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 Decision-making powers are clearly defined

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Summary

Decision-makers are clearly defined, such as through Delegations and Authorisations.

NB: These should be documented in specific instruments or instructions.

Examples

Some examples of this type of countermeasure include:

  • Accountable Authority Instructions and financial delegations (e.g. delegate approval for international travel sits with the Secretary for travel up to $30,000, and the Minister for travel over $30,000)
  • HR delegations for leave and entitlements.
  • Programme procedures define who can make decisions, e.g. bank account changes require approval by a manager or central delegate.

Purpose of this countermeasure

Staff or contractors can abuse their position of trust to process fraudulent requests or claims for themselves or another person. Staff or contractors can also be coerced to process fraudulent requests or claims for another person or entity, e.g. pressured to pay a fraudulent invoice.

Staff or contractors can also abuse their position of trust to access and disclose official information without authority.

Acting dishonestly or influencing a Commonwealth public official to commit fraud are offences under the Criminal Code Act 1995.

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

  • dysfunctional and obscure decision-making processes, and
  • poor management of fraud and corruption risks.

Fraudsters can take advantage of this environment by exploiting weaknesses and avoiding exposure. For example, they may not obtain approval, or may obtain approval from someone who is not the appropriate decision-maker.

Clearly defined decision-making powers increases transparency and reduces the opportunity for fraud and corruption.

Dependencies

This type of control is supported by:

How do I know if my countermeasures are effective?

You can apply the following methods to measure the effectiveness of these types of countermeasures:

  • Confirm instruments of delegation exist and are current.
  • Undertake testing or a process walk-through to confirm that processes cannot be circumvented.
  • Review a sample of approval decisions to determine whether process and workflows are followed on all occasions.
  • Identify how the requirement to follow specified processes and evidence requirements are communicated.
  • Confirm that someone cannot bypass the process when subject to pressure or coercion.

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