6 Roles to Consider for Your Fraud Investigation Team
During fraud investigations, it’s not uncommon for security teams to work with the organization’s internal audit team.
“It might be that they’re going to tag-team it and internal audit is going to do the forensic accounting side of the investigation and work with the security folks to do the interviews or the physical searches of the workplace, or they’re going to have the security people access surveillance footage,” says Mason Wilder, CFE, research director for the Association of Certified Fraud Examiners (ACFE).
The ACFE provides guidance in its Fraud Examiners Manual about establishing an investigation team, planning an investigation, and establishing predication.
These are six roles that should be considered for the team.
Auditors. Auditors are experts in evaluating financial records and reports to ensure they are both accurate and compliant with laws and regulations. They are often relied upon during fraud investigations to make sense of how the scheme was carried out from an accounting point of view.
Legal representation. In-house or external counsel can assist with preserving the confidentiality of the investigation and of the individual or team members being investigated. Counsel can also provide guidance on next steps if the organization is subject to regulations that require disclosures of a fraud investigation.
Human Resources. HR team members can help investigators navigate employment policies that an individual may have violated to carry out fraud. HR can also provide guidance on expectations of privacy for employees for electronic searches or physical searches as part of the investigation.
SMEs. Some investigations may require specialized knowledge, such as an understanding of cryptocurrency. Existing team members may have this knowledge, or the team may need to be expanded to include a subject matter expert (SME) with that skill set—including by contracting an external expert.
Interpreters. If an investigation is likely to span several branches of a global organization, the team may look to bring on an interpreter to act as an official translator for interviews or documents.
Investigators. Internal or external investigators should be on the team to carry out the various facets of the investigation, from establishing predication to conducting interviews to writing a final report of their findings.
For the investigators themselves, Wilder adds that it is important to make sure there are no conflicts of interest between those conducting the investigation and the subjects of the investigation.
“If they work in the same department or something, that can be tricky because you don’t want somebody on the investigation team to have a close relationship with the subject,” Wilder says. “It’s just like a judge recusing themselves from a court case or something because there’s a conflict of interest. You have to be careful about that.”
Megan Gates is the senior editor at Security Management. Connect with her at [email protected] or on LinkedIn.
