Defined decision-making powers

Clearly define decision-making powers to increase transparency and reduce the opportunity for fraud and corruption.

This control targets internal fraud risks. 

Examples 

Examples of this control include: 

  • financial delegations, e.g. requiring international travel to be approved by a senior employee
  • human resource delegations, e.g. approving leave and entitlements
  • procedures that define who can make decisions, e.g. requiring managerial approval to change a vendor’s bank account
  • clear responsibility for decision making in joint or multiagency programmes.

Risks from control gap 

A lack of clarity for decision-making powers can lead to:

  • high levels of non-compliance or errors due to inconsistent practices
  • common use of shortcuts and workarounds
  • a lack of transparency over actions and decisions
  • poor management of fraud and corruption risks
  • fraudsters not obtaining approval or obtaining approval from someone who is not the appropriate decision maker
  • fraud or corrupt activity going unnoticed or unchallenged
  • unknown and unaddressed systemic fraud or corruption. 

Assessing effectiveness

Methods to evaluate the effectiveness of this control include:

  • confirming that delegation documents exist, are current and comply with relevant legislation[EW3.1][JD3.2], policies and guidelines
  • undertaking testing or a process walkthrough to confirm that processes cannot be avoided[RR4.1] or bypassed when subjected to pressure or coercion
  • reviewing a sample of approval decisions to determine whether processes and workflows are followed on all occasions
  • identifying how the requirement to follow specified decision-making processes are communicated to employees.

Complementary controls

Other capability, prevention, detection and response controls that can enhance this control’s effectiveness:

Related fraudster personas

Types of behaviour this control is designed to mitigate:

The corrupt

The enabler

The exploiter

 

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