In the Foreword to my book, Fighting Fraud and Corruption in the Humanitarian and Global Development Sector, fraud expert Jim Gee mentions the ‘un-virtuous’ circle of fraud detection in the third sector.
I thought I’d draw up what this circle might look like. The starting point, as previous blog posts have mentioned, is that fraud and corruption hide. So, in essence, the un-virtuous circle means that NGOs, nonprofits and charities can lose physical assets, funds, and stock regularly and in potentially significant quantities without any red lights appearing on management’s dashboard. It is fuelled by a fear of the consequences of detection – the potential impact on public reputation, donor relationships, staff morale, and project delivery.
The un-virtuous circle might look like this:
Another way to think of this concealed drainage is like corrosion under your car – unless you go looking for it, you won’t ever realise its presence, scale and danger… until your car falls apart in the middle of the motorway. You may fear the consequences (e.g. costs involved) of detecting the corrosion and needing to deal with it, but these costs in the long run are less than those that the motorway incident might involve.
Concealed drainage vs squeezing every drop from our resources
As public scrutiny of the sector rises, together with increased recognition of the scale of fraud and corruption risk facing such organisations, we need to move to a virtuous circle, fuelled by a desire to secure donor, public and staff trust by evidencing accountability and transparency. A virtuous circle might look like this:
In this circle, global development organisations invest in a counter-fraud framework that detects incidents, allowing them to take an evidence-based approach to developing ever-more effective counter-measures and therefore reduce their exposure to fraud and corruption.
Improving the detection of fraud and corruption
‘But what if my organisation really doesn’t have any fraud?’ one might ask. Possibly, but given the scale and nature of the risk factors affecting humanitarian and global development organisations, wider under-detection is a better explanation of low detection.
A holistic approach means that countering fraud and corruption is not just about detecting suspicious matters, but detection is an important strand. In addition to effective and embedded detective controls (such as inventories and reconciliations), key detective methods for humanitarian and global development organisations should include:
- Clear ‘overt’ reporting mechanisms for staff and third parties to raise concerns with line management;
- Confidential reporting mechanisms for staff and third parties to report with an expectation of confidentiality and safety;
- Dedicated work to build trust in ‘overt’ and confidential systems amongst staff, and to communicate and promote these systems;
- Beneficiary feedback mechanisms;
- The use of electronic systems to identify ‘red flags’, anomalies and patterns;
- Proactive examinations of records (‘fraudits’);
- Information-sharing with third parties, such as other INGOs or information exchange services;
- Methods to provide early-warnings of incidents, or rising risk, in local partners;
- Investment in the wider components (deterrence, prevention, response, strategic management, cultural development, and enabling activities) of a holistic counter-fraud and corruption framework that support the detection agenda.
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