Anti-fraud policies and procedures make up an essential part of any business’s compliance program. Firm’s have a duty of care to assess the risk of fraud posed to their business and to put processes into place to mitigate these. This article provide information and suggestions for writing an anti fraud policy and the associated fraud response plan template.
What is Fraud?
Fraud is any wrongful or criminal deception, for instance one that is intended to result in financial and/or personal gain. It is carried out with the intention of deceiving others and usually involves falsely representing facts. This can be from the provision of false statements or information or by deliberately withholding essential information. Fraud can be present both internally and externally.
Under The Fraud Act 2006, fraud is defined by 3 specific sections: –
- Section 2 – Fraud by false representation
- Section 3 – Fraud by failing to disclose information
- Section 4 – Fraud by abuse of position
Anti-Fraud Policy Template
A policy statement, purpose and scope should always be included in a policy template. These three areas define what the policy intends to do, why it has been created and who it applies to. A policy is a statement of intent and not a procedural document. Any step by step process should be documented in your anti-fraud procedure template. The policy should list the objectives you aim to meet for fraud prevention. These can include internal objectives such as defining anti-fraud policies and procedures, as well as external objectives for complying with The Fraud Act 2006.
Any employees will use the policy to understand their responsibility to be alert to situations or instances that could give rise to or perpetuate fraud. The content should also note the implication of none compliance.
Anti-Fraud Response Plan Template
Part of your anti-fraud policies and procedures should be an anti-fraud response plan. This document records the process for managing concerns or allegations of fraud within the company. This includes how to raise a concern and how it should be investigated.
Anti-Fraud Policies and Procedures
Know Your Compliance Limited have been providing regulatory compliance templates for over 10 years to more than 8500 organisations. Our Anti-Fraud Policy Pack comes with dedicated templates for policies, procedures, response plans and recording templates to meet The Fraud Act 2006 requirements.