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Natural or manmade disasters can impact an organisation with little notice. Although not a new concept, a national or global response can attract criminal elements, corruption and organised crime groups where control measures are reduced or dropped to expedite urgent requirements, to protect, preserve or save life.
How does your organisation protect itself from organised crime risk? During the global pandemic and the restriction of movement locally and across borders, criminal groups had to diversify their illicit activities that included moving online to target various aspects of procurement requirement.
SUPPLY CHAIN IMPACT FROM PROCUREMENT FRAUD
As we saw in the global response to the Coronavirus, all sectors were impacted and many organisations have quickly diversified or enhanced their eCommerce capabilities, leveraged digital giants and shortened supply chains to enhance business outputs. Government and healthcare response to this crisis was challenging, and with the limited availability of medical supplies meant an international scramble to obtain the finite quantities of PPE and related medical products.
As countries focused their attention on gaining access to these resources the urgent need for the manufacture and supply of materials from international markets and new vendors gave opportunity for criminal enterprise to maximise their profits when normal guardianship was ignored or omitted. Organised crime groups quickly diversified into online sales and eCommerce using digital giants to sell inferior or counterfeit products, gaining credibility from the site and minimising risk because of sites inability or limitations in detecting criminal enterprises.
Cut the supply chain of procurement fraud by forging strong relationships with trustworthy suppliers
When procurement becomes an urgent requirement, it is not uncommon for organisations to change their procurement approach, dropping or relaxing control measures to expedite delivery and distribution of goods or materials, normal tendering processes are changed to single source and direct award and an organisation's ability to confirm receipt and distribution of materials is limited due to reduction in resources and the need for urgent delivery.
When we initially saw food shortages and empty shelves in supermarkets, we only need to look back a few years at the horse meat scandal and the infiltration of supply chains by organised criminals and the adulteration of meat products. Although not specifically highlighted in the current crisis it is easy to see how supply chains could be compromised.
Initial information from Action Fraud, confirmed 16,352 people fell victim to online shopping and auction fraud, confirming that they received reports of online shopping fraud totalling £16.6 million.
TYPES OF CRIMINALITY
Looking at the current and historical types of criminality or illicit behaviour in such global events, there are many common typologies.
Fake charitable solicitations
Contractor or supply chain fraud
Product substitution & Counterfeit products
Corruption
False invoicing
Fake timesheets & ghost workers
Price gouging
Insurance fraud
Forgery
Theft
Looking at historical disaster events and response, organisations such as The Carnegie Endowment for International Peace reported that during the Ebola crisis in West Africa, the Red Cross estimated that over $6 million of its assistance was lost to fake customs bills, overbilled supplies, and payments to non-existent workers. Other international aid and domestic budgets were likely subject to similar leakage.
In addition to the medical support, in its response to business impact governments also providing financial support to business. When we consider natural disasters like Hurricane Katrina in the USA, it produced one of the most extraordinary displays of scams, schemes and stupefying bureaucratic bungles in modern history, costing taxpayers up to $2 billion.
This type of mismanagement of government funds is not uncommon as we have seen more recently governments losing billions to fraud, as they don't consider fraud controls or the recovery of these funds at the planning stage when there is an urgent need to provide financial grants and support to business.
Criminal enterprises and organised crime groups already have an established supply chain and distribution networks because in the majority of cases is the same one used by legitimate companies, making it very easy to introduce inferior and counterfeit products into legitimate supply chains where organisations are urgently looking for new stock and proper due diligence isn't conducted.
It is also recognised by some of the many online retail and auction sites that identifying and removing fraudulent or counterfeit products from their sales site is challenging. The global threat from counterfeit pharmaceuticals and medical products is significant, in the global drive to obtain medical equipment greater opportunity and profits are available to the criminal.
Interpol said 121 arrests were made related to the seizure of counterfeit medical supplies and medication amid the COVID-19 pandemic. 2,000 online advertisements related to the coronavirus were found, selling a range of illicit medical devices, such as substandard hand sanitizers, unauthorised antiviral medication and counterfeit face masks. About 326,000 packages were inspected and 34,000 unlicensed and fake products were seized, with an estimated value of more than US$14 million, according to Interpol.
RISK PROFILING & MATURITY ASSESSMENT
Understanding the risk that your organisation faces from procurement fraud can be challenging particularly where such a global event hasn’t been planned for that includes the limitation and lack of information and resources, however recognising and planning for this type of event including types of fraud and criminal activity in the short term is the first step in introducing risk mitigation.
As we have touched upon, the variety of criminal behaviour during disaster events can be significant and have a global footprint. Can you identify your current control weaknesses and if a significant event does happen what would be the impact to your current controls and procedures, would be compliance bet set aside or would it be reinforced.
Questions that should be asked include how mature your organisation is when it comes to business resilience and business continuity.
Do you understand and are you able to measure your operational controls, approach and governance.
Is there adequate expertise and capability to mitigate procurement fraud risk within the current operational need.
where a new supplier has to be introduced where there is an urgent need, quality assurance should be a priority to mitigate future risk.
Are procedures introduced and compliance monitoring for direct award procurement for urgent requirements.
Risk profiling and a maturity assessment will reduce future impact that includes illicit activity by criminal groups.
CONCLUSION
To limit future financial loss organisations must take the position that these types of events will happen again and introducing a strategy to mitigate risk to individuals, business and supply chains to ensure organisation and procurement integrity and also that these risks aren't passed on to clients or customers.
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