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Complaints about poor or anomalous outcomes


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Customers, staff and third parties would likely identify anomalous outcomes, such as failure to receive an expected payment, and make a complaint.


Some examples of this type of countermeasure include:

  • A customer can lodge a formal complaint if there are issues with payments or services provided by an agency or provider.
  • A provider can lodge a formal complaint about the conduct or operations of another provider.
  • An unsuccessful bidder can lodge a formal complaint about a procurement decision.
  • A staff member or contractor can make a formal complaint about the workplace or their entitlements.

Purpose of this countermeasure

Someone can provide false or misleading information or stolen evidence of identity to support a request or claim. A staff member can also abuse their position of trust to process fraudulent requests or claims for themselves or another person.

Acting dishonestly and providing false or misleading information to commit fraud are offences under the Criminal Code Act 1995.

Fraudulent activity is less likely to be identified and reported by customers, staff and third parties where the outcome does not cause a noticeable effect.

For example, if a customer is not aware of held Medicare payments on their account, they may not notice if a fraudster diverts those payments to another bank account.


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 that customers, staff or third parties would be able to notice poor or anomalous outcomes.
  • Measure how long it would take to receive a complaint and respond to potential fraud.
  • Confirm that a consistent process exists for making/handling complaints.
  • Confirm that the process for making complaints is easy to locate and use (increasing the likelihood complaints are received and acted upon).
  • Confirm the options for lodging complaints are clearly communicated, e.g. a dedicated phone number is provided.
  • Confirm that complaints are adequately investigated and would identify potential fraud.
  • Confirm that clear processes exist for referring cases of potential fraud for investigation.


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