Coordinated disruption activity
Coordinated activity across multiple programs or agencies to strengthen processes and to identify serious and organised criminals targeting multiple programs.
This could involve revoking funding approvals, de-registering businesses and individuals, issuing Commonwealth debt notices, conducting taxation assessments, and referring service providers to state and territory regulators.
It could also include referrals to law enforcement agencies for those groups that reach the threshold for complex criminal investigations.
Purpose of this countermeasure
Serious and organised criminals are using some sophisticated methodologies to target government programs. These include establishing associated businesses to enable fraud (e.g. registered training organisations providing false qualifications) and criminal consultancies teaching others how to defraud programs.
If agencies are not specifically turning their mind to the prospect of well-coordinated, organised crime groups actively exploiting their programs (as opposed to more opportunistic individual cases of fraud), their countermeasures may be inadequate.
Coordinated disruption activity can also dissuade and deter individuals from committing fraud in the first place.
This type of countermeasure is supported by:
- Governance, accountability and oversight
- Collaboration with strategic partners
- Legislation or Policy
- Procedural instructions or guidance
- Managerial, independent or expert oversight
- Decision-making powers are clearly defined
- A specific form, process or system must be used
- Tip-offs and Public Interest Disclosures
- Internal or external audits or reviews
- Trained fraud analysts and investigators
- Fraud investigations
- Documentation and evidence storage
- Quality assurance checks
- Audit logging
- Video or electronic surveillance
- Penalties for fraud and non-compliance with rules, processes and expectations are enforced