A Framework for Managing Crime
and Fraud
ASIS European Security Conference & Exhibition
Gothenburg, April 15, 2013
Torsten Wolf
Agenda
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Introduction
•
Economic Crime Landscape
Introduction
About Zurich
Zurich is one of the world’s leading insurance groups, and one
of the few to operate on a global basis. Our mission is to help
our customers understand and protect themselves from risk.
With about 60,000 employees serving customers in more than
170 countries, we aspire to become the best global insurer as
measured by our shareholders, customers and employees.
We help individuals, small- and medium-sized companies and
global corporations around the world understand and protect
themselves from risk by offering a wide range of insurance
products, solutions and advisory services.
Group Security is a trusted advisor of choice, viewed as
business partner with security expertise, providing world- class
service that can adapt at the speed of change.
Group Security is a trusted advisor of choice, viewed as
business partner with security expertise, providing world- class service that can adapt at the speed of change.
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One Group Security acts as a business enabler, taking both preventive and reactive measures in order to secure Zurich’s aspiration of becoming the best global insurer.
We accept responsibility for the security and safety of Zurich employees, assets and activities, protecting them from internal
Introduction
Introduction
Business Protection Model
P e o p le Processes Event Security Security & Safety Governance Economic Crime Prevention & Detection Emergency Management Travel Security Personnel Protection Security Threat Management Governance Quality Business Customer Shareholder Employee Assets Reputation P e o p le N e tw o rk s Processes T o o lb o x T e c h n o lo g y
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Introduction
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Economic Crime Landscape
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Economic Crime Framework
Economic Crime Landscape
Definitions
Exaggerated claims Fictitious claimsClaims
Fraud
Financial
Crime
Economic
Crime
Money Laundering/ Terrorist Financing Bribery/ Corruption
Sanctions
Internal/ employee crime and fraud External non-claims crime and fraud Theft
Economic Crime Landscape
Impact of Economic Crime
Impact on customer including increased premiums Loss of confidence in organization
Damage to reputation and brand Damage to stock value
Possible loss of market share
Closer regulatory focus and possible fines (Regulator) Cost of investigations and new internal controls
Accountability of company senior executives and possible legal action against them
Decline in staff morale Impaired business relations
Economic Crime Landscape
Key players in the insurance industry
Interme-diary Customer Third Party Service Provider Vendor External Party 1 3 Insurance Carrier 2 … Reinsurer Distribution crime
1
Commission fraud Policy fraud Premium fraud Internal crime2
Claims fraud (committed by employee) Salvage Sales incentives Identity crime
3
Surrender fraud•
Introduction
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Economic Crime Landscape
•
Economic Crime Framework
Economic Crime Framework
Mandate
Pressure Rationalization Opportunity
Fraud Triangle
Economic Crime Prevention and Detection,
prevent and detect criminal activities and security incidents to mitigate business
damage from crime. Investigate fraud and security incidents.
Economic Crime Prevention and Detection,
prevent and detect criminal activities and security incidents to mitigate business
damage from crime. Investigate fraud and security incidents.
Investigation Root cause analysis Continuous process Improve control environ-ment Assess
crime risk Response
to incident Identify
crime risk
Crime detection
Governance & Quality People & Networks
Processes & Standards
Economic Crime Framework
Overview
Ethical policy (“Zurich Basics”)
Anti-crime Policy (“Zurich Risk Policy”) Anti-crime guidelines (“Global Security Standards”) Adherence monitoring Site visits Audit reviews Internal Control Framework Process Benchmarking Data mining Reporting of economic crime statistics Escalation of ‘significant’ incidents Zurich anti-crime professionals Internal support External support Peer organizations Communication/ training 1 4 5 7
Toolbox & Technology
Awareness training Fraud Risk Questionnaire Whistleblowing (“Zurich Ethics Line”) Reporting database Web conferences 2 3
Investigation Root cause analysis Continuous process Improve control environ-ment Assess
crime risk Response to incident Identify
crime risk
Crime detection
Economic Crime Framework
Economic Crime Framework
Organizational set-up
Group Security
Governance and leadership
Strategy, policy, framework, and methodology Driving execution
Interfacing with other functions
Countries
Execution of strategy
Implement policy requirements Development support
1
Global Business Solutions Group Security Expertise Center CEO COO Objective settingEconomic Crime Framework
Employee crime awareness training
Execution of local training mandatory Generic all employee training developed
Minimal local adaptation necessary (language) Deployed via HR system (tracking of participation) Option to continue with own solutions
Global training (Zurich Basics) Anti-crime module
Close collaboration with Compliance Participation mandatory
2
Crime awareness training Ethics trainingEconomic Crime Framework
Fraud Risk Questionnaire (1/2)
3
Comprehensive coverage Modular approach
Crime risk scenarios and anti-crime controls
Entity and/ or Business Area level Fully integrated into risk
assessment processes
Leveraging existing risk tools and methodologies
Execution facilitated through guidelines, training and
individual consulting
Continuous enhancement (external/ internal trends, management requests)
Development of new modules Refinement of existing modules
Economic Crime Framework
Fraud Risk Questionnaire (2/2)
3
External observations Internal analysis M a n a g e m e n t R e q u e s t Continuous FRQ enhancementEconomic Crime Framework
Internal Control Framework
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Goal: Strengthen the internal control environment•
Consistent view of crime risks and associatedcontrols
•
Set of minimum controls to address crime andfraud
- Governance, roles and responsibilities - Risk assessment and response
- Collection and reporting of incidents - Investigations
•
Mandatory for all Business UnitsEconomic Crime Framework
Reporting
5
Goal: Transparency of economic crime and crime attempts
Database: Local data entry – central analysis to identify trends
Number of cases, potential loss, actual loss Report shared with governance functions and external auditor
Key findings shared with the members of anti-crime network
Potential financial impact above USD 250,000 Potential reputational exposure for the Group A CEO or a direct report to a CEO
Employee in a control function/ fraud role
Alleged/ actual accounting or financial statement improprieties (regardless of amount)
Systemic occurrence of particular fraud incidents Escalation of single economic
crime incidents
Business
Escalation criteria
Statistics of all incidents Economic Crime Report
Group Security
Group Legal
USD 50k
Economic Crime Framework
Pre-employment screening
6
Key component of effective anti-crime governance framework
Obvious benefits
- best hiring decision
- safe working environment
- avoiding cost of bad hiring decision
Investigations of incidents revealed perpetrators had criminal records
Various practices across the organization; impacted by local laws and regulations
Economic Crime Framework
Monitoring adherence
7
Self assessments
Review of work products
- operational risk assessments - economic crime statistics - investigation reports
Visits to selected countries Policy adherence review
Regular sign-off of Internal Control Framework
Investigation Root cause analysis Continuous process Improve control environ-ment Assess
crime risk Response
to incident Identify
crime risk
Crime detection
Governance & Quality People & Networks
Processes & Standards
Economic Crime Framework
Wrap-up
Ethical policy (“Zurich Basics”)
Anti-crime Policy (“Zurich Risk Policy”) Anti-crime guidelines (“Global Security Standards”) Adherence monitoring Site visits Audit reviews Internal Control Framework Process Benchmarking Data mining Reporting of economic crime statistics Escalation of ‘significant’ incidents Zurich anti-crime professionals Internal support External support Peer organizations Communication/ training
Toolbox & Technology
Awareness training Fraud Risk Questionnaire Whistleblowing (“Zurich Ethics Line”) Reporting database Web conferences
Business added value
Reduced cash outflows Recovery of damages
No bad press hurting reputation
Increased confidence of investment community Lesser attention by regulators
Reduced likelihood of fines Deterrence of crime attempts Positive staff morale
Economic Crime Framework
Added value
Pressure Rationalization Opportunity
