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Create penalties for fraud and non-compliance

Type of countermeasure

This is a response countermeasure. Response countermeasures respond to fraud after it has occurred. They help to reduce the consequences or disrupt further consequences.


These are penalties for customers, staff or third parties that commit fraud or do not comply with rules, processes and expectations.

Why this countermeasure matters

A lack of penalties for fraud and non-compliance may lead to:

  • individuals being less deterred from committing fraud
  • increasing levels of fraud over time
  • repeated or endemic non-compliance or criminals reoffending.

How to put this countermeasure in place

Some ways to implement this countermeasure include creating penalties like: 

  • raising debts, penalties and interest payments for clients who commit fraud or do not comply with requirements
  • fining, suspending or cancelling providers or third parties who commit fraud or do not comply with requirements or standards
  • sanctioning, demoting or terminating staff for misconduct or fraud.

How to measure this countermeasure's effectiveness

Measure the effectiveness of this countermeasure using the following methods:

  • Review the results of compliance audits or fraud investigations.
  • Confirm that penalties are:
    • enforced through debts, terminations, demotions, or prosecutions
    • appropriate for the type of fraud
    • consistent across similar cases
    • recorded against the client, vendor, staff member or contractor records
    • reported on (for example, to a risk committee)
    • shared with other parties with a need-to-know basis (for example, other organisations are notified of serious or organised fraud or staff/contractor terminations for fraud/misconduct).
  • Analyse statistics on repeated non-compliance or convicted criminals reoffending.
  • Confirm that countermeasures are in place to disrupt repeated non-compliance or criminals reoffending.

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.

 Investigate fraud in line with the Australian Government Investigation Standards (AGIS).

Coordinate disruption activities across multiple programs or entities to strengthen processes and identify serious and organised criminals targeting multiple programs.

Related Fraudster Personas

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