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 Penalties for fraud and non-compliance with rules, processes and expectations are enforced

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Customers, staff or third parties are penalised for fraud or not complying with rules, processes and expectations.


  • Customers receive debts and penalties for fraud and non-compliance.
  • Providers or third parties are issued with penalties for misconduct or fraud.
  • Staff are sanctioned for misconduct, including demotion.
  • Contract managers enforce penalties for misconduct or unreasonable failures to meet contract obligations.

Purpose of this countermeasure

Not enforcing penalties for fraud and non-compliance can lead to persistent or greater levels of fraud.

Fraudsters will be less deterred from committing fraud if penalties are not enforced.


This type of countermeasure 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:

  • Review the results of compliance audits or fraud investigations for fraud 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; and
    • shared with other parties with a need-to-know, e.g. other organisations are notified of:
      • serious or organised fraud, or
      • staff/contractor terminations for fraud/misconduct
  • Analyse statistics on recidivist offending;
  • Confirm that counter measures are in place to disrupt recidivist offending.

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