Financial Crime World

Fraud Prevention Strategy for Programme Management Structures

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Programme management structures are adopting measures to prevent fraud by reducing the motive, restricting opportunities, and limiting the ability of those committing fraud to rationalize their actions.

Key Initiatives

To achieve this goal, programme management structures have implemented several key initiatives:

  • Set the right tone at the top: Establishing a culture that promotes honesty and integrity from the highest levels.
  • Robust vetting of staff: Ensuring that all staff members are thoroughly screened and cleared before taking on any role in the programme.
  • Appropriate system design and supporting procedures: Implementing systems and procedures that minimize opportunities for fraud and ensure accountability.
  • Effective communication and supervision and review: Regularly communicating with staff, beneficiaries, and other stakeholders to prevent misunderstandings and identify potential issues early.
  • Appropriate training: Providing regular training sessions for staff and beneficiaries on anti-fraud measures and programme rules.
  • Maintaining an effective internal control framework: Establishing a robust internal control system that ensures all transactions are properly authorized, recorded, and accounted for.

Conflict of Interest Declaration

To prevent conflicts of interest, programme management structures require staff to declare their personal interests and any potential conflicts in accordance with the internal rules or code of conduct.

Cooperation with National and EU Institutions

Programme management structures commit to working closely with national and EU institutions/organizations to prevent organized fraud and corruption. This includes cooperation with AFCOS Directorate and OLAF.

Fraud Prevention Measures for Beneficiaries

To prevent fraud at the beneficiary level, programme management structures have implemented several measures:

  • Develop guidelines for beneficiaries with anti-fraud measures: Providing clear guidelines on how to avoid fraudulent activities.
  • Organize seminars and training for staff and beneficiaries: Offering regular training sessions for staff and beneficiaries on anti-fraud measures and programme rules.
  • Draft information material/supporting documents for preventing fraud at beneficiary level: Creating informative materials that help beneficiaries understand the importance of preventing fraud.

Detection and Reporting

Despite best efforts, fraud prevention techniques may not always be successful. Therefore, programme management structures have developed systems to detect potential fraudulent activities in a timely manner:

  • First-level controllers use verification checklists to identify potential fraud indicators: Regularly verifying transactions against established criteria.
  • The Joint Secretariat may detect suspicious fraud during monitoring processes: Conducting regular monitoring and review of programme activities.
  • National Authorities may also detect potential fraud: Working closely with national authorities to identify potential fraudulent activities.

Investigation and Criminal Prosecution

Once a suspicion of fraud is raised, the Managing Authority and respective National Authority must submit the case to the competent authority for investigation and sanctions. Those found guilty of fraud will be prosecuted according to the law.

Recovery of Undue Payments

The recovery of undue payments shall be made according to court decisions or legal acts. Programme management structures shall recover undue payments in accordance with the Memorandum of Understanding signed under the programme.

Follow-up and Learning

Once a fraud investigation is concluded, programme management structures shall conduct a review of processes, procedures, or controls connected to the potential or actual fraud. This ensures that lessons are learned and implemented to prevent similar incidents from occurring in the future.

Output Indicators

The following output indicators will be strictly monitored throughout the strategy implementation:

  • Self-assessment tools permanently updated: Regularly updating self-assessment tools to ensure programme management structures are aware of potential vulnerabilities.
  • Size of evaluation team: Ensuring that the evaluation team is adequately sized and resourced to conduct thorough reviews.
  • Documents/information material regarding fraud for Programme staff and beneficiaries: Providing regular training sessions and informative materials on anti-fraud measures and programme rules.

Monitoring and Evaluation

The monitoring and evaluation of the strategy shall be performed by the Managing Authority, together with the anti-fraud assessment team. This ensures that programme management structures are held accountable for their actions and that the fraud prevention strategy is effective in preventing fraudulent activities.

Reporting a Concern

Individuals may raise a concern or report a suspected fraud or irregularity through various channels. Reports received will be treated confidentially in accordance with programme structures’ internal working procedures.