Case Studies

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Counter Fraud Practitioner Program

Integrity Advisory has been assisting the Attorney General's Department in developing and facilitating a 5 day Counter Fraud Practitioner training program for fraud control officers in Commonwealth government agencies. The program covers counter fraud and corruption frameworks, risk assessment practices, data analytics, pressure testing and developing counter fraud investment cases. 

For several years Integrity Advisory has assisted the Royal Australian Mint with the following counter fraud and corruption services:

• Conducted fraud and corruption risk assessments across all aspects of the Mint’s operations, including retail, finance, payroll, coin design and manufacture, and coin dispatch.
• Developed comprehensive Fraud, Bribery and Corruption Control Plans, articulating the Mint’s approach to fraud prevention, detection and response.
• Developed an Anti-Bribery and Corruption Policy and associated procedures.
• Developed and implemented fraud controls to minimise the risk of financial losses from credit card fraud in the Mint’s face-to-face, online and call centre retail operations.
• Delivered Anti-Bribery and Corruption Training to staff.

Fraud Risk Assessment Leading Practice Guide

Integrity Advisory assisted the Attorney General's Department in the development of a Leading Practice Guide in Fraud Risk Assessment. The guide provides key principles and methods taken from leading practices across public and private sectors. The guide assists fraud specialists, government officials and senior leaders better understand the fraud risk assessment process and how these assessments can benefit their entity.

To complement the guide, Integrity Advisory also developed a Strategic Fraud Profiling Tool which helps agencies identify those areas at higher risk of fraud. This will enable fraud control officers to a schedule fraud risk assessments on a prioritised basis.

Integrity Advisory was engaged by the Department of Social Services to develop an Enterprise Compliance Framework which articulated the Department’s governance, structural and operational arrangements for consistent and effective compliance management across its various programs and service lines. The framework was required to be based on best practice standards and principles, including:

• Australian Standard 3806-2006 – Compliance Programs
• AS/NZ ISO 31000-2009: Risk Management – Principles and Guidelines
• Commonwealth Fraud Control Framework
• Commonwealth Procurement Rules
• Commonwealth Grant Guidelines
• ANAO Better Practice Guide – Administering Regulation
• ANAO Better Practice Guide - Implementing Better Practice Grants Administration

In conjunction with the Canberra Institute of Technology (CIT Solutions), Integrity Advisory was responsible for developing and delivering a comprehensive 10-day training program for the Department of Human Services (which included Centrelink, Child Support Agency and CRS Australia). The program provided participants with a Diploma in Government (Fraud Control) and was specifically tailored to assist personnel in the Business Integrity Division in understanding the principles of fraud risk management.

The Australian Renewable Energy Agency (ARENA) is an independent Commonwealth authority, supporting innovations that improve the competitiveness of renewable energy technologies and increase the supply of renewable energy in Australia. ARENA is responsible for administering $2.5 billion in program funding for the research, development, demonstration, deployment and commercialisation of renewable energy and related technologies. ARENA engaged Integrity Advisory to assist with the following fraud risk services:

• Conducted a fraud risk assessment across all aspects of ARENA’s programs.
• Developed a comprehensive Fraud Control Plan, articulating ARENA’s approach to fraud prevention, detection and response.

The National Museum of Australia (NMA) is a major cultural institution charged with researching, collecting, preserving and exhibiting historical material of the Australian nation. Integrity Advisory assisted the NMA with the following services:

• Conducted a fraud risk assessment across all aspects of the NMA’s functions, including risks associated with the acquisition and management of items in the national collection.
• Developed a comprehensive Fraud Control Plan.

Integrity Advisory was engaged to assist the Department of Agriculture with establishment and management of a major regulatory project. The project’s key objective was to facilitate the timely development and implementation of a regulatory framework to support the Illegal Logging Prohibition Act 2012.

The following were direct outputs from the project:

• Regulations to support the Act.
• An administrative design / blueprint for a compliance and enforcement model to support the Act and regulations. 
• Communications and educational material to support the implementation of the Act and regulations.
• Policies, practice statements, standard operating procedures and templates for the new compliance and enforcement model.
• An information management framework to support the new compliance and enforcement model.

The CBD Program engaged Integrity Advisory to review the program’s compliance and enforcement framework. Key achievements were:

• A comprehensive review of the CBD Program's compliance policies, procedures and functions, to determine if they conform with the ANAO Better Practice Guide for Administering Regulation and the Australian Government Investigation Standards.
• Recommendations on how to address and improve the gaps and deficiencies identified.
• Prioritised and developed a number of these improvements.

Integrity Advisory assisted PM&C with the development of an Investigations Manual to guide the Fraud Control and Investigation Section in the conduct of robust and accountable investigations into instances of suspected fraud committed against the Department and its programs. The manual was based on best practice standards and principles, and Commonwealth legislation and policy, including:

• Australian Government Investigations Standards
• Commonwealth Fraud Control Guidelines
• Criminal Code Act 1995
• Crimes Act 1914
• Public Governance, Performance and Accountability Act 2013
• Acts Interpretation Act 1901
• Archives Act 1983
• Evidence Act 1995
• Public Interest Disclosure Act 2013
• Privacy Act 1988
• Public Service Act 1999

 In response to the increased investigations workload generated by the Australian Crime Commission’s report into doping allegations in the AFL and NRL, David was engaged by ASADA to develop a comprehensive Investigations Manual and associated supporting documents. The manual was fully compliant with the Australian Government Investigations Standards, and the associated documents included templates and guidelines for key investigation elements such as:

• Case referral and acceptance
• Critical decision records
• Investigation plans
• Case finalisation reports