david hicks, kpmg, counter fraud
DESCRIPTION
David Hicks, KPMG, Counter FraudTRANSCRIPT
“You sir, are a fraud!”
12 March 2012
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2© 2012 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.
Agenda
■ How much does fraud cost?
■ Current and emerging fraud types
■ Profile of a fraudster
■ What can you do to manage fraud?
3© 2012 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.
Quiz – famous alleged fraudsters
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UK Fraud Annual Comparison
0
60
120
180
240
300
360
£0
£250
£500
£750
£1,000
£1,250
£1,500
£1,750
£2,000
£2,250
£2,500
£2,750
£3,000
£3,250
£3,500
£3,75019
87
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
Value £m No. of Cases
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0
60
120
180
240
300
360
£0
£250
£500
£750
£1,000
£1,250
£1,500
£1,750
£2,000
£2,250
£2,500
£2,750
£3,000
£3,250
£3,500
£3,75019
87
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
Value £m No. of Cases
5
UK Fraud Annual Comparison – Key events
1992 -MAXWELL
1993 - BCCI
1998 –PETER YOUNG
2005 – RBG RESOURCES
2006 –IMPERIAL
2011 –UBS
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How much does fraud cost?Rising Cost of Insurance Fraud
Source: Association of British Insurers and National Fraud Authority
Insurance Fraud 2006-2011
0
0.5
1.0
1.5
2.0
2.5
2006 2008 2010 2011 (estimated)
Insu
ranc
e Fr
aud
(£ b
illio
n)
Year
7© 2012 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.
How much does fraud cost? Impact of the Recession on the Insurance Industry
Recession
Key Indicators■ An increase in very amateurish claims
■ An increase in the proportion of ‘suspect’ claims
■ An increase in the proportion of claims referred to investigation that are proven to be fraudulent
■ An increase in calls to the Insurance Fraud Bureau’s (IFB) ‘Cheatline’
■ An increase in ‘walk-aways’
Changing Behaviour■ The economic climate could be
creating a more lax attitude to fraud
■ RSA research in March 2008 showed 3.6 million Brits think it’s wrong to lie on an insurance claim
■ In January 2009 they found that 4.7 million do not think making a fraudulent insurance claim is wrong
Impacts of Cuts■ Police resources are set to decline
over the next few years and in particular resources dedicated to financial crime
■ An erosion of middle management
■ This necessitates a much greater need for the industry to be vigilant towards fraud going forward
Motivators■ Desperation and ‘Lifestyle’ fraud
■ Financial difficulties is naturally a key motivator
■ Excessive pressure from within your organisation
Source: Association on British Insurers 2009 Research Brief, RSA Research (2008, 2009)
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Current and emerging fraud types Common types of Insurance Fraud
■ Non-disclosure fraud
■ False claims
■ Claims overstatement
■ Duplicate claims
■ ‘Ghost’ brokers
■ Supply-chain fraud
■ Internal fraud
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Profile of a fraudsterExternal fraud: Example
■ Organised Crime Groups (OCGs) are collaborating with a growing number of professional enablers – including doctors, lawyers and vets – who are all benefitting from advances in technology to widen their fraud operations
■ One typical example is a Staged Accident, where two or more individuals deliberately crash their vehicles into each other, resulting in various claims. (Cash for Crash)
Staged Car Accident
Accident Management Company
Helps stage accident
Garage and EngineerOvercharge for vehicle parts
Recovering CompanySupplies damaged car for staged accident/provides invoice for recovered car
Salvage CompanyUnderpays insurer for scrap
metal from cash
False VictimSolicitorRepresents ‘victim’
Collusive DoctorSupports alleged injury
Medical Treatment ServiceProvides treatment for non-
existent ailments
Credit Hire CompanyClaims to provide “victim”
with substitute car
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Profile of a fraudsterInternal
Source: KPMG Report ‘Who is a Fraudster’ June 2011
■ 36 to 45 years old
■ Holds a management position within the finance function or in a finance-related role
■ Has been working for the same company for more than ten years
■ Commits fraud against his own employer
■ Operates in collaboration with other offenders
■ Male
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Profile of a fraudsterThe Fraud Triangle: Internal fraud
Opportunity
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Profile of a fraudster Fraud triangle: Pressure
Debts
Meet budgets/expectations
Coercion or blackmail
Family pressures ‘I need the Money’
Addiction –drink, drugs
Illness
‘Results at any cost’
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Profile of a fraudster Fraud triangle: Opportunity
Poor controls/lack of monitoring
Abuse ofauthority
Lack of segregation
of dutiesLack of effective
oversight/resource
Fraud can be hidden in complex
transactions
Exploitingerrors
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Profile of a fraudster Fraud triangle: Rationalisation
‘They do not pay me enough!’
‘It’s only a small amount’
‘They can afford it’
‘It’s a victimless crime’
‘Rules are madeto be broken’
‘Everyoneelse does it’ ‘Who cares?’
‘It’s a cost of doing business’
‘I’ll never get caught!’
‘I’m the boss!’
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Profile of a fraudster Warning signs – Accounts manipulation / Fraudulent Financial Reporting
Remote operations
Multiple banking
arrangements
Related party arrangements
Complex corporate structures
Profit warnings / credit warnings
High management
turnover
Results exceed market trend
Cash / funding gap
Unique products – unique risks
Aggressive accounting
policies
Highly-leveraged rewards
Aggressive forecasts
High hope valueDeclining industry / earnings
High analyst or other pressures
Significant director share
sales
Illegal unethical practices
Undue secrecyDominance / lifestyle issues
Lack of trust / poor auditor relationships
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Profile of a fraudster Warning signs – Employee behaviour
Cuts corners or bends the rules!
Vendors and suppliers will not speak to
anyone but this person
Cannot produce notes / records
of business meetings
Personal pay and reward
could be manipulated
Has favourites or is surrounded by
“yes men / women
Ability and performance
not in tune with CV
Bullies or intimidates colleagues
EgotisticOverly secretShifts blame for errors, denies responsibility
Unreliable, prone to mistakes, poor
performance
Stressed, pressurised
Poor motivation or unhappy
Resists or refuses new
positions
Refuses or does not seek
promotion
Rarely takes holidays
Relationship “issues”
Addictive behaviour
Overextended personal finances
Lifestyle / Income
mismatch
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Profile of a fraudster Employee-Related Red Flags: 2010 and 2008
Source: Association of Certified Fraud Examiners (ACFE) ‘Report to the Nations’ 2010
3.6%
4.2%
4.9%
8.7%
6.5%
7.3%
7.9%
6.8%
13.3%
13.6%
17.1%
20.3%
15.2%
18.7%
34.1%
38.6%
4.6%
5.1%
5.6%
6.3%
7.5%
7.9%
9.3%
10.2%
11.9%
14.1%
17.6%
19.2%
22.1%
22.6%
36.4%
43.0%
0.0% 10.0% 20.0% 30.0% 40.0% 50.0%
Complained about lack of authority
Excessive family/peer pressure for success
Instability in life circumstances
Past legal problems
Excessive pressure from within organization
Complained about inadequate pay
Past employment-related problems
Refusal to take vacations
Addiction problem
Irritability, suspiciousness or defensiveness
Divorce/family problems
Wheeler-dealer attitude
Unusually close association with vendor/customer
Control issues, unwillingness to share duties
Financial difficulties
Living beyond means
Percent of cases
Beh
avio
ral r
ed fl
ag
2010 2008
Percentage of red flags displayed by perpetrators of fraud according to according to members of the Association of Certified Fraud Examiners (ACFE)
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What can you do to manage fraud? How do you prevent and detect fraud?
Control Preventative /Detective
Example
Effective systems and controls
Preventative ■ Non disclosure of details – Motor and personal details are put through the CUE system to check previous claims history
Audit and Assurance Detective ■ Audits of underwriting/claims function
Segregation of duty Preventative ■ Cheques are not returned to the claims handler
Data analytics Detective ■ Claims payments just below self-authorisation limit
■ Payments made close to the expiry of a cover
Training Preventative ■ Regular training of fraud coordinators and front office staff
Oversight and Governance
Preventative and Detective
■ Whistleblowing hotline
■ Adequate reporting process in place
Ongoing monitoring Detective ■ Claims which are in a re-opened state at a particular point in time
■ Claims fraud software
Client onboarding Preventative ■ Details captured at application stage to determine whether multiple attempts have been made to lower premium
Information and intelligence sharing
Preventative ■ Sharing of information to wider industry e.g. names of individuals, suspect bank accounts etc. will assist in preventing further frauds and wider criminality
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What can you do to manage fraud? Management’s role in detecting fraud
Occupational frauds are much more likely to be detected by whistleblowing than by any other means
0.8%
1.0%
1.8%
2.6%
4.6%
5.2%
6.1%
8.3%
13.9%
15.4%
40.2%
0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0% 40.0% 45.0%
IT controls
Confession
Notified by police
Surveillance/monitoring
External audit
Document examination
Account reconciliation
By accident
Internal audit
Management review
Whistleblowing
Det
ectio
n M
etho
d
Percent of cases
Source: Association of Certified Fraud Examiners (ACFE) ‘Report to the Nations’ 2010
20© 2012 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.
Future predictions
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Questions?
Thank youDAVID HICKSPartner, Risk Consulting – Financial ServicesEmail: [email protected]: +44 (0) 20 7694 2915
© 2012 KPMG LLP, a UK limited liability partnership, is a subsidiary of KPMG Europe LLP and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative, a Swiss entity. All rights reserved.
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