Create recovery and debt management processes
Summary
These are processes that identify and recover debts owed by staff, customers and third parties.
Why this countermeasure matters
A lack of recovery and debt management processes may lead to:
- not being able to identify or recover debts
- 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 recovery and debt management processes like:
- procedures to immediately retrieve incorrect or fraudulent payments with the help of the Reserve Bank of Australia or financial institutions
- recording and recovering debts arising from non-compliance
- recording and recovering staff overpayments
- obtaining refunds from suppliers if contract obligations are not met
- working with the multi-agency Criminal Assets Confiscation Taskforce
- recovering the proceeds of fraud under the Proceeds of Crime Act 2002
How to measure this countermeasure's effectiveness
Measure the effectiveness of this countermeasure using the following methods:
- Confirm legislation/policy exists to support the recovery of stolen funds or fraudulent payments.
- Confirm processes/systems are in place to support the recovery of stolen funds or fraudulent payments.
- Review debt recovery processes to see if they conform to national guidelines and frameworks.
- Review data on debt recovery.
- Confirm statistics on debt recovery are reported on.
- Determine the timeframes for recovering stolen funds or fraudulent payments. Consider if delays would reduce the ability to recover all the money.
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.
Provide staff with adequate training to increase likelihood that correct and consistent processes and decisions will be applied.
Make sure requests or claims use a specific form, process or system for consistency.
Automatically match data with another internal or external source to obtain or verify relevant details or supporting evidence. This countermeasure is supported by the Office of the Australian Information Commissioner's Guidelines on data matching in Australian government administration.
Require clients, staff and third parties to have ongoing compliance, performance and contract reviews.
Put protections in place to prevent data from being manipulated or misused.
Collect and analyse data to improve processes and controls, increase payment accuracy and find and prevent non-compliance, fraud and corruption.
Coordinate disruption activities across multiple programs or entities to strengthen processes and identify serious and organised criminals targeting multiple programs.
These are penalties for customers, staff or third parties that commit fraud or do not comply with rules, processes and expectations.
Related Fraudster Personas
This countermeasure helps prevent, detect or respond to the following Fraudster Personas:
