Fraud prevention and an adequate fraud response

Forensic and Integrity services

By: Ariën Oskam

Fraud and corruption are harmful to your business and your stakeholders. Directors and supervisors of organisations are responsible for preventing fraud and responding appropriately to it. Accountants assess organisations on the prevention and management of fraud risks and on the follow-up of fraud incidents. In this article, we highlight the key points from the publications “Measures for fraud risk management for directors and supervisors” and “Fraud response plan” of the Royal Netherlands Institute of Chartered Accountants (NBA), to which we made a significant contribution.
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Fraud and corruption are human work. Preventing them is too.

A good example tends to be followed. The exemplary behaviour of directors, also known as the ‘tone at the top’, and the communication of codes of conduct and social norms are essential to create a culture in which everyone is aware of the importance of doing business honestly. A culture with standards and values and legislation and regulations to be complied with. Employees feel valued through attention to, among other things, their development and appropriate remuneration. This ensures that they carry out their work with satisfaction, promotes positive social control and discourages fraud and corruption.

The Association of Certified Fraud Examiners (ACFE) conducts worldwide research into fraud cases every two years. For decades, this research has shown that most cases of fraud within organisations are brought to light by a tip from an employee, customer or supplier. The most recent ACFE research (2026) once again shows that 43% of fraud cases come to light thanks to a tip. Of these tips, 55% came from employees, 21% from customers, 11% from suppliers and 14% from anonymous whistleblowers. After that, fraud cases come to light as a result of an internal audit (15%) and management review (13%). That is why it is important that directors ensure a culture in which employees, customers and suppliers feel free to report suspicions of wrongdoing. Clear and accessible whistleblowing and complaints procedures are part of this. Unfortunately, whistleblowers still regularly experience negative consequences from their well-intentioned reports. This reduces the willingness to report wrongdoing. Therefore, it is essential that whistleblowers are protected and have the possibility to report anonymously.

Of course, strong internal control, screening of customers and suppliers, increasing fraud awareness among employees and maintaining accurate administration and financial statements remain of great importance.

Responding quickly and appropriately to fraud limits damage

Does good fraud risk management prevent all fraud? Unfortunately not. Measures increase the resilience of an organisation, but do not eliminate all risks. However, they can ensure that fraud is detected at an earlier stage. A quick and appropriate response to fraud limits the damage. But how do you approach this?

A fraud response plan supports directors and supervisors in planning, coordinating and conducting investigations and in taking appropriate measures. Therefore, think in advance, in a calm manner, about the process you will follow in case of suspected fraud and elaborate this in a fraud response plan. This will better prepare you to act quickly and appropriately when fraud occurs. The NBA has published recommendations for directors and supervisors on creating a fraud response plan. Six main themes are distinguished:

  1. Leadership and coordination
  2. Securing data
  3. Investigation of (suspected) fraud
  4. Internal and external communication, including dealing with the media
  5. (Temporary) measures before and during the fraud investigation
  6. Follow-up of the findings of the fraud investigation and the actions to be taken

It is important that every organisation draws up its own fraud response plan. This includes your organisation. Take into account the size and complexity of your business. Also consider the various forms of fraud and their potential impact on the organisation. Fraud by management or the board often has a greater impact than fraud by employees. A fraud response plan helps to apply measures proportionately, depending on the nature and severity of the fraud.

Want to know more?

What should you do if you suspect fraud or corruption within your organisation? What steps should you follow and what should you avoid doing? These are important questions. Read more on our forensic investigation services.

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