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bank fraud forum

Take Time For Lessons Learned

May 14, 2009 by Paul McCormack
3 comment(s)

Bank Fraud Forum would like to welcome guest blogger and regular contributor, Paul McCormack. Paul brings an investigator's perspective to Bank Fraud Forum, having worked in loss prevention for over 14 years in retail banking and other industries. Most recently, Paul managed deposit, check, bank card and internal fraud detection for SunTrust Bank. Welcome Paul, we look forward to your insight! --Read more about Paul's background

During a recession, the pressure or incentive for bank employees to commit fraud can increase significantly. As you read this post, there is a good chance that an employee in your bank is considering whether or not to commit fraud. You do not have to sit back and wait for the fraud to happen!

Consider a recent case involving two employees of a Bank of America subsidiary. The scheme was relatively simple. To commit the fraud, the perpetrators raised the credit limits on client accounts. The funds were then dispersed for the benefit of a third party, obviously without the permission of the client. Both employees pled guilty to conspiracy to commit bank fraud. Total losses from this scheme - $9 million!

As you read about fraud at another bank, consider your bank's operating environment and whether or not the same fraud could be perpetrated by your employees. Like many cases that are reported in the media, not all of the details are available. Filling in the blanks is relatively easy once the major components of the fraud have been identified.

  • Does my bank have technology in place to detect, and flag increases in credit limits and subsequent transactions?
  • Could an employee(s) with my institution adjust credit limits without approval or sign off from their manager?
  • How many employees in my bank have the ability to increase credit limits?
  • Do we have reporting in place to monitor credit limit increases by bank employees?
  • What level of approval is needed to grant an employee the authority to raise credit limits?
  • Were the client statements placed on a "do not mail" list? Does our bank monitor accounts that do not receive statements?
  • Do we monitor the type and number of banks accounts that our employees access?

Once you have fully analyzed the fraud in light of your bank's operating environment, press " and watch the fraud happen at your institution. After " the fraud unfold at your bank, you may find that you do not have the people, processes or technology in place to prevent a similar loss. The next step is to determine how much time, effort and expense would be required to fill the gaps. Once the results of your analysis are finalized, they should be shared with appropriate parties in your bank.

Most importantly, the results should not be filed away and forgotten. As your bank develops and grows, there may be an opportunity to revise a process or purchase technology that can detect or mitigate fraudulent activity.

A fraud at another institution should never be treated as a car accident on the freeway. Drivers slow down, see the accident, congratulate themselves that it's not them, and then accelerate away having almost immediately forgotten what they just witnessed. You can learn from someone else's misfortune by taking the time to ask whether or not your bank is positioned to detect and prevent a similar fraud.


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Recent Comments:

Paul McCormack
May 21, 2009 - 2:48 PM
"@Jake Thanks for feedback. You ask a great question. Bank professionals often talk about the need to develop a "holistic" view of fraud risk. How many banks can say that they have developed a holistic view of fraud risk? How many can tell you what holistic actually means? How about we start with developing consistency in how fraud risk is measured within banks? Even bank industry groups do not always agree on how to measure and assess risk, and they are some of the most experienced individuals that you can meet! There are so many professional certifications that focus or address risk management in their body of knowledge that it is no wonder banks employ so many different approaches. All of these highly educated professionals feel equipped to analyze and comment on bank fraud risk. However, if they were educated on risk from an accounting perspective, they can tend to focus on control remediation, information technology, system access etc. You get the idea. Input from multiple disciplines is crucial in order to develop a bank's approach to fraud prevention. But there needs to be a better way to balance the different views of risk into a more balanced, dare I say "holistic" view (I hate that word). It should never ONLY be about controls, or technology. No one element is ALWAYS more important than any other. Balance is crucial. Not to mention the issues that arise when you add the lines of business in to the discussion. I digress.... "
Compliance Monitoring
January 31, 2010 - 8:08 PM
"they were educated on risk from an accounting perspective, they can tend to focus on control remediation, information technology, system access etc. You get the idea. "
Jake
January 31, 2010 - 10:15 PM
"Excellent points, worst case scenario, don't repeat the sins of your peers. How do we take it one step further though, and turn these lessons learned into a fundamental understanding of systemic risk to advance further down the "prevention" continuum? "