Coordinate disruption activity
Summary
Coordinate disruption activities across multiple programs or entities to strengthen processes and identify serious and organised criminals targeting multiple programs.
Why this countermeasure matters
Serious and organised criminals are using advanced and complex methods to target government programs. Poor or no coordinated disruption activities can lead to criminals:
- continuing to exploit programs
- shifting focus and exploiting new programs
- exploiting multiple programs
- easily moving into and exploiting other programs.
How to put this countermeasure in place
Some ways to implement this countermeasure include coordinating disruption activities like:
- revoking funding approvals
- de-registering businesses and individuals
- issuing Commonwealth debt notices
- conducting taxation assessments
- sharing information with other entities to support due diligence processes
- referring service providers to state and territory regulators or to law enforcement entities for those groups that reach the threshold for complex criminal investigations.
Related countermeasures
This type of countermeasure is supported by:
Establish governance, accountability and oversight of processes by using delegations and requiring committees and project boards to oversee critical decisions and risk. Good governance, accountability and oversight increases transparency and reduces the opportunity for fraud.
Collaborate with strategic partners such as other government entities, committees, working groups and taskforces. This allows you to share capability, information and intelligence and to prevent and disrupt fraud.
Legislation and policy can help prevent, detect and respond to fraud, such as by outlining clear rules, regulations and criteria, allowing entities to collect, use and disclose information and allowing entities to enforce penalties and recover fraud losses.
Develop clear instructions and guidance for activities and processes, such as instructions for collecting the right information to verify eligibility or entitlements, procedures to help staff apply consistent and correct processes and guidance to help staff make correct and ethical decisions.
Make sure a manager, independent person or expert oversees actions and decisions. Multiple people being involved in actions and decisions increases transparency and reduces the opportunity for fraud.
Clearly document decision-makers using delegations, authorisations and instructions. Clearly defined decision-making powers increase transparency and reduce the opportunity for fraud and corruption.
Make sure requests or claims use a specific form, process or system for consistency.
Put in place processes for staff or external parties to lodge tip-offs or Public Interest Disclosures.
Conduct internal or external audits or reviews to evaluate the process, purpose and outcome of activities. Clients, public officials or contractors can take advantage of weaknesses in government programs and systems to commit fraud, act corruptly, and avoid exposure.
Provide staff with the knowledge and skills required to analyse and investigate different types of fraud.
Investigate fraud in line with the Australian Government Investigation Standards (AGIS).
Capture documents and other evidence for requests, claims and activities to detect, analyse, investigate and disrupt fraudulent activity.
Conduct quality assurance activities to confirm that processes are being followed correctly and to a high standard.
Audit logging is system-generated audit trails of staff, client or third party interactions that help with fraud investigations.
Capture video or other electronic evidence of activities to support a fraud investigation and prosecution.
These are penalties for customers, staff or third parties that commit fraud or do not comply with rules, processes and expectations.