airline fraud survey 2006. 8 november 2006 iaaia conference – goa, india rania bejjani

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Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

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Page 1: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 2006.8 November 2006

IAAIA Conference – Goa, India

Rania Bejjani

Page 2: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 20062 ©2006 Deloitte & Touche LLP. Private and confidential

Airline Fraud Survey 2006Overview

Survey background and participants

Key findings

Recommended actions to reduce fraud

Questions and answers

Page 3: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential3 Airline Fraud Survey 2006

Survey background and participants

Page 4: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 20064 ©2006 Deloitte & Touche LLP. Private and confidential

Airline Fraud Survey 2006Objectives

Our objectives were to:

understand fraud risks and how these are impacting the airline industry around the world

capture the root causes airlines believe are driving certain types of fraud

consider trends of fraud since the last survey in 2000

flag changes and schemes which have been found to help reduce or mitigate these risks

inform the airline industry of the risks it faces, share lessons learnt and promote a more secure and controlled business environment

identify the key step or steps all airlines need to take to address fraud

Page 5: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 20065 ©2006 Deloitte & Touche LLP. Private and confidential

Airline Fraud Survey 2006Methodology

Key steps included:

Survey questions were pulled together by Deloitte and the IAAIA building on the 2000 IATA/IAAIA survey

Confidential personal invites were sent out to Heads of Internal Audit or Finance Directors (for smaller airlines) to nearly 180 airlines worldwide

Responses have been summarized on an aggregate, collective no-name basis and confidentiality has been maintained at all times

Page 6: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 20066 ©2006 Deloitte & Touche LLP. Private and confidential

Who participated? Airlines from across the 5 continents

Americas 17%

Africa 7%

Europe 44%

Middle East 10%

Pacific 10%

Asia 12%

Network carriers 76%

Low cost carriers 17%

Charter carriers 7%

Page 7: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 20067 ©2006 Deloitte & Touche LLP. Private and confidential

Gross Revenue - USD Mil

Minimum 30Maximum 20,712Average 4,442

Participants’ demographics: How do you compare?

Revenue distribution

Number of employees Fleet

< 2,000 employees 24% < 50 aircrafts 49%2,000 - 4,999 26% 50 - 99 17%5,000 - 9,999 17% 100 - 199 15%10,000 - 19,999 12% 200 - 999 17%> 20,000 21% 1000 & more 2%Total 100% Total 100%

Average 13,707 Average 127

In 2000, average employees was: 9980 Average Gross Revenue was: USD 1.9bn

< USD 100M5% USD 101M -

1000M34%

USD 1001M - 2500M22%

> USD 4500M27%

USD 2501M - 4500M12%

Page 8: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential8 Airline Fraud Survey 2006

Key FindingsOverview

Page 9: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 20069 ©2006 Deloitte & Touche LLP. Private and confidential

Airline Fraud Survey 2006Key findings

Fraud related loss increased 5 fold since 2000: On average each airline suffered at least USD 3M in 2006

External fraud is by far greater than internal fraud

Credit card fraud is the single most prevalent and costly fraud scheme costing every airline on average nearly USD 1M

99% of technology fraud relates to poor IT security

Page 10: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200610 ©2006 Deloitte & Touche LLP. Private and confidential

Airline Fraud Survey 2006Key findings - cont’d

90% think fraud will increase or at least remain the same in 2007

Over 60% have no anti-fraud programmes, do not perform risk assessments and do not track or record fraud

60% rely on IA as a solution to fraud yet airlines have smaller IA teams than other industries

31% discover fraud “by accident” and 45% are informed by external parties

Page 11: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential11 Airline Fraud Survey 2006

Key FindingsA closer analysis

Page 12: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200612 ©2006 Deloitte & Touche LLP. Private and confidential

Number of Cases USD Mil Impact

2000 2006 2000 2006Average

per airline N/A 446 0.6 3.3

How much does fraud cost you?

Have you experienced fraud Yes No

during the last 12 months? 79% 21%

Estimated loss across the industry is USD 600M

On average: Fraud related loss per airline has increased 5 fold since

2000 Every airline has suffered in 2006 a loss of at least USD 3M

Page 13: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200613 ©2006 Deloitte & Touche LLP. Private and confidential

External fraud is by far greater than internal fraud in volume and impact

External versus internal fraud

Number of Cases USD Mil Impact

Internal External Total Internal External TotalAverage

per airline 33 413 446 0.4 2.9 3.3

Page 14: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential14 Airline Fraud Survey 2006

What are the most common and most costly fraud schemes?

Page 15: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential15 Airline Fraud Survey 2006

External fraud

Page 16: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200616 ©2006 Deloitte & Touche LLP. Private and confidential

External fraud schemes – Survey findings

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Page 17: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200617 ©2006 Deloitte & Touche LLP. Private and confidential

External fraud schemes – A closer analysis

If we exclude those schemes affecting one airline only, what are the most significant external frauds affecting all airlines?

Credit card fraud: 60% of external fraud related losses relate to credit card abuse

33% of respondents have experienced credit card fraud

Related losses nearly average USD 1M per airline, that’s an estimated at least USD100M across the industry

Technology and web-based fraud: 17% of external fraud losses relate to technology and the web

26% of respondents have suffered USD 10.2M in total

Third party providers’ fraud: 17% of external fraud losses relate to third party providers

10% of respondents have suffered USD 9.3M in total

Credit card fraud is the most prevalent and costly fraud scheme

Page 18: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200618 ©2006 Deloitte & Touche LLP. Private and confidential

56%36%

2%

5%

-

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

2,000,000

Europe Americas Africa MiddleEast

Asia Pacific

0%

10%

20%

30%

40%

50%

60%

Average USD cost per airline % of USD cost per location out of total

Understanding credit card fraud

Credit card fraud related average 2000 2006

loss per airline in USD 96k 854k

For large airlines, average cost is USD 2.5M each In Europe and US, average cost is USD 1.5M per airline

Analysis by Gross Revenue Analysis by location

8% 5%

11%

76%

-

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

< USD 100M USD101M - 1000M

USD1001M - 2500M

USD2501M - 4500M

> USD4500M

0%

10%

20%

30%

40%

50%

60%

70%

80%

Average USD cost per airline % of USD cost per revenue bracket out of total

Type % of Total Average USD

Network Carrier 79% 880,157

Low Cost Carrier 21% 1,101,286

Chartered Carrier 0% 100

Total 100% 854,150

Page 19: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200619 ©2006 Deloitte & Touche LLP. Private and confidential

Technology and web based fraud

All respondents believe that technology surpassing current controls in place is a key driver of fraud

A third nearly have experienced some form of technology fraud costing USD 10.2M

In 2006, 67% of respondents think additional fraud risks have been taken by their airline because of new technology, compared with 44% in 2000

Contributing to

99% of technology fraud (in volume and USD impact) relate to “Internet payment fraud”

Is your IT security not robust enough?

Credit card fraud related loss Average per airline: USD 1MEstimate across industry: USD 100+M

Page 20: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200620 ©2006 Deloitte & Touche LLP. Private and confidential

Third party fraud – What are the common schemes and who are the perpetrators?

8 types of fraud were considered. Below are the top 3:

Other types of fraud reported included theft of airline goods / services and the use of declined credit cards

Types of frauds perpetrated

10 different outsourcing / service providers were considered. Below are the top 3:

Other includes “travel agents” and “advertising agencies”, which were not part of the original 10

Perpetrators of fraud

Billing for services not

rendered75%

Incorrect pricing11%

Double billing14%

20 ©2006 Deloitte & Touche LLP. Private and confidentialAirline Fraud Survey 2006

Other 1%

In flight service

providers 86%

Ground handlers

13%

Page 21: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200621 ©2006 Deloitte & Touche LLP. Private and confidential

External fraud schemes – Summary comparison with 2000

In 2000, 3 most common and costly external fraud schemes were: Tariff abuse Ticket theft Credit card fraud

In 2006, 3 most common and costly internal fraud schemes are: Credit card fraud Technology and web-based fraud Third party providers’ fraud

The fraud profile has changed since 2000: Credit card fraud has significantly increased in volume

and costs Ticket theft, tariff abuse and counterfeit tickets have

been experienced by fewer airlines Technology effect is more evident

Page 22: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential22 Airline Fraud Survey 2006

Internal fraud

Page 23: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200623 ©2006 Deloitte & Touche LLP. Private and confidential

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Internal fraud schemes – Survey findings

Page 24: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200624 ©2006 Deloitte & Touche LLP. Private and confidential

Internal fraud schemes – Summary comparison with 2000

In 2006, the 3 most common internal fraud schemes are: Frequent flyer abuses Inventory theft Cargo theft

In 2006, the 3 most costly internal fraud schemes are: Diversion of revenue Frequent flyer abuses Abuse of passenger personal

details

How does that compare with the 2006 survey?

In 2000, the 3 most common internal fraud schemes were: Cargo theft Ticket theft Expense account fraud

In 2000, the 3 most costly internal fraud schemes were: Payroll theft Cargo theft Ticket theft

Frauds relating to frequent flyer and passenger personal details abuses are on the increase

Page 25: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200625 ©2006 Deloitte & Touche LLP. Private and confidential

In progress

66%

No13%

Yes 21%

Compliance with Payment Card Industry standards

33% of respondents have experienced external credit card frauds costing them USD 35M

20% of respondents have experienced internal abuse of passengers’ personal details costing them USD 3.5M

7% have experienced instances where their employees stole the identity of their passengers

24% are not aware of the new Payment Card Industry (PCI) standards by credit card companies

Are the “aware” airlines compliant with the new PCI standards?

Page 26: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential26 Airline Fraud Survey 2006

Who is more exposed to fraud?

Page 27: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200627 ©2006 Deloitte & Touche LLP. Private and confidential

0

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Does size matter?

Company size

Number of External Fraud Cases

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USD 101M - 1000M 13%

USD 1001M - 2500M

7%

Number of Internal Fraud Cases

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USD 101M - 1000M 20%

> USD 4500M61%

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Page 28: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200628 ©2006 Deloitte & Touche LLP. Private and confidential

681

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Asia

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Total

Average number of internal fraud

cases per airline

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are more exposed to internal fraud then their counterparts in other parts of the world

European and Asian airlines experience significantly more external fraud

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Average number of external fraud

cases per airline

Page 29: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200629 ©2006 Deloitte & Touche LLP. Private and confidential

Does your business model affect fraud exposure?

41 9

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Network Carriers Low Cost Carriers Charter Carriers

Low Cost Carriers are significantly more exposed to external fraud

Page 30: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential30 Airline Fraud Survey 2006

What are the expectations for fraud in 2007?

Page 31: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200631 ©2006 Deloitte & Touche LLP. Private and confidential

0% 20% 40% 60% 80% 100%

Changes in routes flown

Complex fare structures

Economic pressure

New products not regulated

Staff reduction

Technology surpassing controls

Weakening of society values

Organized crime

Resources allocated to fraud control

Strongly agree Agree Strongly disagree Disagree

Less Same More

10% 49% 41%

In comparison to 2006, fraud occurrences in 2007 will be:

Fraud expectations for 2007Will the occurrences of fraud increase in comparison to 2006?

The main reasons for the expected fraud increase are:

Page 32: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential32 Airline Fraud Survey 2006

How well do you manage fraud risks?

Page 33: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200633 ©2006 Deloitte & Touche LLP. Private and confidential

How well do you manage fraud?

Airlines surveyed confirmed that they have experienced fraud,

yet:

72% do not have a fraud policy

56% do not perform a risk assessment

65% do not have an anti-fraud programme

63% do not have a whistle-blowing mechanism to report fraud

61% do not have a formal system to track fraud

Airlines lack robust and well established anti-fraud programme to prevent, detect, report and track fraud.

This is increasing your risks of and vulnerability to fraud

Page 34: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200634 ©2006 Deloitte & Touche LLP. Private and confidential

How do you assess fraud risk?

39% perform the fraud risk assessment yearly

28% link the risks of fraud identified to anti-fraud programmes and controls

21% follow a set of stringent and consistent procedures when fraud is detected

Only 22% have a good representation from across management, business units and locations when performing the risk assessment

Yes No

44% 56%

Do you perform a regular fraud risk assessment exercise to consider, identify and prioritise risks of fraud?

The risk assessment initiatives being undertaken are not stringent and comprehensive enough to reduce fraud

Page 35: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200635 ©2006 Deloitte & Touche LLP. Private and confidential

14 potential mechanisms that airlines rely on to discover fraud were considered in the survey and here are the most common:

Fraud identification - How did you discover the frauds?

50%

31%

43%

5%

50%

40%

26%

19%

14%

5%

57%

0% 10% 20% 30% 40% 50% 60%

Applying standard internal control procedures

Revenue accounting, special fraud checks

By accident

Investigation by management

External audit review

Internal audit review

Notification by employees

Notification by outsiders

Anonymous whistle- blower hotline

Notification by police

Other

Up to 31% discover the frauds by “accident”

Combined 45% of respondents are informed by external parties

Nearly 50% rely on internal assurance processes such as internal audit and internal control procedures

Page 36: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential36 Airline Fraud Survey 2006

Who is responsible for fraud prevention, detection and

investigation?

Page 37: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200637 ©2006 Deloitte & Touche LLP. Private and confidential

Responsibility for fraud prevention, detection and investigation

In 2006, departments responsible for fraud response have remained overall the same compared with 2000

Prevention Detection Investigation

Internal Audit Revenue Billing Internal AuditSecurity Internal Audit Security

Accounting Security

Revenue Accounting Line Management

IT Security are out of the equation

Page 38: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200638 ©2006 Deloitte & Touche LLP. Private and confidential

Responsibility for fraud prevention, detection and investigation

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Percentage of respondents’ reliance on the following departments for fraud response

At least 60% of airlines rely on Internal Audit to prevent, detect and investigate fraud

Page 39: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200639 ©2006 Deloitte & Touche LLP. Private and confidential

Department: Average number of staff per department

Accounting 130

Fraud prevention 2

Internal Audit 13

Risk Management 3

Legal 12

Revenue accounting & billing 53

Security 33

Responsibility for fraud prevention, detection and investigation

Have your staffing, retention and training been appropriate to meet these challenges?

Average number of total employees 13,707

Ratio of I A resources per 1000 employees 0.914

Page 40: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200640 ©2006 Deloitte & Touche LLP. Private and confidential

How do airlines compare with other industries?

Source of industry figures: The Institute of Internal Auditors' Global Auditing Information Network (GAIN)

Compared with other industries, airlines have smaller internal audit teams

Distribution of I nternal Audit Team Staff Numbers Across I ndustries

I nternal Audit Department Staff Size - Percentage

Industry Group 1 to 10 11 to 25 26 to 50 51 & more Total

Agri/Min/Construction 56% 33% 11% 0% 100%

Petroleum 28% 22% 11% 39% 100%

Wholesale Retail 55% 24% 12% 9% 100%

Chemical / Drugs 56% 24% 8% 12% 100%

Manufacturing 53% 22% 18% 8% 100%

Educational Institutions 86% 12% 2% 0% 100%

Transportation 20% 50% 20% 10% 100%

Communications 43% 19% 19% 19% 100%

Bank / Financial 47% 26% 9% 17% 100%

Util-Gas/Electricity 41% 36% 17% 6% 100%

Insurance 48% 25% 14% 13% 100%

Services 65% 22% 8% 6% 100%Government 40% 25% 19% 16% 100%

Total Universe 54% 24% 12% 11% 100%

Airlines 64% 17% 19% 0% 100%

Page 41: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential41 Airline Fraud Survey 2006

Actions to reduce fraud

Page 42: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200642 ©2006 Deloitte & Touche LLP. Private and confidential

Steps to reduce fraudAre you focusing on the right steps?

Responses from the survey suggest that: improving internal controls increasing reference checks on new employees increased focus by Senior Management on the problem

are considered to be the most effective steps to reduce fraud in the future

Given the findings relating to the most common fraud schemes, how fraud is currently managed and the level

of resources, the above are not enough

Page 43: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200643 ©2006 Deloitte & Touche LLP. Private and confidential

The top 3 steps every airline needs to take to address fraud

Implement a preventative anti-fraud programme Assess fraud risks regularly and link them to controls Define a fraud policy and educate your staff Involve all relevant parties and increase senior management focus

Involve IT Security To address credit card and internet payment fraud

To design improved internal controls to keep up with new technologies

To facilitate compliance with PCI standards

Improve your detective capability Larger and fraud-trained internal audit teams with a wider scope/reach

A whistle-blowing / speaking up mechanism to report fraud internally

A central repository to record, monitor and escalate as appropriate

Page 44: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

©2005 Deloitte & Touche LLP. Private and confidential44 Airline Fraud Survey 2006

Questions and answers

Page 45: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

Airline Fraud Survey 200645 ©2006 Deloitte & Touche LLP. Private and confidential

Statement of Responsibility

DisclaimerDeloitte has made no attempt to verify the reliability of the information or representations provided to us by the organizations participating in the 2006 Airline Fraud Survey. This summary document is limited in nature, and does not comprehend all matters relating to the survey that might be pertinent to your self-assessment. We make no representation as to the sufficiency of this summary for your purposes. 

This document should not be viewed as a substitute for other forms of analysis that management should undertake in order to assess whether their internal controls, anti-fraud program or internal audit strategy are adequate or appropriate for the organization’s purposes. The information in this report is not intended to constitute legal, accounting, tax, investment, consulting, or other professional advice or services. Before making any decision or taking any action which might affect your personal finances or business, you should consult a qualified professional advisor.  

This document is solely for your informational purposes and internal use and you will not disclose it to any other person or entity. This document is prepared solely for presenting the key findings of the Airline Fraud Survey. Therefore you should not, without our prior written consent, refer to or use our name or this document for any other purpose, disclose them or refer to them in any prospectus or other document, or make them available or communicate them to any other party. No other party is entitled to rely on our document for any purpose whatsoever and thus we accept no liability to any other party who is shown or gains access to this document.

THIS SUMMARY AND THE INFORMATION CONTAINED HEREIN IS PROVIDED “AS IS,” AND DELOITTE MAKES NO EXPRESS OR IMPLIED REPRESENTATIONS OR WARRANTIES REGARDING THIS REPORT OR THE INFORMATION. YOUR USE OF THIS REPORT AND INFORMATION IS AT YOUR OWN RISK. DELOITTE WILL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, PUNITIVE DAMAGES OR OTHER DAMAGES, WHETHER IN AN ACTION OF CONTRACT, STATUTE, TORT (INCLUDING, WITHOUT LIMITATION, NEGLIGENCE) OR OTHERWISE, RELATING TO THE USE OF THIS REPORT OR INFORMATION.

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Page 46: Airline Fraud Survey 2006. 8 November 2006 IAAIA Conference – Goa, India Rania Bejjani

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