
Егор Мисюра
It is cheaper to prevent fraud than to investigate it and then attempt to recover losses through the courts. In some cases, the scale and financial impact may prove completely insurmountable for a company and jeopardise its very survival. Therefore, the primary focus in medium and large enterprises should be on establishing a structured, risk-based system that integrates corporate governance, internal controls, technology and a culture of integrity amongst staff. At the same time, whilst emphasising the prevention of misconduct, this also ensures an appropriate operational response, including the investigation of such incidents and the minimisation of losses.
Any modern anti-fraud system is tailored to a specific business, but in most cases they contain a number of essential elements, which are briefly described below.
Effective corporate governance and ‘tone at the top’
Fraud prevention starts with the company’s leadership. The board of directors and senior management must clearly demonstrate zero tolerance for fraud, bribery and corruption. This includes:
- active oversight by the board of directors of fraud and ethical risks;
- clear allocation of responsibility for compliance and internal control functions;
- integration of fraud risks into the overall corporate governance framework.
A strong ‘tone from the top’ sets expectations and influences the behaviour of employees at all levels of the organisation.
Fraud risk assessment
Organisations should regularly conduct a documented fraud risk assessment to identify and prioritise areas of heightened risk. Best practices include:
- identifying fraud risks across business processes;
- assessing the likelihood and potential damage from possible schemes;
- updating the risk assessment in the event of organisational or regulatory changes.
The results of the assessment should be directly used in the design of controls and the allocation of resources.
A robust internal control system
Well-designed internal controls are a key element in fraud prevention. Key elements include:
- segregation of duties to reduce opportunities for manipulation;
- authorisation and approval procedures for high-risk transactions;
- reconciliations, monitoring and reporting of discrepancies;
- clear documentation and audit trails.
Controls must be practical, consistently applied and regularly tested.
Policies, procedures and code of conduct
Clear and accessible policies form the foundation of the compliance system. Best practice involves:
- a comprehensive code of conduct covering fraud, bribery and conflicts of interest;
- detailed procedures for high-risk areas, such as procurement, payments, gifts and entertainment expenses;
- regular review and updating of documents to reflect changes in risks and legislative requirements.
Policies must be applied consistently to maintain trust and credibility.
Channels for reporting breaches (whistleblowing)
An effective whistleblowing system is one of the strongest deterrents to fraud. Best practices include:
- confidential and, where permitted by law, anonymous reporting channels;
- protection of whistleblowers from retaliation;
- independent investigation and follow-up procedures.
Employees and third parties must trust the system and be confident that reports will be dealt with appropriately.
Training and awareness-raising
Regular training reinforces expectations and raises awareness of fraud risks. Effective programmes:
- are tailored to roles, risk levels and job functions;
- use practical examples and real-life scenarios;
- are regularly updated and supported by systematic communication.
Training helps employees recognise warning signs and understand how to act in problematic situations.
Managing risks associated with third parties
Many cases of fraud and corruption involve counterparties and third parties in general. Best practices include:
- risk-based vetting of counterparties, agents and partners;
- contractual safeguards, including the right to audit and terminate the contract;
- ongoing monitoring of third-party activities and payments.
Controls relating to third parties must be integrated into the overall compliance framework.
Use of data analytics and technology
Technology enhances the ability to prevent and detect fraud at an early stage. Leading organisations:
- use data analytics to identify anomalies and suspicious patterns;
- automate controls in processes involving high transaction volumes or increased risk;
- integrate fraud monitoring with internal audit and compliance functions.
Technology should complement, not replace, professional judgement.
Incident response and continuous improvement
Even the most effective systems cannot completely eliminate fraud. Therefore, any anti-fraud system must include:
- clear investigation and escalation procedures;
- consistent disciplinary and corrective measures;
- root cause analysis to strengthen controls and prevent recurrence of breaches.
Lessons learnt must be taken into account in subsequent risk assessments and improvements to the control system.
Conclusion
First-class fraud prevention systems are comprehensive and dynamic in nature and deeply embedded in the organisation’s culture. A combination of effective corporate governance, internal controls, technology and ethical leadership enables organisations to significantly reduce the risk of fraud and demonstrate their commitment to integrity and compliance. All these measures not only minimise damage to companies but also have a positive impact on their reputation, thereby ensuring their success and the achievement of their objectives.
Egor Misiura, Partner CRIDexperts.srl
cridexperts.com









