and Malaysian Anti-Corruption Foundation to develop a nationwide anti-corruption awareness campaign on International Anti-Corruption Day and initiated other activities to fight bribery and corruption globally. Bribery and corruption is everybody’s problem, and it cannot be prevented and detected if your employees aren’t provided with the information and training they need to combat it.
ABAC® is committed to promoting transparency and compliance to businesses and their professional relationships. Let’s address bribery and corruption together.
Third-party risk: how to survive in a brave new world?
Third party risk management, how to survive in a brave new world?
Third party risk management. The Current Business Climate Requires a Review and Reassessment of Your Organisation’s Third-Party Relationships. We won’t soon forget the year 2020 and the myriad ways worldwide business was derailed over a microscopic virus that caused a global pandemic. From layoffs and shutdowns to shortages and closures, the long-term effects of the pandemic have yet to be determined. But one thing is certain: The disruption to the global supply chain has wreaked havoc in virtually every business sector. third party risk management
Automobile manufacturing in Korea has been suspended due to a lack of parts from China. The fashion industry in the United States is struggling over sourcing as garment producers in Asia reduce output. U.K. aerospace manufacturer Rolls-Royce has announced it is cutting 9,000 jobs as a result of the coronavirus. And sharp declines in consumer demand have adversely affected global manufacturers who, in turn, are idling production to curb losses.
Find out how anti-bribery and anti-corruption management plays an important part in your third-party risk management strategy. This free ebook analyses the performance of Rolls-Royce in terms of ABAC policies within the scope of the ISO 37001 provisions.
Global sourcing has been greatly impacted as suppliers have ceased operations, and multinational organisations have had to scramble to locate replacement supply sources. This gloomy picture has been made all the more daunting as opportunists, bad actors and other sanctioned, restricted, or unreputable parties have set up operations to take advantage of unsuspecting and desperate businesses by producing inferior goods, missing contractual deadlines, or operating in ways that could raise flags in the areas of ethical conduct, business integrity or jurisdictional compliance. As such, multinational companies need to be on high alert for such nefarious outside operations, lest they put their reputations, stakeholders, directors and bottom lines at risk.
Now is the time to identify alternative supply scenarios and re-evaluate contractual terms and performance metrics with those parties in the sourcing network. And to accomplish this, a risk-based approach to diligence, screening and vetting present and potential third-party suppliers is more important now than ever before.
Get your guide for risk prevention, detection and compliance. Download our Risk Management and Anti-Bribery Anti-Corruption Playbook
What is third party risk management?
Threats are increasing on several levels for organisations that rely on outside third parties, such as agents, brokers, vendors and suppliers. While depleted inventories, idle production, inferior products and delayed delivery have greatly impacted the marketplace worldwide, multinational businesses are feeling the brunt of these pandemic-induced supply chain disruptions on a greater scale:
- Organisations are suffering financial loss as the supply chain falters;
- Companies are losing customers because of poor-quality products and services from third parties;
- Organisations are opening the doors to litigation by working with third parties that may be engaging in bad labour practices or forcing workers to produce in unsafe work conditions;
- Company data systems are being exposed and breached because of poor security practices by third parties;
- Companies are experiencing a greater level of supply chain issues due to poor disaster recovery procedures enacted by third parties;
- Organisations and boards are increasingly being exposed to litigation because of relationships with outside providers that may have violated contractual terms, potentially resulting in regulatory exposure;
- Such organisations are being targeted by story-hungry media sources determined to expose the company to a global audience.
The result of these increased risks can be highly problematic:
- Business litigation has skyrocketed;
- Corporate reputations are negatively impacted on a larger scale;
- Organisations have had to continually review, reassess and adapt risk management frameworks to adjust and acclimate to an ever-changing global business environment;
- Board members are becoming increasingly subjected to intense scrutiny from outside watchdogs and critics;
- Unfortunately, a highly educated market responds to the above scenarios accordingly with their pocketbooks.
From supply and production disruptions to regional compliance issues and bad media exposure, multinational corporations face increased scrutiny working with unscrupulous third-party partners. Thus, the an intense need to remain vigilant in conducting due diligence and vetting those outside affiliations.
VIEW 3PRMTM BROCHURE
Don’t let the dominoes fall, ever, with our 3PRM certification
CRI® Group’s third-party compliance verification and certification program – 3PRM-Certified™ – can help organisations establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. Third-party relationships are critical in business today and include partnerships with suppliers, distributors, consultants, agents and other contractors.
While such affiliations are essential to the success of your organisation, a business cannot overestimate the consequences of inadequate due diligence. As the risk for data breaches and supply chain disruption continues to rise with COVID-19, so does the need for effective third-party risk management (TPRM) programs.
Whether you’re a TPRM professional looking for a certification to advance your skillset, or the leader of your organisation considering how to better equip your team with the best knowledge and skills, 3PRM-Certified™ program is an all-in solution.
When is it time to conduct third-party screening?
CRI® Group’s exclusive 3PRM-Certified™ solution provides the very best in third-party risk management. Our 3PRM-Certified™ program provides a proactive approach to mitigating risks from third-party affiliations, protecting the organisation from liability, brand damage and harm to the business. The 3PRM-Certified™ program includes a focus on the following:
- Providing third-party risk assessments
- Meeting contracting requirements
- Conducting due diligence
- Identifying potential fraud risks
- Providing management oversight
Utilising a network of trained professionals positioned across five continents, CRI® Group’s 3PRM services utilise one of the largest multi-national fraud investigation teams the industry has to offer. The 3PRM-Certified™ program is especially critical when your business is performing pre-merger and acquisition research and pre-IPO due diligence, engages new clients, employs, contracts or retains foreign business partners and requires a consistent and audit-worthy AML and anti-corruption compliance program.
Who is CRI® Group?
Based in London, 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.
We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification.
ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
Meet our CEO and Author
Zafar I. Anjum is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due diligence and employee background screening services for some of the world’s leading businesses organisations.
Headquartered in London (with a significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center-QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguards businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business.
CRI® Group maintains offices in UAE, Pakistan, Qatar, Singapore, Malaysia, Brazil, China, the USA, and the United Kingdom. Contact us to learn more about the third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.
Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime)
CRI® Group Chief Executive Officer
t: +44 207 8681415 | m: +44 7588 454959
e: zanjum@crigroup.com
The Role of a Fraud Investigator
Fraud investigators are the front line of establishing the facts of suspected fraud or other unethical business behavior. A fraud investigator’s skillset and wide knowledge of fraud laws, evidence gathering and interviewing make them the go-to expert for investigating insurance fraud, financial fraud, procurement fraud, asset recovery, cyber fraud, healthcare fraud, retail fraud and other areas.
A fraud investigator can either be part of a team of experienced investigators, or the leader of such a team. If part of a team, the fraud investigator generally works with the other team members to handle reports of suspicious activity. If in charge of a team, the fraud investigator would typically report to the head of a department, such as corporate security, compliance or audit. A fraud investigations manager at a typical retail business, for example, would be responsible for the day-to-day monitoring, investigation and resolution of fraudulent activity relating to delays in the repayment and refunds processes. They will take the lead on the implementation of strategies to prevent fraud and financial crime, thereby mitigating risk to the business.
Fraud Investigator Key Functions
Fraud investigators provide subject matter expertise on claims and associated fraud risks, helping to ensure effective resolution of investigations. The effective fraud investigator adheres to relevant security standards, internal and external procedures and legislative requirements. Their role often involves developing and maintaining close working relationships with relevant law enforcement agencies, ensuring that cases are developed and prosecuted to a criminal standard.
When working with an organization in a preventative fashion, a fraud investigator will perform fraud risk assessments across the business relating to both external and internal threats; implementing mitigation measures as required. They also build appropriate fraud prevention and detection processes and implement them. Some fraud investigators manage the day-to-day operation of an expanding fraud team, ensuring that KPIs are met and regular reports produced for the management team. In this capacity, they will also work closely with the senior management team to ensure that operational capacity is correctly aligned to combat a variety of fraud types.
Here are some of the other key functions performed by fraud investigators:
- Evaluate potential fraud indicators and the impact of current fraud trends and make recommendations as to appropriate mitigation.
- Conducting investigations into allegations of fraud, waste or abuse committed by clients against our company
- Reviewing and researching evidence/documents to analyze the overall fact pattern of a claim and synthesize data into a professional report with recommendations
- Preparing and coordinating field assignments to obtain relevant evidence and information
- Conduct objective, fair, thorough, unbiased and timely investigations into allegations of fraud, waste or abuse committed by clients against our company
- Review and research evidence/documents to analyze the overall fact pattern of a claim and synthesize data into a professional report with recommendations
- Prepare and coordinate field assignments to obtain relevant evidence and information
- Coordinate with defense attorneys to provide deposition strategies and use law enforcement resources for assistance
- Manage and priorities a large and varied caseload effectively and efficiently to achieve positive results
- Prepare prosecution packages and restitution proposals.
Responsibilities
As a fraud investigator often wears many different hats, they also have many ongoing responsibilities. These include monitoring transaction reports to identify any suspicious transactions and conducting detailed investigations as required. They must also proactively identify financial crime trends through data analysis and share findings with leadership as and when needed. A few other responsibilities of a fraud investigator include:
- Working to a high standard, meeting strict time-frames whilst working under pressure.
- Communicating directly with customers as part of ongoing fraud investigations through in-app messages or via telephony with potential victims of fraud to establish circumstances and additional information, before providing a fair and logical decision, with supporting rationale.
- Work as part of a team and supporting colleagues as and when required to reduce workload(s).
Personality Traits of a Fraud Investigator
There are some common traits among the most successful fraud investigators. This includes being a self-starter who is results-driven with high levels of self-motivation, energy and initiative. An effective fraud investigator has a proven ability to work under pressure to and meet tight deadlines, without compromising the quality of output. One key trait that can’t be overlooked is the ability to be an effective communicator – a fraud investigator must have excellent written and verbal skills. Here are some other key traits among successful fraud investigators:
- An ability to thrive under pressure amidst changing business priorities
- Effective cost management and analytical integrity
- Experience in leading and developing a team
- Keen interest in stopping fraud whilst considering the impact of how an investigation can impact customers
Knowledge and Skills
A successful fraud investigator brings to the table a broad range of security/ fraud detection and prevention experience. A fraud investigator must be a subject matter expert on fraud for their related field, such as insurance fraud, financial fraud, procurement fraud, asset recovery, cyber fraud, healthcare fraud, retail fraud and other areas.
Many fraud investigators have specialized skills such as:
- Experience of interviewing in accordance with the Police and Criminal Evidence Act following the PACE framework.
- Strong knowledge of cyber risk and common fraud typologies, along with the emerging trends affecting fraud and financial crime.
- Familiarity with key AML, TF, Financial Crime and Sanctions legislation and associated Regulatory Guidance.
- Demonstrated experience working with customers on fraud prevention and detection strategies.
- Sound understanding of the customer impact of a transaction monitoring system; able to balance fraud prevention with the need to provide an excellent customer experience.
As previously mentioned, an effective fraud investigator must have strong interpersonal and communication skills, including the ability to interact with clients, upper management and law enforcement. They also need to have an ingenuity and persistence to obtain case information not readily available with an eye for detail. Dealing with various different cases and different types of evidence requires strong organizational skills. For insurance fraud, investigators must be proficient with the insurance procedures, regulations and investigation methods
Perhaps most important, fraud investigators must set a positive example for their colleagues. They need to be honest and ethical, with high levels of integrity and confidentiality.
A fraud investigator has many different responsibilities, and the role requires an individual with some specific traits. CRI Group’s fraud investigators are experts at uncovering the facts and evidence of a case, but they also implement proactive anti-fraud measures to help an organisation be better protected against future incidence of fraud. Fraud investigators specialise in insurance fraud, financial fraud, procurement fraud, asset recovery, cyber fraud, healthcare fraud, retail fraud and other areas. It’s important that organisations hire trained, qualified fraud investigators who understand the laws, are effective at evidence collection and fact-finding, and are good communicators (since interviewing is one of the key processes of fraud investigation). A fraud investigator might work with a team, or they might lead their team and report to another division. Being able to work under pressure and meet deadlines is critically important. Properly evaluating and securing evidence is of equal importance. CRI Group has only the best expert fraud investigators to meet these challenges.
Are you a fraud investigator? Tell us about your day-to-day job, we would love to hear it.
Who is CRI Group?
Based in London, 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. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organizations. Contact ABAC® for more on ISO Certification and training.
Q&A session with our CEO: United Arab Emirates fighting Fraud and corruption
Middle east corruption is a threat to the world. The United Arab Emirates (UAE) is a land of complex extremes where fabulous wealth and supercars live right next to staggering poverty. This is generally a recipe for fraud and corruption. However UAE has been talking the right steps towards a fraud free future. This Financier Worldwide Q&A session with our CEO discusses United Arab Emirates role in fighting fraud and corruption. Read the answers to the following questions:
- To what extent have you seen a notable rise in the level f corporate fraud, bribery and corruption uncovered in United Arab Emirates in recent years?
- Have there been any legal and regulatory changes implemented in United Arab emirates designed to combat fraud and corruption? What penalties do companies face for failure comply?
- Do regulators in United Arab Emirates have sufficient resources to enforce the law in this area? Are they making inroads in this area?
- If a company finds itself subject to a government investigation or dawn raid, how should it respond?
- and much more…
Q. To what extent have you seen a notable rise in the level of corporate fraud, bribery and corruption uncovered in United Arab Emirates (UAE) in recent years?
ANJUM: Some recent, high profile cases have affected companies and countries in the Middle East. Embraer’s bribery scandal, involving sales of its aircraft, included officials in Saudi Arabia, among others. Further, there have been suspicions of corruption surrounding the awarding of the 2022 FIFA World Cup to Qatar, suspicious which have been worsened by allegations of human rights abuses involving migrant workers. In general, however, it is still issues like data theft, e-commerce fraud, information security and other high tech threats that pose serious risks to organisations in the Middle East. We live in an increasingly connected world, so while anti-fraud laws and controls in one country may be robust, a company might find itself doing business abroad in a location where laws and enforcement are more lax, and risk is heightened.
Q. Have there been any legal and regulatory changes implemented in UAE designed to combat fraud and corruption? What penalties do companies face for failure to comply?
ANJUM: the UAE has a strong reputation for being tough on corruption, and a new law enhances this stance. The recently approved, and highly anticipated, Anti-Commercial Fraud Law will strengthen protections of intellectual property rights (IPR) and will impose stricter penalties anon counterfeiters. For example, a fraud offence related to counterfeiting could now result in up to 2 years in prison, as well as a fine of up to Dh1m. Overall, corruption is still a low risk for companies operating in the UAE. Laws against corruption are enforced, and they cover bribery, facilitation payments, embezzlement and other types of fraud and abuse. However, when concerning the Middle East as a whole, there are indications that fraud and corruption are the rise, which means we must be ever vigilant in protecting investments throughout the region.
Q. In your opinion, do regulators in UAE have sufficient resources to enforce the law in this area and fight corruption? Are they making inroads in this area?
ANJUM: When considering the Middle East region, there can be no ignoring war-ravaged areas like Syria, Iraq, Libya and Yemen. It is an understatement to say that countries embroiled in conflicts and crisis usually do not have the resources or manpower to properly prevent and detect fraud. But according to Transparency international’s most recent Corruption Perceptions Index, a few of the other more stable and affluent countries in the region are experiencing some difficulty preventing fraud, as well. Different factors can contribute to these struggles, be they politics, autocratic leadership, weak laws or judiciary bodies. However, the UAE still ranks as the least corrupt country in the Middle East, and other countries might take heed of the country’s Anti-Commercial Fraud Law and other existing laws, not to mention the UAE’s enforcement measures, as a possible model for future efforts.
Q. If a company finds itself subject to a government fraud and corruption investigation or dawn raid, how should it respond?
ANJUM: A company that finds itself in such as crisis should immediately cooperate with authorities and work quickly to gather the facts. What are the allegations? What is the scope of the investigation? Was the raid expected, or has the company been taken completely by surprise? In the early stages, it is crucial that the company engages in a good-faith effort to be transparent and cooperative. Of course, retaining legal counsel, is a must at this an every stage of an investigation, If an employee or employees have engaged in fraud, the company should support the fact-finding process and let justice run its course. Company leaders should also evaluate their internal controls and ensure that additional fraud or corruption is not occurring under the radar.
Q. What role are whistle-blowers playing in the fight against corporate fraud and corruption? How important is it to train staff to identify and report potentially fraudulent activity?
ANJUM: The statistics on fraud, such as in the Association of Certified Fraud Examiners Report to the Nation on Occupational Fraud & Abuse show that fraud is most often uncovered by tips, more so than audits, surveillance, account reconciliation, document examination and other methods. Accordingly, a company’s own employees are their first line of defence against fraud. But to encourage whistle blowing, two critical measures need to be in place. First, employee should be trained to identify the red flags of fraud, and to know what does, and what does not, constitute fraudulent behaviour. Second, a reporting mechanism should be in place; an anonymous system by which whistle-blowers can submit their tips without fear of retaliation or negative consequences.
Q. What advice can you offer to companies on conducting an internal investigation to follow up on suspicions of fraud or corruption?
ANJUM: In any situation where fraud is suspected, it is crucial that experts be brought in as quickly as possible to help unravel the facts of the case, if the company does not have anti-fraud professional among its staff, It is critical to remember that there are various laws, depending on your country or region, which govern the rules of gathering evidence and interviewing witnesses. Any evidence that is mishandled or collected improperly can negatively impact an investigation and hurt the chances of a resolution. If an investigation is bungled from the start, it is nearly impossible to then ‘wind it back’ and correct mistakes later. Also, if criminal behaviour is suspected, legal authorities should be quickly notified and provided with the company’s findings and reasons for the allegation.
Q. What general steps can companies take to proactively prevent corruption and fraud within their organisation?
ANJUM: Every organisation, large or small, should have a plan in place for preventing and detecting fraud. The first step is to communicate the organisation’s zero-tolerance stance against fraud. An ethical code of conduct, signed by every employee, can be effective in this regard. A fraud risk assessment should be conducted to find vulnerabilities. The company’s hiring policy should include pre- and post-employment background screening. Job responsibilities should include segregation of duties, so that no single employee has too much control over finances or assets. The company should conduct audits and encourage whistle-blowing with an anonymous reporting system. With a comprehensive fraud prevention system in place, business owners can sleep a little easier, knowing that their organisation has reduced risk and increased their ability to prevent and detect fraud.
Speak up – report any illegal, unethical, or improper behaviour
If you find yourself in an ethical dilemma or suspect inappropriate or illegal conduct, and you feel uncomfortable reporting through normal channels of communication, or wish to raise the issue anonymously, use CRI® Group’s Compliance Hotline. The Compliance Hotline is a secure and confidential reporting channel managed by an independent provider. When reporting a concern in good faith, you will be protected by CRI® Group’s Non-Retaliation Policy.
About CRI® Group
Based in London, 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. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI® Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
Meet our CEO
Zafar I. Anjum, is Group Chief Executive Officer of CRI® Group (www.crigroup.com), a global supplier of investigative, forensic accounting, business due diligence and employee background screening services for some of the world’s leading business organisations. Headquartered in London (with significant presence throughout the region) and licensed by the Dubai International Financial Centre-DIFC, the Qatar Financial Center-QFC, and the Abu Dhabi Global Market-ADGM, CRI® Group safeguards businesses by establishing the legal compliance, financial viability, and integrity levels of outside partners, suppliers and customers seeking to affiliate with your business. CRI® Group maintains offices in UAE, Pakistan, Qatar, Turkey, Singapore, Malaysia, Brazil, China, USA, and the United Kingdom.
Contact CRI® Group to learn more about its 3PRM-Certified™ third-party risk management strategy program and discover an effective and proactive approach to mitigating the risks associated with corruption, bribery, financial crimes and other dangerous risks posed by third-party partnerships.
CONTACT INFORMATION
Zafar Anjum, MSc, MS, CFE, CII, MICA, Int. Dip. (Fin. Crime) | CRI Group Chief Executive Officer
37th Floor, 1 Canada Square, Canary Wharf, London, E14 5AA United Kingdom
t: +44 207 8681415 | m: +44 7588 454959 | e: zanjum@crigroup.com
This Q&A article is based on a 2017 Financier Worldwide interview.
Since 2001, Financier Worldwide has provided valuable information on corporate finance and board-level business issues through its monthly magazine and exclusive website content. As a leading publisher of news and analysis on this dynamic global market, the organisation is recognised as a valued source of intelligence to the corporate, investment and advisory community. More from Financier Worldwide:
- Corporate resilience: managing third party risks, April 2013 | SPECIAL REPORT: MANAGING RISK
- Contract fraud: is your organisation at risk?, February 2013 | SPECIAL REPORT: CORPORATE FRAUD & CORRUPTION
- Fraud & Regulatory Enforcement 2013, April 2013 | FRAUD & CORRUPTION
Download 2018 annual reviews by Mr. Zafar Anjum, CEO, and Ms. Fatima Farrukh, Compliance professional at CRI® Group.
ISO 37001 Solutions for all industries (Part 1)
Organisations of all industries, from financial institutions to international energy companies, can gain distinct benefits from ABAC® Certification for ISO 37001:2016 Anti-Bribery Management System standard. The fact is, any company is potentially susceptible to bribery and corruption. Some industries face increased risk – which is why CRI Group’s ABAC® tailors ISO 37001 for companies across a wide range of industries, including automotive, aviation, insurance, pharma/healthcare, property, IT/telecommunications, financial, oil and energy, and others. In today’s business climate, no organisation can afford the risk of being non-compliant and unprotected. The following are some of the issues facing companies in different industries.
Automotive
The automotive industry is a huge worldwide business, and corruption and “pay-to-play” schemes make the headlines on a regular basis. Considering the markets involved include steel, labour, shipping, and others, it stands to reason that the industry can be a target for bribery and corruption problems.
One example is Rolls-Royce Motor Cars, which was punished to the tune of an $800 million (U.S.) global settlement that included a deferred prosecution with the UK’s Serious Fraud Office (SFO), the U.S. Justice Department and Brazilian authorities. The company was found to have engaged in systemic bribery spanning 13 years and 22 countries. There were multiple schemes in various countries and locations, including Indonesia, Thailand, India, Nigeria, China, and Russia. Learn more in detail about the Rolls-Royce investigation in CRI Group’s case study, “Ethics, Compliance and Rolls-Royce”.
Aviation
The aviation industry is facing a series of pressures that challenge each airline’s profitability and growth. Over the course of the next 20 years, the global commercial aircraft fleet is expected to double to approximately 45,000 aircraft, driven by increased air travel due to an expanding middle class in emerging economies. Risk of bribery and corruption is ramped up, however, by the fact that the supply chain struggles to keep up with demand due to the ramp-up in production, volatility in the geopolitical and economic environment is increasing, and a growing labour shortage is lurking in the background.
Look at major cases like Pakistan International Airlines (PIA), which has been embroiled in a scandal. The allegations involve “organised failure of institutional management, state, and internal controls,” in some cases connected to air accidents with loss of lives. PIA is just a high-profile example of what can result when such corruption goes unchecked, with mismanagement, corruption and kickbacks causing irreparable harm. Read more about the PIA case in the CRI Group white paper, “Organised Catastrophe of Pakistan International Airlines: Major Critical Risk Elements – Mismanagement – Corruption”.
Insurance
While every type of insurance is ripe for fraud, did you know that bribery and corruption are among those schemes in the insurance industry? Fraudsters are opportunists who look for an opening, and that can involve collusion, such as between claimants and adjusters, for example; or bribing officials to provide false reports or otherwise fabricate evidence in support of an insurance claim. In fact, there are well-known cases of highly organised criminal gangs who have built money-making enterprises on insurance fraud.
With the enormous liability presented by insurance fraud, every organisation should address their risk with proper control systems in place. This includes vigorous anti-bribery anti-corruption measures such as those implemented in ISO 37001. Successful risk mitigation includes conducting regular risk assessments, staying in compliance with all major laws and regulations, and regularly measuring and evaluating results.
Stay updated
Stay tuned for Part 2 or follow us on LinkedIn, Facebook or Twitter for more industry news and insights.
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Who is CRI Group?
Based in London, 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. We have the largest proprietary network of background-screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are we have the network needed to provide you with all you need, wherever you happen to be. CRI Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI Group launched Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body established for ISO 37001:2016 Anti-Bribery Management Systems, ISO 37301 Compliance Management Systems and ISO 31000:2018 Risk Management, providing training and certification. ABAC® operates through its global network of certified ethics and compliance professionals, qualified auditors and other certified professionals. As a result, CRI Group’s global team of certified fraud examiners work as a discreet white-labelled supplier to some of the world’s largest organisations. Contact ABAC® for more on ISO Certification and training.
The Unseen Enemy: Insurance Fraud – Part I
This three-part series of articles examines the problem of insurance fraud, including its pervasiveness and general characteristics in the United States, the United Kingdom and the world. Insurance fraud is a widespread problem that requires real solutions and is often difficult to detect and combat.
Part One of the series, “What is Insurance Fraud,” provides an introduction to a topic that is important for any business leader, insurance professional, compliance agent or fraud investigator. Part Two, “How do Companies Detect Insurance Fraud,” details red flags of insurance fraud that help tip off investigators to possible illegal behaviour. Part Three, “Anatomy of an Insurance Fraud Investigation,” provides a look at case studies and reveals key tips for handling a successful investigation. To receive the next series subscribe to our monthly newsletter subscribe now!
Taken as a whole, this series is the perfect primer for any insurance fraud professional and companies looking to avoid becoming victims of insurance fraudulent claims. It provides the tools and knowledge needed to effectively combat insurance fraud.
Insurance Fraud Consequences Around the World
Fraudulent claims costs an estimated $40 to $80 billion per year in the U.S. alone. According to Cifas, the UK’s leading fraud prevention service, members report a 27% rise in false insurance claims across the UK in the past year, with spikes in household and motor insurance. Cifas members also reported the following:
- Household insurance fraudulent claims have increased by 52%, with claimants aged 31-40 the biggest culprits
- motor insurance fraudulent claims have increased by 45%, with 21-30 year-olds making up the largest group
- Fronting insurance is on the decline overall, however the share of millennials (21-30 year-olds) committing the offence increased by 18% in 2018.
Fraudulent claims are deliberately undetectable, therefore it’s hard to place an exact value on the money stolen. According to Alfred Manes’ “Insurance Crimes” in the Journal of Law and Criminology, the official number of cases does not correlate with the reality. The Coalition Against Insurance Fraud Annual Report estimates that a total of about $80 billion was lost in the US in 2006.
- Insurance Information Institute estimates that the insurance fraud accounts for about 10% of the property insurance industry’s incurred losses and loss adjustment expenses.
- The National Health Care Anti-Fraud Association’s “The Problem of Health Care Fraud” estimates that 3% of the health care industry’s expenditures in the U.S. are due to fraudulent activities, amounting to a cost of about $51 billion.
- David A. Hyman writes in “Health Care Fraud and Abuse” estimates that 10% of the total healthcare spending in the US to fraud—about $115 billion annually.
Consider these statistics:
- According to Federal Bureau of Investigation’s “FBI — Insurance Fraud,” non-health insurance fraud costs an estimated $40 billion per year – consequently this increases the premiums for the average U.S. family between $400 and $700 annually.
- J.E. Smith’s book “The Trillion Dollar Insurance Crook” puts the true cost fraud committed in the US at 33% to 38% of the total cash flow through the system
- In the UK, the Insurance Fraud Bureau estimates that the loss due to insurance fraud is about £1.5 billion ($3.08 billion), causing a 5% increase in insurance premiums
- Insurance Bureau of Canada “Cost of Personal Injury Fraud” estimates that personal injury fraud costs about C$500 million annually.
- “Indiaforensic Study on quantification of fraud losses to Indian Insurance Sector” estimates that Insurance frauds in India costs about $6.25 billion annually.
Part One: What is Insurance Fraud?
It’s been called an epidemic and is a scourge of insurance providers, private companies and consumers alike. But what is it, how do companies detect it, and how does an insurance fraud investigator unravel it? In this part one of a three-part series, we will address the first question: What is insurance fraud?
Most of us deal with insurance in various forms throughout our lives. It’s a necessity in some cases through which we pay regular premiums in order to be protected from damages or liability from an unknown future event, such as an accident or illness. For large corporations, insurance can be worth millions, covering things like product liability, workers’ compensation, business interruption and other serious risks. It’s also rife for fraudsters, who often live by the well-known maxim, “follow the money.”
Don’t have time to read the rest?
Taken as a whole, this ebook is the perfect primer for any insurance fraud professional and companies looking to avoid becoming victims of insurance fraud claims. It provides the tools and knowledge needed to effectively combat insurance fraud.
Download your Insurance Fraud Investigations FREE ebook here!
Every type of insurance is vulnerable to insurance fraud. This type of cases can be committed by opportunists – consider claim fraud, where perpetrators invent or exaggerate a claim; or application fraud, where they deliberately or recklessly provide false information when applying for insurance. There are well-known fraudulent insurance claim cases of highly organised criminal gangs with money-making enterprises based on motor-vehicle fraud or health care fraud, for example. But fraud can happen at any point along the process of an insurance claim, by insurance applicants, members/policyholders, third-party claimants or others (including professionals who specialise in pursuing claims for policyholders).
Fraudulent claim cases also cover a wide range of schemes and crimes. The following are some of the most common types of fraud involving the insurance industry, according to the ACFE’s “Insurance Fraud Handbook”:
- Agent and broker schemes
- Underwriting irregularities
- Vehicle insurance schemes
- Property schemes
- Life insurance schemes
- Liability schemes
- Health insurance schemes
- Worker’s compensation schemes
Fraudsters find new ways to pull off their scams, from simply falsifying claims to engaging in mail fraud, identity theft, and forgery, they will make it happen. For example, when looking at just motor vehicle-related fraudulent claims, the types of schemes include the following:
- Vehicle dumping or destroying
- False registration
- Exaggerated repair costs after a car accident
- Faulty airbag replacement
- Faulty windshield replacement
All of the above is intended to enrich the fraudsters at the expense of insurance providers, and, in some cases, other innocent victims. People have even been injured in schemes that involved faked traffic accidents for the purpose of insurance fraud.
Who is Involved?
Often committed by someone directly connected to the insurance policy. This includes the policyholder, applicant and their beneficiaries. However, insurance insiders – i.e. brokers and agents- as well as gatekeepers – i.e. lawyers and accountants, could be behind the scheme. They collude with the policyholder in exchange for a portion of the profits or victimize the policyholder for their own gain. Examples include:
- A doctor submitting improper medical coding to receive a higher payment than they are entitled to.
- A mechanic fabricating a bill for more repairs than the car required after an accident.
- A private investigator not really doing the investigation on fraudulent behaviour.
- An attorney was helping a claimant fabricate a story about how they hurt themselves on the job so they can receive worker’s compensation.
When times are tough for them financially, people are more likely to commit insurance fraud. You can sometimes discover opportunistic fraud by interviewing the alleged fraudster’s friends or neighbours about their financial situation.
Case Study: The ‘Phantom Collision’ Ring
In 2014 in Los Angeles, a ring of over a dozen insurance fraudsters was busted for fraudulent collision claims. The perpetrators of the frauds recruited family members and friends to help orchestrate fake accidents, ultimately stealing more than $300,000 from auto insurance companies before they were caught.
In some cases, the collisions didn’t even happen at all. All it took were willing participants to make claims in coordination with repair and auto body shops to make the fraudulent claims. In the end, fraud investigators were able to detect a pattern to their claims, helping them unravel the scheme.
The case is reminiscent of a similar instance that made shocking headlines in 1996 when an organised crime ring (also in L.A.) made up of six perpetrators netted a jaw-dropping $20 million in phoney claims. When they were caught, it was discovered that they had staged more than 100 fake accidents, filing $10,000 to $20,000 in claims per incident. For many people who read about the case in the newspapers, it was their first exposure to something of this magnitude, whereas they had previously thought of insurance fraud cases as “one-off” crimes of opportunity.
Case Study: Doctors, Clinics Get in on Insurance Fraud in New York
Healthcare fraud is another area that is susceptible to major fraud conspiracies. Last year in New York City, more than 20 people and more than a dozen corporations were charged in a massive scheme to defraud Medicaid, Medicare and other insurance providers. The operation was so sophisticated; it allegedly involved “office staff, recruiters, managers, billers and money launderers.”
As is common with such cases, the fraudsters targeted poor and vulnerable people to help them execute the fraud. They went into low-income areas and in some cases approached homeless people, offering them cash ($30 to $40) in exchange for them going into clinics that were in on the scheme and ordering unnecessary tests. In many cases, the tests weren’t even performed, and the “patients” didn’t even have a consultation with a doctor.
The massive fraud included doctors and utilised shell companies to help launder the millions of dollars that were processed by the perpetrators. The case, with 878 indictments, is still in the court system.
The Ten Most Common Types of Insurance Fraud
In case you think that fraud is limited to automobiles and healthcare, consider all of the types of insurance that are available – and know that all of them are susceptible to fraud. In fact, investigators from Business Insurance have provided a list titled “10 Most Common Types of Insurance Fraud.” These cases even include staged home fires and faked deaths:
- Stolen car
- Car accident
- Car damage
- Health insurance billing fraud
- Unnecessary medical procedures
- Staged home fires
- Storm fraud
- Abandoned house fire
- Faked death
- Renter’s insurance
Investigating Insurance Fraudulent Claims are Best Left to the Experts
With the enormous liability presented by insurance fraud, every organisation should address the risk in their due diligence and fraud prevention programs. The best way to do that is to bring in the experts at CRI Group to help implement this as part of a risk management plan.
When fraud is detected, CRI Group’s investigations cover the full range of fraudulent claim cases, from health care fraud to disability and even fake death claims. CRI Group’s thoroughly trained experts are trained, for example, to look for the tell-tale signs of fraud carefully reviewing claims, medical and hospital records, conducting interviews, examining statements and documents and performing on-site inspections.
In Part Two, we will examine some of the tell-tale signs and red flags of fraudulent claims, and how insurance fraud investigation companies can have a better chance of detecting it before it causes irreparable damage. Like many criminal schemes, this type of cases are often well-hidden – the key is knowing what to look for.
Do you want to read the next series now? Not a problem, this three-part series of articles is part of our “The Unseen Enemy: Insurance Fraud” ebook with actionable advise on how to protect your business and much more. Download the FREE ebook here!
9 ways COVID-19 impacted background checks
The COVID-19 pandemic has disrupted business as we know it. How is the crisis still affecting your organization? Are you still experiencing a temporary decline in hiring, or does hiring seem to be non-stop? No matter your industry, the hiring environment has changed because of COVID, probably forever. Workforces are still restricted mainly in the way they can work, and many are still in some form of lockdown or self-isolation. This poses a lot of challenges when it comes to recruitment, such as:
1. Navigating the new realm of virtual recruitment;
2. High demand for recruitment in specific sectors (e.g. pharmaceuticals, retail supermarkets, delivery companies, transportation, retail banks, healthcare);
3. Accommodating for existing staff working from home;
4. The need to hire employees (in high demand) with a specific skill set (e.g. digital marketing, IT teams, customer service);
5. The overwhelming amount of applicants without the right qualifications due to industries struggling;
6. Delayed hiring processes;
7. The need to expand candidate reach because of the lack of appropriate applicants;
8. Losing applicants to competitors;
9. Considering the long-term and short-term economic impact of hiring during the uncertainty of the pandemic.
The number one challenge companies will face as they restart hiring is that their people and financial resources may be dramatically limited. They’ll have to think about efficiencies in the way they hire and the people they bring on.When they post positions, they’re going to be flooded by applicants. How will a limited HR staff sort through 400 online applications to find the best two?
Companies are faced with the difficult task of hiring quickly and economically whilst managing the day to day risks and challenges. And the situation is changing at an hourly rate. Businesses have to adapt rapidly to survive, i.e. cutting steps in their hiring process, and no one knows how this will play out. However, there are ways you can mitigate the impact, learn how with this FREE ebook. Taken as a whole, this ebook is the perfect primer for any HR professional, business leader and company looking to avoid employee background screening risks. It provides the tools and knowledge needed to stay ahead of COVID-19 effectively.
Regardless of the industry, you work in, and the likelihood is that your normal hiring processes and background checks would have been affected by the COVID-19 pandemic forever.
Key Impacts of COVID-19
Lockdown drastically reduced the data sources needed to carry out checks for incoming employees, and many vital workers would have been affected by this. As the lockdown restrictions are being lifted, sources are slowly becoming available, but the uncertainty of a second wave could put them under threat again. The economic impact of Covid-19 resulted in many employees being furloughed. This would have also restricted the availability of accessing data sources.
Did you know that 1 in 3 furloughed UK employees was pressured to work? Read more about furlough fraud and how it looks like.
Employsmart™: background checks during COVID-19 and more
As a background screening provider, CRI® Group can support you by proactively monitoring the data sources and working with them to understand when and how to carry out verification requests. By working with a background screening partner, we can tailor your screening needs to the challenging times we’re facing. EmploySmart™ is CRI® Group’s robust pre-employment background screening service that helps companies of any size and industry avoid negligent hiring liabilities. We know you have lots of questions. We compiled a FAQ ebook, read now or download your FREE ebook.
During the COVID-19 pandemic, it’s imperative to ensure a safe work environment for all of your employees. EmploySmart™ can be tailored to meet the requirements of each specific position within your company. As a leading worldwide provider of specialised local and international employment background screening, CRI® Group’s services are second-to-none in providing risk mitigation and peace of mind in the hiring process.
Learn more about how EmploySmart™ can help your company stay protected during these strange and uncertain times. Contact CRI® Group today.
Who is CRI® Group?
Based in London, 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.
We have the largest proprietary network of background screening analysts and investigators across the Middle East and Asia. Our global presence ensures that no matter how international your operations are, we have the network needed to provide you with all you need, wherever you happen to be. CRI® Group also holds BS 102000:2013 and BS 7858:2012 Certifications, is an HRO certified provider and partner with Oracle.
In 2016, CRI® Group launched the Anti-Bribery Anti-Corruption (ABAC®) Center of Excellence – an independent certification body that provides education and certification services for individuals and organisations on a wide range of disciplines and ISO standards, including ISO 31000:2018 Risk Management- Guidelines, ISO 37000:2021 Governance of Organisations, ISO 37002:2021 Whistleblowing Management System, ISO 37301:2021 (formerly ISO 19600) Compliance Management system, Anti-Money Laundering (AML) and ISO 37001:2016 Anti-Bribery Management Systems.
FAQ: Employment Screening
Want to know what red flags are most often found on résumés and employment applications? CRI® Group’s EmploySmart™ experts provided some statistics on their latest pre-and post-employment screening engagements, giving insights into where companies are most vulnerable in the hiring process. The operations team found that providing incorrect employment details is the most common red flag, as it was uncovered in about 4.5 per cent of background screenings. This is followed by providing incorrect education degree details and having adverse media (unfavourable news or online mentions), both at 2.33 per cent.
Most employers would probably say that when it comes to educational background, the only thing worse than providing incorrect degree information would be outright claiming a fake degree – which occurred in nearly 2 per cent of cases. Other red flags included:
- Having a criminal record (1.5 per cent).
- A civil litigation record (1.27 per cent).
- Providing a fake address (also 1.27 per cent).
To round out the findings, the operations team found bankruptcy records, fake certificates and negative references among 0.85 per cent of those screened.
Get answers to frequently asked questions about background checks/screening cost, guidelines, check references etc. This eBook is a compilation of all of the background screening related questions you ever needed answers to:
- Does a candidate have to consent to process a background check/screening?
- How long does it take to conduct a background check?
- When should I conduct pre-employment checks?
- How often should I screen employees?
- How to collect references, and what to ask?
- How much does it cost to conduct background checks?
- What is the difference between employment history verification and employment reference?
- How do I check on entitlement to work?
- How to conduct identity checks?
- What will a financial regulatory check show?
- Is it possible to identify conflict of interest during checks?
- What is a bankruptcy check?
- What about directorships and shareholding search?
- Can I have access to a criminal watch list?
- Anti-money laundering check?
- Can we conduct FACIS (fraud and abuse control information system) searches?
- … and MORE!
Taken as a whole, it is the perfect primer for any HR professional, business leader and company looking to avoid employee background screening risks. It provides the tools and knowledge needed to make the right decisions.
Download your “Employee Background Screening FAQ” FREE ebook now!
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