James Tebbs James Tebbs is a Senior Managing Director at Ankura and leads the firm’s risk, forensics and compliance team in the Middle East. He has over 20 years’ experience in fraud prevention, detection and investigation, including 10 years in the Middle East. Kassem Younes Kassem Younes is a Senior Managing Director at Ankura in Riyadh. Kassem’s experience covers a variety of cases including corruption, money laundering and asset misappropriation and he has appeared on several occasions as an expert witness. Contact James Tebbs Senior Managing Director, Dubai T: +971 (0) 4 381 9000 Main Kassem Younes Senior Managing Director, Riyadh T: +966 11 261 1522 www.ankura.com provides a wealth of information on individual cases and the crystallisation of perceived risks, often allowing senior leaders to see their organisations from a new perspective. Recommendation and Reporting No investigation can be complete without detailed and clear reporting and clear recommendations. Always consider two key outputs: what controls have failed (or been circumvented) in allowing this fraud to happen, and where else in the organisation the same scheme might be possible. Actively answering both of these questions can then complete the ‘cycle’ and feed back into enhanced controls design and monitoring. The above steps really do apply to any business, of any size. The cycle is designed not to demand more resources, but to ensure that resources are efficiently allocated and focused on the most relevant activities. As highlighted, whilst this is presented through an anti-fraud lens, the results should provide far more commercial value. What can we expect to see in the future? As a wise colleague once pointed out, there has been no ‘outbreak of honesty’. The human psychology of fraud is well documented and will likely not change. Our advice therefore is clear – focus on your risk assessment and focus on the cycle. There are, however, developments in anti-fraud which are bearing fruit. Perhaps the most effective of these, outside of individual organisations, is the growing tendency for cooperation amongst public and private sector organisations. Examples of this include: • In the Kingdom of Saudi Arabia, the central bank has recently inaugurated its Joint Operations Centre to combat financial fraud, involving all Saudi banks, tasked with following up and monitoring cases of financial fraud5. • In the UAE, the Financial Intelligence Unit has published useful guidance on fraud typologies and trends which provides specific information organisations can incorporate into their own risk assessments. These examples demonstrate the willingness and ability of government bodies to engage with the private sector to combat fraud. Whilst further cooperation is undoubtedly needed, these initiatives demonstrate a state- and global-level commitment to working together to combat fraud. Concluding What should we take from this? Whilst fraud does continue, and new attack vectors develop every day, anti-fraud activities can be efficient and effective and achieve more than just anti-fraud at the organisational level. With the right collaboration at an organisation and state-level, moving the needle on fraud might not be so far from our grasp. © Copyright 2022. The views expressed herein are those of the author(s) and not necessarily the views of Ankura Consulting Group, LLC., its management, its subsidiaries, its affiliates, or its other professionals. Ankura is not a law firm and cannot provide legal advice. THOUGHT LEADER 71 About Ankura Ankura is an independent global expert services and advisory firm that delivers services and end-to-end solutions to help clients at critical inflection points related to conflict, crisis, performance, risk, strategy and transformation. 1 For the purposes of this article, we refer to anti-financial crime as a narrower concept related to AML, CFT, Sanctions compliance and the financing of proliferation. 2 What is the Reshaped Landscape of Fraud Investigation? (lawyer-monthly.com) 3https://www.acfe.com/fraud-resources/fraudrisk-tools---coso 4Including the ACFE/COSO anti-fraud framework referenced above 5Saudi Central Bank governor launches operations center to combat financial fraud (arabnews.com)
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