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Establish governance, accountability and oversight

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.

decorative  prevention 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.

Why this countermeasure matters

A lack of good governance, accountability and oversight can:

  • lead to processes not working properly or becoming uncertain
  • cloud the visibility of fraud and corruption risks
  • inhibit decisions and actions needed to prevent, detect and respond to fraud and corruption.

How to put this countermeasure in place

Some ways to implement this countermeasure include creating:

  • program/project reporting requirements and governance arrangements to make sure there is transparency and accountability
  • executive boards and committees to oversee operations and make decisions
  • clearly defined accountabilities and responsibilities
  • clear reporting lines and accountability for program/project performance and risk
  • risk management plans and regular risk reporting
  • dedicated positions to monitor research integrity.

How to measure this countermeasure's effectiveness

Measure the effectiveness of this countermeasure using the following methods:

  • Review governance structures to confirm clear reporting lines and accountability for program/project performance and risk.
  • Confirm executive oversight exists for critical processes and decision-making.
  • Confirm that risk management plans or fraud risk assessments have been completed and they are monitored and reported to appropriate officials.
  • Confirm who is accountable for managing the identified fraud risks.
  • Identify how governance processes and accountabilities are communicated.
  • Undertake a staff census and particularly ask questions relevant to strategic direction and executive engagement.
  • Review APSC Census Results if you are Commonwealth entity.

Related countermeasures

This type of countermeasure is supported by:

A positive workplace culture can encourage ethical and supportive behaviours while discouraging fraudulent or corrupt activities. Staff will be less able to rationalise fraudulent or corrupt activities where a positive workplace culture exists. A culture built on honesty, transparency and integrity is a key organisational strength that can serve to reduce the risk of fraud. If weak countermeasures are the fuel, a bad culture can be the spark that ignites fraud and corruption.

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

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.

Prepare summary reports on activities for clients, managers or responsible staff.

Establish exception reports to identify activities that are different from the standard, normal, or expected process and should be further investigated.

Report on incidents or breaches to help identify if further investigation is required. Clients, public officials or contractors can take advantage of a lack of reporting and transparency to commit fraud, act corruptly and avoid exposure.

Internal or external audits or reviews 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.

Coordinate disruption activities across multiple programs or entities to strengthen processes and identify serious and organised criminals targeting multiple programs. It can also include referrals to law enforcement agencies for those groups that reach the threshold for complex criminal investigations.

Related Fraudster Personas

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