Penalties for fraud and non-compliance with rules, processes and expectations are enforced
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:
- Governance, accountability and oversight
- Collaboration with strategic partners
- Legislation and Policy
- Managerial, independent or expert oversight
- Trained fraud analysts and investigators
- Documentation and evidence storage
- Intent to commit fraud can be demonstrated
- Fraud investigations
- Coordinated disruption activity
- Recovery and Debt Management
- Separation and termination processes
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.