Failure to prevent fraud: What to do now? Part 2: Policies and procedures

Our regulation and investigations team have published the second article in their series breaking down the steps companies will need to take to put “reasonable procedures” in place to prevent fraud. As discussed in their previous article, the first step in considering “reasonable procedures” is to conduct a risk assessment to better understand the risks faced by the business. Many clients have put in place a cross-functional working group to consider the underlying offences and different risk scenarios applicable to each function. Once the risk assessment has been conducted, it is important to consider what policies and procedures are already in place to manage the risks identified – and where enhancements are needed.

This article sets out a summary of the approach we generally adopt in assessing and implementing necessary enhancements to fraud policies and procedures.

The full article case be accessed here.