CM October 2023

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FRAUD PREVENTION AUTHOR – Annie Birch As highlighted there are a broad range of potentially complex offences covered and therefore risk assessments will need to be wide ranging and incorporate input from a number of different functions within an organisation. Organisations should therefore make sure that individuals tasked with conducting a risk assessment and putting in place procedures have a sufficient understanding of the offences covered. It is important that legal and compliance are closely involved to ensure the nuances of the offences are addressed both in the risk assessment itself, and in policies and the procedures to implement them. Based on the results of their risk assessment, organisations should ensure that anti-fraud policies, systems and controls manage the risks identified effectively. This means putting in place anti-fraud policies and procedures that mitigate outward fraud committed for the benefit of the organisation. Recent proposed amendments have also introduced a failure to prevent money laundering offence, although it remains to be seen whether this will be included in the final legislation. Tailored training Training, including tailored training for those in higher risk positions, should be organised. Given the complexities, case studies will be really important in policies and training to ensure individuals fully understand where offences may arise. Financial controls need to be reinforced and tailored to ensure that any potential red flags are picked up and investigated. Also, two person checks will be required. Due diligence will be necessary in respect of transactions for clients and contracts (for example, suppliers), particularly on third party agents given the offence will apply to the acts of agents acting on the organisation’s behalf. Where possible fraud due diligence should be integrated with existing processes such as anti-bribery and corruption due diligence processes already in place. Also, contractual provisions should cover outward fraud. Organisations also need to put in place effective audit and monitoring processes in relation to fraud, and in particular for third parties. Medium and high risk third parties should be monitored more closely and on a more regular basis. And as for due diligence processes, it is recommended that fraud monitoring and review processes are built in to existing procedures. Lastly, there should be a regular internal review of systems and controls along with a clear tone from the top. Fraud should be an agenda item at board and senior management level to ensure this is prioritised and given the appropriate oversight. Summary A change to the law in relation to fraud is coming, regardless of how it is finally enacted. With the emphasis on ‘preventing’ fraud rather than pinning the blame on a ‘controlling mind’, organisations need to implement procedures that de-risk the likelihood that action will be taken against them. Annie Birch is a Senior Associate at Norton Rose Fulbright LLP. Brave | Curious | Resilient / www.cicm.com / October 2023 / PAGE 18
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CM October 2023

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