Penalties for fraud and non-compliance

Penalise customers, staff or third parties that commit fraud or do not comply with rules, processes and expectations.

This control targets both internal and external fraud risks. 

Examples

Examples of this control include: 

  • 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 or terminating staff for misconduct or fraud
  • penalties for contractor misconduct or unreasonable failures to meet contract obligations.

Risks from control gap

A lack of penalties for fraud and non-compliance can lead to:

  • individuals not being deterred from committing fraud
  • fraud increasing over time
  • repeated or systemic non-compliance or criminals reoffending.

Assessing effectiveness

Methods to evaluate the effectiveness of this control include:

  • reviewing the results of compliance reviews or fraud investigations to confirm that penalties are:
    • enforced, e.g. debts raised, termination, 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 who need to know, e.g. other departments are notified of serious or organised fraud, or staff or contractor terminations for fraud or misconduct
  • analysing statistics and reports on repeated non-compliance or criminals reoffending
  • confirming that controls are in place to disrupt repeated non-compliance or criminals reoffending.

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 deceiver

The enabler

The exploiter

The fabricator

The impersonator

The organised

 

Download the complete fraud control catalogue

Explore a range of controls that can be put in place to reduce the risk of fraud happening in your organisation.

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