Fraud Basics

Confronting the challenges of cross-border fraud examinations

Part 1 of 2

A whistleblower within our organization alleged that high-profile personnel were taking bribes, bypassing laws, creating conflicts of interest and harassing women — all in collusion with local and foreign officials of a government aid agency that provided relief funds and educational scholarships.

The allegations, which arose from a Middle Eastern country, implicated foreign officials from a ministry of a country at war who’d colluded with a senior official from another country that followed the Western judicial system. We now had a complex case that crossed legal, judicial and cultural borders.

During our investigation, we discovered that all the paper trails had literally been burned and electronic data destroyed because of a fire and a virus attack. We were left with no choice but to visit numerous cities in a country at war to check paper records at a university and a government ministry associated with the scholarships. Our evidence and witness statements suggested:

  • Candidates applying for scholarships (who were aspiring for better lives) at Western higher-education schools had paid “facilitation payments” (bribes) to scholarship ministry personnel.
  • The scholarship ministry had provided some funds to family members of ministry employees who didn’t have the requisite skill sets and qualifications.
  • Female scholarship recipients were sexually harassed under the guise of medical examinations in collusion with a hospital physician.

We obtained enough evidence to suggest that some top managers had colluded with a few foreign officials of a Western aid agency. Our investigation took another turn when we found that the mastermind of the scholarship scheme did indeed live in a country with well-established Western laws. So, we then had to research, study and understand those laws before we visited that Western country and interviewed officials in their jurisdiction.


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