Not every threat to a company comes from outside.

A Marsh webinar on fraud risk, prevention and response reported that there were 778 internal-fraud cases in 2012. The most common schemes in the U.S. involve billing, making up three-fourths of the statistic; corruption, which increased by three percent since 2010; and expense reimbursements.

In more than half of these cases, the embroiled company physically lost only $200,000 or less, but the real headache surrounding fraud discovery comes from the ensuing private civil claims, potential government investigations, criminal prosecutions and bad publicity.

Having a strong ERM program in place, in which all department leaders understand their role in assisting management while keeping employees calm and collected, will help prepare companies, says Tracy Gillis, leader of Marsh's Reputational Risk and Crisis Management Practice.

She recounted an incident in which a client discovered a trail of internal fraud that had been occurring for years. As the FBI stormed the headquarters, removing significant records and files before the eyes of the watchful media, the company realized it was unprepared to respond to the negative publicity.

“When dealing with crises, it is critical to realize that as soon as you can see the potential damage that can impact the company and organize your response, the sooner you can position your company to manage it,” Gillis said.

She added that it is important to stick to the internal plan and not be distracted by disruptive forces like social media, which she said is a good indicator of the public knowledge of the situation, but it is only one of many avenues for the spread of information.

Usually, fraud is detected by an employee tip-off, or is caught during a management review or following an internal audit. If any of these potentialities applies, or even a “gut” feeling by an experienced executive, the first step is to conduct a prompt and thorough self-investigation.

“An internal-audit investigation is like an insurance policy” for a company, said Paul Mastrocola, Business Litigation partner at Burns & Levinson LLP, during the webinar. Its goals are to determine the relevant facts of a fraud event, to gather and preserve evidence, assess legal repercussions, and administer corrective action- before an outside authority does.

Also, being the first to report the incident to authorities “can take the sting out of government investigations.”

Corrective actions should involve making amends with the “victims”, revising or implementing corporate-compliance programs and strengthening internal controls.

“Any corrective action must be tangible and real, and not for appearances — that would be counterproductive in the government's eyes,” Mastrocola said. These actions can include offering employees incentives to open up about their qualms.

“Often, an employee suspects that something is occurring but doesn't want to get involved. In these cases, a little incentive, if it comes with several zeros after it, may help,” said Jason Lelio, managing consultant with Marsh's Forensic Accounting and Claims Services Practice.

There are several fidelity and crime coverage options available to protect insured from the loss of money, securities and inventory resulting from employee dishonesty.

Crime coverage can include property theft, losses due to forgery and electronic wire transfer fraud. The financial and commercial markets saw a flat to 5 percent increase of such lines in 2012.

And no modern coverage is complete without a cyber policy, especially as a recent court decision may allow for the expanded coverage of cyber losses under a fidelity bond.

Said Damian Brew, managing director of Marsh's FINPRO practice, “Having insurance coverage without cyber is like playing hockey without a goalie.”

Special Reports /

Combating Internal Fraud Through Preparedness, ERM

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