Remote but Engaged, internal fraud investigations from home
“How do fraud examiners conduct fraud investigations when they often can’t meet their team members and subjects in person?”
In this article on “FRAUD” magazine, we have some insights of Anthony Campanelli (CPA, CFF and partner at Deloitte), Leah Lane (CFE, Director of TIGI) and Steven Merrill (Chief of FBI Financial Crimes Section).
Campanelli says as the COVID-19 pandemic continues, virtual work and social-distancing orders have made fraud investigations in a remote environment more complex. Some of the hurdles can include identifying signs of verbal or non-verbal deception in interviews; relying on scanned documents instead of originals; working without the ability to “walk the halls” and have impromptu conversations with company personnel.
Merrill says investigators and fraud examiners must contend with the risk that witnesses will record interviews. “As such, each interviewer should be appropriately cautious”.
Lane believes that when people feel like they have no choice or they have a great financial need, they may commit fraud for the first time, which leads to red flags being more important than ever. She says that best practices for getting the most out of remote interviews are, of course, evolving. You must prepare your internal investigation how you are going to present evidence virtually and still be able to observe the interviewee; ensure the interviewee has video and audio capabilities. Have a backup plan in place in case that technology fails.
Campanelli agrees that over-planning is paramount, giving these tips: ensure that the interviewee is on camera and using the best video technology available. Organizing key documents for use and reduce the need to share screens. Assess what could go wrong and how you would react, and finally prepare your steps if your subject confesses during a guilt-confession or admission-seeking interview.
Finally, Merrill says the act of reviewing records has always been best done collaboratively in person by fraud examiners with all parties so they can change information and ask probing questions and that this critical process has been severely impacted without the ability to personally verify comprehension of the materials and verify the records are exactly what is sought.
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