Focus area · FRD
Fraud exposure by market, sector and process
Fraud risk sits in processes: procurement, sales incentives, expenses, payments and reporting. We show where external conditions and sector patterns raise that risk, and where your own data confirms it.
Fraud against and for the company
Fraud is the focus area closest to day-to-day operations. It covers fraud against the company, such as procurement fraud, embezzlement and payment diversion, and fraud committed for the company's benefit, such as misrepresentation to customers, investors or authorities.
The second category has moved up the agenda. Since 1 September 2025, large organisations can be prosecuted in the UK for failing to prevent fraud by their associated persons. In Germany, supervisory duty and corporate fines under administrative-offence law have long had a comparable effect.
Legal frameworks we map
We map the regimes that apply to your footprint. Typical anchors:
- UK failure to prevent fraud
- Corporate offence under the Economic Crime and Corporate Transparency Act 2023, in force since 1 September 2025 for large organisations, with reasonable fraud-prevention procedures as the defence.
- Germany: StGB and OWiG
- Fraud (§ 263 StGB), breach of trust (§ 266 StGB) and related offences; corporate fines (§ 30 OWiG) and breach of supervisory duty (§ 130 OWiG).
- US fraud statutes and SOX
- Mail and wire fraud, securities fraud and the Sarbanes-Oxley internal-control requirements for issuers.
- EU financial interests
- Directive (EU) 2017/1371 on fraud affecting the EU budget, relevant where you receive EU funding; prosecuted by the European Public Prosecutor's Office (EPPO).
- Local criminal and corporate-liability law
- Fraud offences and corporate-liability regimes of each country in scope.
This is a risk analysis, not legal advice. Where a finding raises a legal question, we say so and you take it to counsel.
What we look at
External analysis
Your exposure as the outside world sees it.
- Fraud cases and enforcement in your sector, per country
- Prevalent typologies per country, e.g. procurement, invoice or reporting fraud
- Cases involving public funding and subsidies
- Cases at your direct competitors
- Rule-of-law indicators, read with their limits
Internal analysis (under NDA)
Your exposure as your own data shows it.
- Internal fraud cases, losses and investigations
- Procurement and payment patterns by country and unit
- Supplier master data and bank-detail changes
- Expense, gift and hospitality patterns
Seven focus areas, mapped against every source we read.
| Module 1 · External analysis | Module 2 · Internal analysis (NDA) | ||||||||
|---|---|---|---|---|---|---|---|---|---|
| Focus area | Law & regulation | Enforcement record | Sector cases | Competitor cases | Indicators | Internal cases | Business partners | Sponsoring, donations, memberships | Gifts & hospitality |
| ABCAnti-bribery & corruption | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Core source |
| AMLAnti-money laundering | Core source | Core source | Core source | Core source | Core source | Core source | Core source | Where relevant | Not used |
| ATRAntitrust & competition | Core source | Core source | Core source | Core source | Where relevant | Core source | Where relevant | Core source | Where relevant |
| FRDFraud | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Where relevant | Where relevant |
| PRVData privacy | Core source | Core source | Core source | Core source | Where relevant | Core source | Where relevant | Not used | Not used |
| EXCExport control & sanctions | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Not used | Not used |
| HRTHuman rights | Core source | Core source | Core source | Core source | Where relevant | Core source | Core source | Where relevant | Not used |
Highlighted row: FRD · Fraud
Typical red flags
- Suppliers whose address, bank account or directors match those of employees
- Purchase orders split to stay just below approval thresholds
- Sales incentives tied to targets that can be met by misreporting
- Frequent changes to supplier bank details
- Revenue, quality or test data adjusted at period end
- Public grants or subsidies with weak reporting controls
- Thin segregation of duties in small subsidiaries far from headquarters
Sources
- Prosecutor and court publications
- Releases of authorities such as the SFO, SEC, EPPO and OLAF
- Studies on fraud typologies by sector, used as context rather than as statistics about you
- Press reporting, cross-checked against primary sources
- Rule-of-law indicators such as the World Justice Project Rule of Law Index, with their limits stated
Every finding in the report carries its source and date.
Typically exposed sectors
Fraud exposure is broad. It tends to be higher where procurement volumes are large and decentralised, where public funding is involved, in healthcare billing, in construction projects and where sales incentives are complex.
A tendency, not a rating. Your actual exposure depends on business model, customer mix and footprint.
In your deliverable
- PDF: a fraud chapter with legal map, typologies per country and sector, cases, red flags and recommended measures
- Heatmap row per country × sector with the likelihood × impact rating
- XLSX: case register, typology table and scoring sheet
- With the internal module: your internal cases and process data set against external patterns
Questions on fraud
Do we fall under the UK failure-to-prevent-fraud offence?
It applies to large organisations as defined in the Act, which can include non-UK companies where the fraud has a UK nexus. Whether you qualify is a legal question. The analysis shows where fraud exposure in your footprint would matter under the offence.
Is this a forensic investigation?
No. We do not investigate individual suspicions. The analysis shows where fraud risk concentrates and what supports that view; findings that need investigation are flagged as such.
Find out where fraud risk concentrates.
Tell us your markets, sectors and the processes you are worried about. We come back with a scope proposal.