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Create procedural instructions or guidance

Type of countermeasure

This is a prevention countermeasure. Prevention countermeasures are the most common and cost effective way to stop fraud. They prevent or limit the size of the fraud risk by reducing the likelihood and consequences of fraud.

Summary

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
  • guidance to help staff make correct and ethical decisions.

Why this countermeasure matters

A lack of clear guidance and procedural instructions can lead to:

  • high levels of non-compliance or errors due to inconsistent and unclear processes, rules and decision-making
  • common use of shortcuts and workarounds
  • a lack of transparency over actions and decisions
  • poor management of fraud and corruption risks
  • fraudsters taking advantage inconsistent practices and processes to commit fraud and avoid exposure or prosecution
  • fraud or corrupt activity going unnoticed or unchallenged
  • unknown and unaddressed systemic fraud or corruption.

How to put this countermeasure in place

Some ways to implement this countermeasure include creating:

  • clear instructions for clients and third parties to follow
  • clear program procedures and processing instructions for staff
  • clear procedures for internal functions such as credit card acquittals
  • clear guidance for managers who oversee processes and decisions.

How to measure this countermeasure's effectiveness

Measure the effectiveness of this countermeasure by using the following methods:

  • Confirm that procedural instructions and guidance material exists.
  • Confirm that staff can easily find and reference procedural instructions and guidance material.
  • Confirm that staff can easily understand and apply procedural instructions and guidance material.
  • Confirm that staff use procedural instructions and guidance material.
  • Check that procedural instructions and guidance material is reviewed regularly and updated as required.
  • Review statistics on the number of page visits to procedural instructions and guidance material to confirm staff are using it.

Related countermeasures

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.

Clearly document decision-makers using delegations, authorisations and instructions. Clearly defined decision-making powers increase transparency and reduce the opportunity for fraud and corruption.

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.

Related Fraudster Personas

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