Penalties for fraud and non-compliance
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
- information not being shared about individuals who commit fraud.
How you might apply this countermeasure
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
- penalties for contractor misconduct or unreasonable failures to meet contract obligations.
How to check if your countermeasures are effective
To measure the effectiveness of this type of countermeasure
- review the results of compliance reviews or fraud investigations of this specific or similar type. Confirm that penalties are:
- enforced, e.g. debts raised, termination, demotion, prosecution
- appropriate for the type of fraud
- consistent across similar cases
- recorded against the customer, vendor, staff member or contractor records
- reported on
- shared with other parties with a need-to-know, for example, other departments are notified of:
- serious or organised fraud
- 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.
This type of countermeasure is supported by: