We often overlook criminology when combating insider threats, fraud and sabotage

5–7 minutes

Key Takeaways:

  1. You can’t fix insider fraud or sabotage with firewalls alone—these are people problems, not just process problems, so you need to consider perpetrator motive in your control design.
  2. Behavioural science and criminological theory offer practical ways to design smarter, cheaper, and more effective controls.
  3. Mapping threat types to motivations is the secret sauce to stopping expensive mistakes—before they hit your bottom line.

Why this matters to your business

If you think trade secrets theft, sabotage, or internal fraud is something that happens to “other companies,” let me burst that bubble. These threats are not random—they’re often deeply personal. And they’re expensive. The Association of Certified Fraud Examiners (ACFE) estimates that internal fraud alone costs businesses 5% of annual revenue. For a $100M business, that’s a $5M hole—every year.

And that’s just the financial side. The reputational cost? The loss of trust with investors or research partners? The delay to your product launch because someone leaked your IP to a competitor? That stuff doesn’t show up on a balance sheet… until it does.

So how do we stop it?


Let’s talk motive (yes, like in crime dramas)

We often forget security and fraud actors have different motivations. Some actors are in it for profit. Others want revenge, power, or validation. If you treat all threats the same—say, by rolling out the same boring training module to every department—you’re wasting money and creating a false sense of security.

This first table helps you step back and align your controls to the actual psychology of your adversary.

Table 1: Motivation-Based Threat Profiling

Threat TypeKey MotivationsRelevant TheoryConsiderations for Control Design
Organised CrimeProfit, group objectivesRoutine Activity TheoryTarget hardening, threat intel, supply chain vetting
Insider ThreatsRevenge, stress, entitlementControl TheoryStrengthen social bonds, build fair culture, early intervention
Nation-State ActorsMoney, Ideology, Coercion, Ego (MICE)MICE TheoryAccess controls, vetting, protective security
man sitting on snowy park bench in winter
Photo by Amirhossein Bolourian on Pexels.com

How to use this:
When assessing security risks, we often fail to ask “What is the likely motive”. If your AI is being stolen by an employee, that’s an insider threat, not a problem with cyber criminals. The control response (culture, access rights, change monitoring) needs to reflect that nuance.


Behavioural theory helps at every risk stage

Here’s the bit I wish someone had told me 10 years ago: criminological theories don’t just help you after something goes wrong—they help you design better systems from the start. I use these theories for risk indentification, design risk treatments, and frame executive dialogue.

Table 2: How Behavioural Theory Supercharges Risk Management

Risk StageHow Theories Help
Risk IdentificationReveal root causes and hidden risk signals
Control DesignTailor controls to motivations (not just compliance)
Risk AssessmentImprove likelihood and impact estimates
Monitoring & ReviewSpot early warning signs and behavioural red flags
Training & AwarenessShift from checkbox compliance to ethical behaviour reinforcement

How to use this:
When you’re building your next fraud control or insider risk program, don’t start with a control library—start with questions. What kinds of pressures might lead someone to rationalise stealing research data? Where are the opportunities? Who might feel disengaged or unfairly treated? These insights help you focus resources where they’ll have the most impact—without overengineering.


Choosing the right theory for the job

Criminological theory might sound academic, but it’s just a lens—a way to make better sense of why risks materialise. I often get asked, “Which theory should I use?”. The answer is: it depends, which is helpful-unhelpful. Here’s a guide I use in consulting to help organisations focus their resources.

Table 3: Best-Fit Theories for Common Security Risks

Risk AreaRelevant TheoriesWhy It Matters
EspionageMICE (Money, Ideology, Compromise or Coercion, Ego), Routine Activity, Swiss CheeseExplains varied motives, layered failures, and access points
Trade Secrets / IP TheftRoutine Activity, Crime Opportunity, MICEFocuses on access, motivation, and weak controls
Internal Fraud / CorruptionFraud Triangle, Routine Activity, Control TheoryAddresses personal pressure, weak oversight, and cultural cues
SabotageOpportunity Theory, Strain TheoryTied to frustration, injustice, and lack of guardianship
Workplace ViolenceStrain, Social Learning, Routine ActivityDriven by grievance, modeled behaviour, and opportunity
Supply Chain DiversionCrime Pattern Theory, Opportunity TheoryHelps pinpoint vulnerable choke points and recurring loss patterns

How to use this:
Say your business is about to enter a new research partnership with a university or foreign lab. You’re worried about losing your IP or trade secrets. Start by applying MICE Theory to understand potential risks on the other side: Are their staff well-paid? Are there ideological risks? How vulnerable is your business partner or their employees to coercion or bribery? Then combine that with Crime Opportunity Theory to assess access and controls.

You don’t need to become a criminologist—but bringing these concepts into boardroom discussions will make your risk strategies more intelligent and effective.


What you should do next

  1. Reassess your threat profiles – If your risk registers don’t account for behavioural motivations, rewrite them.
  2. Train your teams on motive-driven threats – Stop relying on bland compliance modules. Teach managers how to spot early red flags.
  3. Map controls to theories, not hunches – Don’t throw money at controls that don’t match the motive. Use behavioural theory to guide investment.
  4. Get smarter about culture – Your culture is your first control. Build fairness, transparency, and connection before a bad day turns into a $10M incident.

One final (uncomfortable) truth

You can’t patch human vulnerability like you patch software. Your best firewall is a culture that understands why people do the wrong thing—and a strategy that uses that insight to get ahead of the next crisis.

So, if you’re ready to move beyond checkbox security and build a behavioural-led risk strategy, let’s talk. I’ve got frameworks, models, and a whole lot of lessons learned the hard way.

Further Reading:

DISCLAIMER: All information presented on PaulCurwell.com is intended for general information purposes only. The content of PaulCurwell.com should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon PaulCurwell.com is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.

Combatting Adaptive Threats: Control Assurance Strategies

7–10 minutes

3 Key Takeaways

  1. Security and fraud controls decay over time—especially when facing smart, persistent human adversaries who adapt faster than your processes do.
  2. Mapping the criminal business process helps build typologies, essential for designing detection logic to embed into your fraud, insider threat, and SIEM systems.
  3. You must monitor control decay continuously using early indicators and adaptive analytics—not just wait for losses or incidents to show you’ve failed.

The Adversarial Evolution Challenge

Fraud and security controls face a unique challenge: they’re not defending against random failures or faulty processes—they’re up against people. Adaptive, intelligent, persistent people.

Think of it like this: you lock your doors. But if someone really wants in and watches you long enough, they’ll figure out where the spare key is. That’s what control decay looks like when your adversary is watching, learning, and evolving. Over time, even the best-designed controls wear thin against determined adversaries—especially when those adversaries have motivation, time, and community support.

This constant pressure creates a cycle where:

  • Controls lose effectiveness as attackers discover workarounds.
  • Fraudsters evolve their TTPs (tactics, techniques, and procedures) to sidestep your latest defences.
  • Control bypass techniques get shared in underground forums, speeding up the learning curve for others.
  • Every successful breach becomes a repeatable blueprint—one your analytics may not be trained to detect.

The Real Cost of Ignoring Control Decay

In 2023, reported global losses from fraud hit US$485 billion, with insider threat incidents costing an average of US$16.2 million each. And those figures only capture what’s been detected and disclosed.

Control decay is especially dangerous in environments that depend on digital platforms (e.g. eCommerce, online banking), protecting trade secrets, and product protection. Supply chains and distirbution are particularly vulnerable. Third parties may have weaker controls, creating backdoors into your systems. And when fraud or insider threats go unnoticed, they erode trust and value, fast.

Security and Fraud threats are carried out by people: Adaptive, intelligent, persistent adversaries.

From Static to Smart: Rethinking Controls

Many organisations treat security and fraud controls as one-time investments—set them, test them, and move on. That mindset doesn’t work against adaptive human threats.

Controls decay like milk, not wine. Even when controls are automated, humans are still involved—approving actions, ignoring alerts, or skipping procedures. Over time, fatigue and complacency creep in, creating gaps that adversaries can exploit. That’s why it’s essential to continuously reassess the effectiveness of your defences, a process known as ‘control assurance’.


Mapping the Criminal Business Process

Before you can improve detection, you need to understand the steps an adversary must take to succeed. That’s where mapping the criminal business process comes in.

This means reverse-engineering the steps an adversary would take to achieve their goal—whether that’s stealing research data, committing payment fraud, or accessing protected systems. By mapping out their “workflow,” you can identify where to disrupt them.

Key disruption opportunities include:

  • Reconnaissance – How do they learn about your systems, people, or gaps?
  • Access – What path do they use to gain entry (e.g., phishing, credential reuse)?
  • Evasion – How do they stay under the radar?
  • Monetisation – What do they do with what they’ve taken?
  • Exit strategy – How do they cover their tracks?

This process forms the backbone for building targeted detection strategies.


Typologies: Turning Adversary Tactics into Detection Models

Once you understand the criminal business process, you can develop typologies. These are structured descriptions of how specific threats play out in your context—complete with behavioural indicators, red flags, and contextual cues.

Typologies aren’t just lists of “bad behaviours.” They are comprehensive models that describe how specific threats manifest within a particular context. A typology outlines the sequence of actions, behavioural indicators, contextual factors, and potential red flags associated with a particular threat scenario:

  • They aggregate indicators, sequences, and behaviours that point to fraud or compromise.
  • They include the context—industry, access levels, timing—that makes them relevant.
  • They support prioritised detection by translating threats into models your systems can monitor.

Developing typologies involves analyzing real-world cases to identify common patterns and methods used by adversaries. One effective approach is Comparative Case Analysis (CCA), which compares multiple incidents to extract shared characteristics and inform the development of robust typologies.

Click to find out more about Comparative Case Analysis

From Typologies to Detection: Using Analytics to Catch Adaptation

Once established, these typologies serve as the foundation for designing analytics-based detection models. By translating the insights from typologies into detection logic, organizations can proactively monitor for activities that align with known threat patterns, enabling earlier identification and response to potential incidents.

Click to find out more about typologies

Data analytics helps you identify these early signs of attacker adaptation—well before a control fails outright. By building detection around these patterns, you shift from reactive incident response to proactive defence.

  • Anomaly Detection – Spot subtle changes in normal activity before a bypass is successful.
  • Clustering & Pattern Discovery – Uncover organised campaigns or repeated techniques across cases.
  • Temporal & Spatial Analysis – Track when and where new threats emerge or evolve.
  • Simulations & Wargaming – Test how your controls stand up to evolving TTPs (modus operandi) in different organisational contexts or business processes (inclusive of internal control points).
  • Threat Intelligence Integration – Correlate public vulnerabilities or attack trends with what’s happening in your own data.

Measuring and Monitoring Control Decay

You can’t improve what you’re not measuring. Most businesses track breaches and incidents—but that’s too late. Control decay needs earlier signals.

The goal is to monitor signs that controls are being weakened, tested, or circumvented—even if the attacker hasn’t succeeded yet. These metrics give you early warning that your system is becoming vulnerable.

  • Bypass Detection Rate – How often are adversaries getting around your controls?
  • Control Learning Curve – How fast are attackers adapting after implementation?
  • Adaptation Indicators – Are there new methods or patterns in failed attempts?
  • Control Evasion Techniques – What are the latest tricks being used to slip past detection?
  • TTP Evolution Tracking – How are known techniques changing over time?
  • Reconnaissance Patterns – Is someone repeatedly probing or testing your systems?
  • “Low and Slow” Attacks – Are there stealthy signs of gradual testing or exploitation?
  • Correlation with Vulnerability Disclosures – Do public CVEs line up with spikes in suspicious activity?
Fraud and security controls decay over time in the face of threats

Countering Control Decay with Adaptive Analytics

Now that you’re watching for decay, you need to build controls that respond to it. Static rules can’t keep up with adversaries that are constantly learning and evolving.

This is where adaptive analytics come in. By layering behavioural insights, detection flexibility, and external intelligence, you can keep your controls sharp and responsive.

  • Control Variation – Don’t apply identical rules across environments—vary thresholds and triggers to make it harder to game the system.
  • Adaptive Rule Sets – Let your system adjust thresholds when probing is detected.
  • Behavioural Baselines – Define “normal” for each user or system, and refresh those profiles regularly.
  • Interdependent Control Effectiveness – Evaluate how your layers of control interact—do they actually reinforce each other?
  • Simulate Responses – Use testing and wargames to anticipate how controls would respond to emerging tactics.
  • Threat Intelligence Integration – Don’t just collect external threat data—use it to shape detection models and control tuning in real time.
Click to find out more about how to build insider threat detection capability

TL;DR: The Threat Is Human, and So Is the Weakness

Your adversaries are human, which means they’re persistent, curious, and adaptive. They’ll keep pushing until they find a way through.

But the people inside your organisation—who operate, review, and respond to controls—are also human. And humans get bored, distracted, and desensitised. That’s how control decay happens, both technically and culturally.

The big mistake is waiting for a loss to act. Losses are lagging indicators—they tell you your controls already failed. The real win is spotting decay before the breach. That means checking your data constantly for signs that someone’s testing your system or that your team has stopped paying attention.

Wondering what to do next? Start by looking at your risks and controls, and doing some data analytics on key processes, products or information against historical incidents and near misses to understand what’s going on. Then identify indicators of control decay, and build dashboards to monitor the. And don’t forget to look at them regularly!


Further Reading:

DISCLAIMER: All information presented on PaulCurwell.com is intended for general information purposes only. The content of PaulCurwell.com should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon PaulCurwell.com is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.

Unlocking New Uses for your SIEM: Beyond Cybersecurity

7–11 minutes

3 key takeaways:

  1. Most companies are sitting on powerful analytics platforms like SIEMs—but rarely use them beyond cyber.
  2. There’s untapped potential to apply these tools to fraud, insider threat, IP protection, and compliance monitoring.
  3. With the right strategy, businesses can reduce compliance costs, improve visibility, and make better investment decisions.

Why this matters

Today’s risk environment demands more from businesses than ever before. Whether you’re protecting sensitive R&D, complying with complex regulations, or trying to prevent fraud, the traditional playbook is falling short. Organisations invest millions in security analytics. Frequently though, use of these tools happens in a silo, begging the question “can’t they do more?”. That’s a missed opportunity.

Many organisations already own high-powered Security Information and Event Management (SIEM) and observability platforms to give rich, real-time operational insights. In most businesses, there is no use of these tools outside of cybersecurity. That’s where this story begins.


The landscape: SIEMs, observability tools, and everything in between

Let’s unpack the main types of platforms:

  1. Security Information and Event Management (SIEM) – These platforms are the backbone of many security operations centres. SIEMs like Splunk, Sentinel, and Elastic collect and correlate security events to find and respond to threats in real time. They’re also critical for compliance reporting, audit trails, and forensic investigations.
  2. Observability platforms – Tools like Datadog, New Relic, and OpenTelemetry provide deep insights into how systems are operating. Used by DevOps and Site Reliability Engineers, they collect metrics and logs to monitor system health, performance, and prevent outages.
  3. Data lakes and warehouses – These centralised platforms are great for long-term storage and complex data queries. However, they often lack the speed or alerting capability needed for real-time risk response.
  4. BI dashboards and analytics tools – Platforms like Power BI and Tableau provide strong visualisation for decision-making. They focus on historical data, not real-time detection.
  5. Log management platforms – Tools like ELK store data for troubleshooting, but don’t get integrated into business processes.
  6. Application Performance Monitoring (APM) tools – Focus on user experience and technical metrics but often miss the business context needed for enterprise insights.
  7. Custom threat intelligence platforms – Powerful in capable hands, but often resource-intensive to maintain and inaccessible to non-technical teams.

Understanding how these tools work—and where they overlap—opens up new opportunities for extending their use into fraud, compliance, and continuous monitoring.


Non-cyber use cases hiding in plain sight

What became clear through my research is that many businesses are unknowingly sitting on a goldmine of data. This data can improve resilience, situational awareness and decision quality, resulting in reduced losses. Many tools already have access to the underlying telemetry. The gap is that organisations don’t translate their use cases into language or workflows these systems can use to solve business or compliance problems.

Here are a few real-world examples of how some organisations are using their existing telemetry platforms to solve non-security problems:

  • Fraud detection – One financial services firm used their SIEM to detect behavioural anomalies in user logins and transaction data. This helped identify fraudulent activity faster and reduce false positives in fraud alerts.
  • IP protection – A biotech set up observability pipeline alerts to detect unusual access patterns to protected research environments. This gave them a chance to intervene before valuable data walked out the door.
  • Insider threat monitoring – A large enterprise integrated HR systems with SIEM logs to flag when high-risk employees (e.g. those about to exit the company) accessed sensitive files, enabling pre-emptive action.
  • Physical security integration – A logistics company ingested building access logs into their SIEM to monitor for suspicious after-hours activity. This provided near real-time visibilty of threats in zones containing high-value or regulated assets.
  • Regulatory compliance – A US health services provider configured automated alerts to detect improper access to patient records. This streamlining HIPAA compliance and reporting, easing the burden on their audit teams.

These examples aren’t outliers. They represent what’s possible when organisations look beyond the traditional cyber perimeter and align technology with broader business risks.


Trade-offs and tricky bits

Of course, extending the use of SIEMs and observability platforms isn’t without its challenges. These are powerful tools, but were built with specific users and functions in mind. Repurposing them for broader use requires careful planning, stakeholder alignment, and a realistic view of limitations.

MetricConsiderations
Cost vs returnSIEM platforms, in particular, can become prohibitively expensive as more data sources are added. Every additional log source or telemetry stream can drive up ingestion costs, licensing fees, and infrastructure requirements. Businesses need to balance the value of added insights against escalating costs.
Expertise and resourcingMany of these platforms are complex and require specialist skills to configure and manage. Cyber teams are often already overstretched, they don’t have capacity. Asking them to support fraud, compliance, or operational use cases often requires cross-skilling or additional resources.
Data governance and privacyAggregating sensitive business data—such as HR records, payroll, or personnel movements—can raise privacy concerns. Any use needs to be aligned with data protection laws such as Australia’s Privacy Act, or the GDPR in Europe.
Tool mismatch and workflow gapsObservability platforms are fast, lightweight, and built for performance. But they’re not designed for legal defensibility, long-term retention, or audit-ready compliance reporting. SIEMs, on the other hand, are great for that. But, they can lack the ease of use or responsiveness that observability tools provide.
Redundancy and duplicationWithout coordination, multiple teams end up collecting and analysing the same data using different tools. This can lead to inefficiency and potential confusion around ownership and accountability. Worst case for regulatory compliance, you generate contradictory records which is a red flag to an inspector.
Table: Benefits and Challenges

Yes, there are challenges, but the opportunities are too great to ignore. Now’s the time for risk and compliance leaders seeking smarter, scalable approaches to assurance to speak to the CIO.


Real compliance benefits—if you play it right

Compliance is a growing cost centre for many organisations. Increasingly, fraud and protective security is becoming a regulated compliance program. Take Australia’s Privacy Act, Scams Protection Framework Act and Security of Critical Infrastructure Act as two examples. Teams are under pressure to meet complex compliance obligations, conduct audits, investigate incidents, and coordinate a response. Given most responses increasingly relate to compliance obligations, there’s a regulatory imperative to get this right. They’re often using manual processes and disconnected systems to do this, taking time, effort and higher chance of errors.

This is where SIEM and observability platforms can play a much bigger role. By automating key controls organisations can reduce the manual workload on compliance and audit teams. Examples include detecting access to sensitive data, validating privileged user activity, or monitoring export-controlled environments. The result? Improved productivity, cost control, and compliance. Dashboards and real-time alerts eliminate the need for manual reviews, reduce investigation time, and improve coordination across the business.

These platforms also provide strong evidence for legal and regulatory inquiries. For example, access logs and alert histories makes it easier to prove data segregation or show controls were in place. This supports compliance SOX, the Privacy Act, or Australia’s Security of Critical Infrastructure Act (SOCI).

These tools allow compliance teams to shift from reactive policing to proactive risk reduction. In turn, this makes them more efficient, more strategic, and more valuable to the business.


What business leaders need to do next

This isn’t just a technology issue—it’s a business opportunity. Executives should be asking how they can leverage their existing technology investments to solve new problems.

Here’s a five-step path to get started:

  1. Audit your existing tools – Inventory the telemetry and analytics platforms already in use. Identify whether you have a SIEM, an observability platform, or both. Are you using these to good effect?
  2. Map broader risks – Work with fraud, HR, IP, and compliance stakeholders to identify high-impact, high-cost business risks. Identify use cases that benefit from automation and real-time monitoring.
  3. Engage privacy and legal early – Involving these teams from the outset. This helps prevent delays later and ensures any solution aligns with data protection laws and internal governance frameworks.
  4. Pilot a use case – Choose one low-risk, high-impact use case (e.g. unusual access to critical systems) and configure alerts or dashboards using existing tools. Track the cost, value, and effort involved.
  5. Build the business case – Quantify what value these solution will save in hours, cost or loss reduction, or productivity. Present this in a way that links directly to business strategy and financial performance.

If you’re already paying for the Ferrari, why are you only using it for trips to the supermarket? With a little tuning and creativity, you can unlock value across new use cases without buying yet another tool.


Further Reading

DISCLAIMER: All information presented on PaulCurwell.com is intended for general information purposes only. The content of PaulCurwell.com should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon PaulCurwell.com is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.

The Hidden Threat to Your Bottom Line: How Sales Fraud is Bleeding Your Business Dry

5–8 minutes

Key Takeaways:

  • Fraud costs companies 5% of annual revenue, with economic downturns increasing fraud risks
  • Sales teams present unique fraud vulnerabilities through returns schemes, revenue manipulation, and commission fraud
  • Implementing targeted controls like commission clawbacks and automated monitoring can protect your revenue and reputation

Introduction

Let’s face it – while you’re busy watching your supply chain for external threats, your sales team might be quietly bleeding your company dry. As someone who’s spent years investigating corporate fraud cases, I’ve seen firsthand how sales fraud schemes can fly under the radar while causing massive financial damage. In today’s shaky economic climate (thanks, tariffs), fraud is on the rise, and your sales department is particularly vulnerable.

The Costly Reality of Sales Fraud

Did you know that companies lose a whopping 5% of annual revenue to fraud? That’s billions collectively wasted across industries. What’s more alarming is that according to fraud experts, 55% observed increased fraud during economic downturns – precisely the environment we’re navigating now.

For business leaders and finance chiefs, this isn’t just a financial headache—it’s a direct attack on your business strategy and profitability. While you’re focused on protecting your trade secrets and IP protection from outside threats, your greatest insider threat might be sitting in your sales department.

Six Common Sales Fraud Schemes Killing Your Profits

1. Returns Fraud with Kickbacks

This scheme is particularly sneaky. A salesperson encourages customers to purchase excess inventory (often with unauthorized discounts) to inflate sales figures. Later, the customer returns the excess inventory, but the salesperson keeps their commission. Meanwhile, your inventory numbers and forecasting are completely thrown off.

Red Flags to Watch For:

  • Large sales orders followed by significant returns
  • Sales spikes near reporting periods (quarter-end) that reverse shortly after
  • High return rates for specific salespeople compared to others
  • Unusual relationships between sales staff and certain customers

In 2022, a global electronics distributor discovered a senior salesperson colluding with a key customer on bulk orders at steep discounts. After commissions were paid, the customer returned over 60% of the inventory. Pretty clever scam, right?

2. Revenue Recognition Fraud

This scheme involves manipulating revenue figures or pocketing unrecorded revenue. For example, an employee might issue a credit note and split the refund with a customer. For technology companies especially, recording revenue too early can artificially inflate performance metrics.

Red Flags to Watch For:

  • Customer receipts missing for completed sales
  • Same person handling both invoicing and payment collection
  • Unusual timing of revenue recording (especially at quarter-end)
  • Differences between contract terms and recorded revenue

3. Credit Note Manipulation

Your sales team might be issuing unauthorized credit notes to steal funds or hide theft. Without proper oversight, this fraud can continue for months or even years before anyone notices.

Red Flags to Watch For:

  • Credit notes issued without proper approval
  • Unusual patterns or increased frequency in credit note issuance
  • Credit notes that lack supporting documentation
  • Certain employees processing a disproportionate number of credit notes

4. Inventory Fraud

This classic scheme involves stealing stock via false sales or diverting goods in transit. In 2022, an employee at an Australian parts supply company altered supplier bank details to divert payments while covering up inventory theft through falsified invoices. Their research showed this could be prevented with better automated fraud detection tools.

Red Flags to Watch For:

  • Negative inventory entries or unexplained stock differences
  • Frequent cancellations of sales transactions
  • Differences between physical inventory counts and system records
  • Unusual shipping or delivery patterns
inventory in a warehouse
Photo by Tiger Lily on Pexels.com

5. Discount and Pricing Manipulation

In Asia, employees were caught receiving kickbacks for granting unauthorized discounts. This not only hurts your profits but can disrupt your entire pricing strategy and market positioning.

Red Flags to Watch For:

  • Discounts disproportionately benefiting specific customers
  • Patterns of excessive discounts tied to one salesperson
  • Discounts offered without proper approval or documentation
  • Unusual changes in profit margins across similar sales

6. Commission Fraud

Consider this simple example: if a salesperson fraudulently changes their commission rate from 10% to 20% on $1,000,000 in sales, that’s $100,000 straight out of your pocket. Multiply that across your sales team and years of operation, and you’re looking at potentially huge losses.

Red Flags to Watch For:

  • Cash skimming from sales that go unrecorded
  • Creating fake sales to inflate commission numbers
  • Differences between sales data and bank deposits
  • One salesperson consistently outperforming peers by unusual margins

Software vs. Physical Products: Different Risks

The selling of software brings its own unique fraud risks. While physical product fraud often involves inventory theft and returns, software sales fraud typically involves revenue manipulation and more complex schemes.

For software subscription companies, a common scheme involves selling discounted multi-year subscriptions to partners who later cancel most licenses after commissions are paid. One company discovered a regional manager had colluded with a reseller to inflate sales figures and split the commission.

For physical products, fraud detection may be easier due to inventory checks you can see and touch. Software fraud, however, can be harder to detect since the product isn’t physical. For instance, in 2021, a software company found that a sales manager sold discounted multi-year subscriptions to a partner who later canceled over 70% of the licenses within six months. The manager received commissions based on gross sales but wasn’t penalized for cancellations.

Protect Your Bottom Line: Four Action Steps

  1. Implement Commission Clawbacks: Tie commissions to net sales (gross sales minus returns) and implement penalties for canceled subscriptions or returned goods. This single control can eliminate much of the motivation for fraud.
  2. Create Stricter Approval Processes: Require manager approval for large discounts, bulk orders, or unusual contract terms. This creates accountability and transparency. For credit notes, implement a two-person approval system that prevents a single employee from handling the entire process.
  3. Leverage Data Analysis: Monitor return rates by salesperson, product line, and customer using tracking tools. Look for patterns of excessive discounts followed by high return rates. Modern analysis can flag unusual activities long before traditional audits would catch them.
  4. Conduct Regular Internal Audits: Focus on high-risk areas such as discounts, bulk orders, refunds, and return transactions. Surprise audits are particularly effective at catching ongoing fraud schemes.

Call to Action

Stop leaving your revenue vulnerable to insider threats. Review your sales controls today and implement these four steps to protect your bottom line. The economic landscape is already challenging enough without letting sales fraud drain your profitability. In my experience, most companies discover fraud only after significant damage has been done. Don’t wait for your technology investments and research efforts to be undermined by preventable financial losses. As business leaders, we can’t afford to overlook this hidden danger in our sales departments. Take action now before your next earnings report reveals the damage.

Further Reading

DISCLAIMER: All information presented on paulcurwell.com is intended for general information purposes only. The content of paulcurwell.com should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon paulcurwell.com is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.

Crafting Security Business Cases for Executive Buy-in

6–9 minutes

Key Takeaways:

  1. Here’s the bottom line: Executives don’t fund security initiatives; they fund outcomes. A strong business case is essential to get their support.
  2. Focus on Impact, Not Activity: Executives care about how your proposal boosts business outcomes, not your list of security tasks.
  3. Show Value Beyond Compliance: Prove that security investments enable growth, reduce risk, and give your company a competitive edge.
  4. Quantify Risks and Benefits: Use statistics and real-world examples to demonstrate how security measures can save money or prevent significant losses.

What’s the Real Deal with Business Cases for Security?

Let’s be real: writing a business case for security, fraud, or IP protection can feel like trying to convince your dog to do your taxes—it’s tough and often gets ignored. Unlike departments that directly generate revenue, these functions are often viewed as “cost centers.” But the truth is, they’re vital for preventing catastrophic losses. Think about it: how much would a major data breach, insider threat, or IP theft cost your company? Exactly. That’s where your business case comes in.

If you want executives to take your proposal seriously (and fund it), you need more than just a list of security threats or the need for more budget. You need to speak their language. Executives want to know how your proposal will reduce risk, drive growth, and improve profitability. If your business case doesn’t hit those marks, expect a polite nod and zero budget. So how do you get the green light? You need to answer these seven crucial questions in your security business case.

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7 Key questions executives care about – linking security to strategic outcomes

The challenge is proving that security isn’t just about checking boxes or avoiding fines—it’s about tangible business outcomes: protecting revenue, improving customer trust, and enabling expansion into new markets. If you can’t connect security investments to these results, your proposal won’t make it past the trash can. So, let’s dive into the key questions executives are really asking when reviewing your case.

Question 1: What’s the Impact?

Executives want to know how your security investment will improve business resilience, customer trust, or revenue. Security isn’t just about defending against threats; it’s about keeping the lights on, ensuring smooth operations, and even opening new markets. Can your proposal do that? If not, it’s not going to get approved.

Useful strategy metrics for security business cases include:

  • Brand Equity (measured through surveys)
  • Customer Lifetime Value (CLV)
  • Net Promoter Score (NPS)
  • Revenue impact from security investments
  • Customer Trust Index (measured through surveys)
  • Employee Engagement Score

Question 2: Will This Stop Downtime (and Make Us Look Good)?

Downtime is the nightmare that keeps executives up at night. Every minute of downtime can cost your company thousands of dollars. Worse, it leads to frustrated customers and a PR disaster. You need to show how your security initiative prevents downtime, ensures business continuity, and (let’s be honest) makes the execs look like rockstars.

Useful strategy metrics for security business cases include:

  • Cost of Downtime
  • Recovery Time Objective (RTO)
  • Recovery Point Objective (RPO)
  • System Uptime Percentage
  • Mean Time Between Failures (MTBF)
  • Mean Time to Resolve (MTTR)
  • Customer Satisfaction Scores

Question 3: Can This Help Us Expand Into New Markets?

Want to expand into new geographies or high-compliance industries? Security plays a key role here. New markets require solid compliance and security frameworks. Prove that your security investment is the gateway to growth, not just a cost center.

Useful strategy metrics for security business cases include:

  • Market Penetration Rate
  • Revenue from New Markets
  • Market Share in New Segments
  • Compliance Rate with Market-Specific Regulations
  • Profit Margin in New Markets

Question 4: Does This Make Us Better Than Competitors?

In today’s world, security is a competitive differentiator. Customers stick with companies they trust to protect their data. Your company’s security posture could be the reason a customer chooses you over the competition. Show how your security proposal will improve customer retention and acquisition rates.

Useful strategy metrics for security business cases include:

  • Customer Retention Rate (churn)
  • Customer Acquisition Cost (CAC)
  • Security Breach Incident Rate (compared to industry average)
  • Brand Trust Index (measured through surveys)
  • Competitive Benchmarking Scores

Question 5: Are We Saving Money or Just Spending It?

Let’s face it—compliance fines can be crippling. A solid fraud detection, Trade Secrets or IP protection system can save your company millions. Demonstrate how your security investment prevents financial losses, whether from regulatory fines, operational downtime, or reputational damage.

Useful strategy metrics for security business cases include:

  • Return on Security Investment (ROSI)
  • Total Cost of Ownership (TCO) for Security Solutions
  • Operational Cost Savings
  • Compliance Fine Avoidance (measured in cost savings)
  • Automation Efficiency Gains

Question 6: How Much Risk Does This Actually Remove?

No one can eliminate risk entirely, but you can reduce it. How much are you saving by investing in security today to avoid a breach tomorrow? Help your execs understand the cost-benefit—are you spending $100K today to avoid a $5M loss in the future? Make the numbers clear.

Useful strategy metrics for security business cases include:

  • Risk Mitigation Rate
  • Expected Loss Reduction
  • Risk Score Improvement
  • Vulnerability Management Efficiency
  • Reduction in Security Incidents

Question 7: What’s the Brand Damage if We Don’t?

Nobody wants to be the next big breach in the headlines. Think Target, Equifax, or Sony. Show how your proposal protects the company’s reputation and brand equity, which can take years to build and mere seconds to destroy.

Useful strategy metrics for security business cases include:

  • Brand Valuation
  • Media Sentiment Analysis Score
  • Social Media Engagement Rates
  • Employee Net Promoter Score (eNPS)
  • Employee Turnover Rate
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Writing Business Cases for Non-Revenue Generating Functions: The Struggle Is Real

It’s not easy to sell risk and compliance functions because they don’t directly generate revenue. But that doesn’t mean they don’t provide value. Here’s how to make your case:

  • Focus on Cost Avoidance and Risk Mitigation: A solid security program prevents disasters before they happen. Consider the massive fine HSBC faced for anti-money laundering violations: $1.9 billion. Your security measures are the front lines against such catastrophic fines and reputational damage. Use metrics like Annualised Loss Expectancy (ALE) to show how much risk you’re removing.
  • Emphasise Indirect Revenue Enablement: Compliance and security aren’t just about avoiding risks—they also enable growth. A strong security posture can open doors to new markets, especially if you’re meeting the right regulatory standards. By investing in security, you can unlock new opportunities for revenue without worrying about fines or legal issues.
  • Link Security to Strategic Goals: Non-revenue functions like risk management enable other revenue-generating activities. Think about how security protects supply chains, ensures smooth operations, and allows for market expansion. Security supports business continuity, which directly impacts the company’s ability to generate revenue.
  • Qualitative Benefits Matter Too: Not all benefits can be measured in dollars, but that doesn’t mean they’re less important. Enhanced trust, better customer relationships, and a positive corporate culture all contribute to the company’s long-term success.

The Bottom Line: Get Your Security Business Case Right

Security business cases should focus on outcomes, not just activities. Link your proposals to business strategy and demonstrate how security helps reduce risk, save money, and enable growth. Link your business case to your strategy by addressing the seven questions executives care about and you’ll put yourself in a strong position to secure the budget you need.

What’s Your Next Step?

Take a fresh look at your security business case. Does it speak to business outcomes? Does it quantify risk reduction and highlight opportunities for growth? If not, it’s time to rewrite it. Trust me, your executives will thank you.

Further Reading

DISCLAIMER: All information presented on PaulCurwell.com is intended for general information purposes only. The content of PaulCurwell.com should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon PaulCurwell.com is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.

Scams are now a national security issue – published in ‘The Strategist’

1–2 minutes

On 26 Jun 2024, Nicholas McTaggart and I wrote an article for The Strategist, a publication of the Australian Strategic Policy Institute). We explored how scams have evolved from being a nuisance to becoming a critical national security issue. These sophisticated operations exploit technology and human vulnerabilities, targeting individuals and organisations alike. From phishing schemes to supply chain compromises, the impacts are far-reaching, undermining trust in systems and draining economies.

In our view, governments and businesses must treat scams as more than a financial issue; they are a threat to resilience and security. A multi-pronged approach involving education, regulation, and technology is essential to combat this escalating challenge.

If you want to read the full article on The Strategist, head to Scams are now a national security issue



Further Reading

DISCLAIMER: All information presented on PaulCurwell.com is intended for general information purposes only. The content of PaulCurwell.com should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon PaulCurwell.com is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.

Hey, business owners! Tired of losing money to CEO scams?

1–2 minutes

Who isn’t, right? It’s time to get smart about security risk assessments.

Yes, those pesky assessments that sound boring but are actually your best friend in dodging scams.

  1. Step one: map out your company’s email flow. Who’s sending what to whom? Knowing this helps you spot anomalies. If Bob from accounting suddenly asks for a wire transfer, you’ll know something’s up—especially since Bob’s been on vacation for two weeks.
  2. Next, scrutinize your email security settings. Is your spam filter set to “catch-all-the-junk” mode? Great! But is it also catching important emails? Not so great. Adjust those settings to filter effectively without blocking legitimate business.
  3. Oh, and let’s not forget about multi-factor authentication (MFA). Yes, it’s an extra step, but it’s a step that can save your bacon. MFA ensures that even if a scammer gets your password, they still need a second form of verification. It’s like having a bouncer for your email.

Train your staff. Regularly. If your employees can’t spot a phishing email from a mile away, you’re in trouble.

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Use simulated attacks to keep everyone on their toes: Trust me, it’s worth the effort!

Lastly, always verify before you trust.

Got an urgent email from the CEO asking for funds? Pick up the phone and double-check.

It might just save your business from a costly mistake.

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So, there you have it. Conducting a security risk assessment isn’t just a good idea—it’s essential. Keep those scammers at bay and protect your hard-earned money.

Channel stuffing fraud – a distribution problem

7–10 minutes

What is Channel Stuffing?

Channel Stuffing is also known as ‘trade loading’, and is where sales teams sell an abnormally large quantity of product to distributors at one time. These sales are usually at a significant discount, or on generous payment terms making it both attractive and financially viable to the buyer. Channel Stuffing increases earnings in the short-term, but you are effectively front-loading the next quarter’s sales, which makes it harder to achieve future sales targets.

Sometimes, Channel Stuffing can be fraudulent, such as where a sales person engages in Channel Stuffing to get a higher short term incentive (bonus) or commission knowing they intend to resign before the next quarter. In some cases, the buyer (e.g. retailer) is forced or coerced by the Distributor to purchase the extra inventory. This can damage the relationship and even impact the retailer’s financial viability.

To make it more attractive to sourcing and procurement teams in the retailer, the sales person attemping Channel Stuffing may offer bribes or kickbacks to the retailer’s staff to complete the Channel Stuffing transaction, or distributor sales staff and retailer procurement staff may be acting in collusion to perpetrate the scheme. An illustration of how Channel Stuffing works is shown below:

An illustration of the way channel stuffing works in a supply chain

Companies that don’t have proper controls in place are likely to fall victim here – it’s worth pointing out that Channel Stuffing is an internal fraud, a type of insider threat which occurs in the distribution stage of the supply chain.

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What industries are most exposed?

Industries most at risk of Channel Stuffing are those with high margins, because high margins can be discounted without overly impacting revenue. Those most likely to be impacted include:

  • Consumer Electronics
  • Tobacco
  • Automotive Industry
  • Pharmaceuticals
  • Fast Moving Consumer Goods (FMCG)
  • Technology, including software providers
  • Fashion and apparel
  • Industrial equipment
  • Alcohol and Distilled Spirits

As with many supply chain and distribution fraud schemes, it is hard to find reliable statistics on incident data so I have replaced a graph of losses with a more uplifting pic of something I enjoy – getting outdoors!

people riding on inflatable raft
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Who are the victims in Channel Stuffing?

There are two victims in channel stuffing fraud – that is, parties who incur a loss. First is the distributor (channel partner) itself which employs the sales team. This is commonly the case in fraud perpetrated by one or a small group of disaffected sales leads who are trying to engineer a good bonus and intend to resign in the near future to avoid any repercussions.

Where sales people have fraudulently engineered sales, the channel partner may need to engage legal support to claw back bonuses, and may also be subject to financial penalties from the manufacturer under the Distribution Agreement for having inadequate controls which allowed Channel Stuffing to happen.

The second victim is the manufacturer or business which creates its products and sells them to customers via its channel partners. This company is dependent on third party channel partners to execute the distribution agreements as agreed.

Impacts of Channel Stuffing include:

  • Financial: Depending on scale and materiality, Channel Stuffing will likely impact a manufacturer’s actual revenue against plan (forecast), artificially inflating revenues in the short term. For publicly listed companies or companies with Private Equity investors, if not detected material cases of Channel Stuffing could be misleading to investors and have regulatory impacts.
  • Customer Satisfaction: Customers of the distributor (i.e. retailers) may be forced or coerced to take on additional inventory, which can impact customer satisfaction, brand and reputation. Where products are easily substituted for a rivals, retailers may even stop offering a product and switch to selling other brands.
  • Inventory distortions: A large volume of unexpected sales (through Channel Stuffing) will result in excess inventory at a retailer, which could take months to clear and may even need to be discounted. This situation can also trigger a manufacturer to build more product, believing that market demand for their product is high. When Channel Stuffing is discovered, one or more parties will be left holding excess inventory, with all the associated implications.
  • Misrpresentation of sales and marketing campaign effectiveness: If a large incidence of Channel Stuffing occurs during a sales campaign or when A|B testing is underway, this may give a wrong impression that the sales are driven by marketing or advertising when they are actually fraudulent. This can cause manufacturers to spend thousands of dollars on marketing and advertising which isn’t actually working.
  • Returns: Some purchasing terms may include provisions for retailers to return excess inventory for a refund a few months after the sale was completed. Sales teams may walk away with a larger bonus, but the manufacturer will be left to unexpectedly refund some or all of the sale, and accept the additional inventory or alternately agree to the inventory being sold at a heavy discount to end users or offloaded onto the resale market. Either way, the manufacturer loses.
man falling carton boxes with negative words

How can you identify Channel Stuffing and what are the indicators?

Identifying frauds and insider threats like Channel Stuffing is really an intelligence and analytics problem. In order to detect fraud, we need to know what we are looking for. The most effective way of doing this is to build one or more typologies that captures how the fraud scheme would actually work in your business, and what to look for. If you’ve never heard of a typology, have a read of my previous article.

If you read Forewarnedblog.com regularly, you will know I frequently talk about the importance of keeping data on incidents – such as through an incident register. Use the details of a previous case (or public cases involving your competitors or similar industries) for Comparative Case Analysis which allows you to develop detailed fraud detection typologies.

Detecting any type of threat in your data involves identifying the patterns (behaviours, indicators), anomalies (unusual activity), and signatures (unique offender characteristics associated with how they perpetrate the fraud). Indicators of Channel Stuffing to look for in the data includes:

  1. Unusually High Sales Volumes: Look for anomalies and spikes in sales figures, especially towards the end of reporting periods or bonus periods
  2. Rising inventory: setting aside seasonable flutuations and sales trends, can inventory increases be reliably explained?
  3. Extended Payment Terms: Do unusual sales volumes correlate with issuing of extended payment periods or more favourable return policies for retailers?
  4. Excessive Discounts or Incentives: Is your business offering unusually high discounts, rebates, or incentives to distributors or retailers?
  5. Returns and Chargebacks: (lagging indicator) Can abnormal rates of returns, chargebacks, or unsold inventory be observed in a period after indicators 1-4 were identified?
  6. Abnormal Sales Patterns: Are there any anomalies such as consistently high sales in the last week of a reporting period?
  7. Increased Distributor or Retailer Complaints: Are partners reporting concerns about pressure to accept more inventory than they can reasonably sell?
  8. Unrealistic Sales Targets: Are they realistic, or are they impossible which encourages sales staff to resort to Channel Stuffing (especially where sales team compensation is commission-based)?

By paying attention to these indicators, you can help businesses detect and prevent channel stuffing, ultimately safeguarding their financial integrity and long-term relationships with distributors and retailers. Additionally, offering guidance on transparent and ethical sales practices will contribute to sustainable business growth.

Four things businesses can do to minimise Channel Stuffing risk

With an understanding of what Channel Stuffing is and the ways it can be identified, there are four key things businesses can do to mitigate the risk:

  • Develop typologies and use data analytics to continuously monitor for, and proactively detect Channel Stuffing
  • Implement transparent, detailed reporting that ensures visibilty of emerging trends and issues that allows early management intervention
  • Ensure appropriate reporting and audit rights are included as part of any distributor compliance program forming part of Distribution Agreements. Channel Managers need to consider this in the Channel Management strategy.
  • Implement programs to perform market surveillance and obtain customer (end user) feedback to understand what is actually happening and who is buying your product. This helps validate observations in data analytics

As with all fraud schemes, paying attention to your data and having a good understanding of your business can help deter and detect frauds early. The bottom lime is that proactively looking for Channel Stuffing can avoid significant downstream pain!

Further Reading

DISCLAIMER: All information presented on ForewarnedBlog is intended for general information purposes only. The content of ForewarnedBlog should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon ForewarnedBlog is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.

An introduction to third party screening processes

6–8 minutes

What is third party screening and why is it important?

Screening is a term applied in the governance, risk and compliance field which equates to one or more database checks. In a screening process, the name of a business, organisation or individual is queried in a database to identify potential matches.

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Where a match is identified, the screening process should include a confirmation step to determine how reliable the match is prior to determining next steps. Screening is used in a range of functions, including:

Many risk and compliance laws and international standards have a reasonable expectation that screening will be performed by business and government as part of routine business operations or as part of customer service delivery. Vendor screening is also an essential part of vendor due diligence and is a foundational element of any supplier integrity framework.

Overview of the third party screening process

Any screening process comprises two stages – screening design and screening delivery – with a total of five steps in the process, as follows:

Stage 1 – Screening Design

  • Determine screening context and objectives: Confirm what you need to achieve by screening. This could be an obligation under legislation, standards, or policies.
  • Agree screening parameters: Determine what you are going to search (sources), when (at what point in a process or relationship), how frequently (e.g. once on commencement of relationship annually ), who will perform the work and where the results will be stored.

Stage 2 – Screening Delivery

  • Perform name-based screening: Query the relevant database for a name manually or automatically, ensuring all steps and results are documented.
  • Qualify potential matches and escalate matters of concern: Have a mechanism to perform further view (investigation) of likely matches
  • Perform Quality Assurance (QA) to validate search parameters, providing assurance that your proceses achieve their intended objectives.

Third Party Screening processes employing ‘name matching’ algorithms are inherently risky

If you are unfamilar with text analytics or computer science, you could be forgiven for thinking every search you do in a database is the same, but this is not correct. Broadly speaking, there are two main types of screening query:

  • Exact Name Matching: This search setting queries the exact phrase you have entered against the database (some systems may also be case sensitive). If there is a typo or names are back to front, no match will be returned giving a erroneous result.
  • Fuzzy Name Matching: Fuzzy matching is used to compare to search strings which may be similar but are not identical based on critieria determine either by the user (when performing the search) or by the algorithm.
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Common problems encountered when designing your screening process (Stage 1 above) include:

  • Spelling errors
  • Truncated words
  • Names containing multiple languages (e.g. Arabic + English)
  • Names that have been incorrectly translated to English (either in a database record or in the search parameter)
  • Dealing with initials and titles / honorifics
  • Words that are out of order (e.g. surname -> first name or first name -> surname)
  • Spaces and hyphens
  • Nicknames or unofficial names

When performing screening for compliance purposes, it is common to determine how your screening procesess (including selected search parameters) complies with your organisation’s policy, legislative obligations, or risk appetite. It is also important to understand your data, both in the database and the material you are using to search. If your data quality is poor, you can have the best process in the world but you will still miss something. In a compliance or reputation context, improperly performing screening can have serious financial and legal consequences.

What should businesses screen third parties for?

Precisely what a business screens its vendors for will vary depending on regulatory obligations, internal policy settings and risk appetite. In some cases, the cost of performing the screening may outweigh the risk. Examples of what is commonly employed as part of a screening process include:

Screening is only the first step in any supplier due diligence or third party risk management. Remember that not everything is in a database, and may require an audit or use of investigative techniques for detection. Show and Shadow Factories are one such example.

There are a plethora of screening solutions on the market, particularly for vendors. Some screening solutions are aggregators meaning they offer access to multiple different databases (e.g. financial viability plus adverse media) within the same interface. Many aggregators also offer proprietary reporting and case management tools, as well as continuous monitoring and alerting functionality at a variety of price points.

What about emerging markets where there is no third party data?

Screening tools are powered by databases, so the quality of the output reflects the data quality inputs. I have previously worked with clients to test the accuracy, coverage and reliability of paid proprietary databases against known results to determine whether the information holdings of paid databases are as accurate as they claim.

Unfortunately, the results of these comparisons haven’t always been great, particularly when it comes to data quality in emerging markets. Here are three things to consider in this scenario:

  • Consider the type of record and what the regulatory obligations are for updating that record in the given jurisdiction. A country which provides 3 months for company secretaries to register a change of director is not going to show up in a database just because the company has made a press announcement
  • Understand whether the database vendor collects the records themselves, or if they are an agregator (or worse, an aggregator of aggregators). The closer your provider is to the primary source the greater the likely the record will be accurate and timely
  • Remember that errors can be made in declarations or when transposing information unless the country uses data validation tools. Some errors can be intentional, such as where a front company provides fictitious director details

When designing your screening process, it pays to understand what you are doing and why, and confirm this meets your requirements and acceptance criteria.

Further Reading

DISCLAIMER: All information presented on PaulCurwell.com is intended for general information purposes only. The content of PaulCurwell.com should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon PaulCurwell.com is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.

Business Email Compromise – persistent threat or consistently mismanaged?

4–6 minutes

What is Business Email Compromise (BEC)?

I remember working in banking when BEC first happened – according to Google, this was around 2013. In our bank security department, we worked out how the fraud scheme worked, quickly developed internal controls and process improvements to reduce our vulnerabilities, and effectively treated the risk. So why in 2023, ten years later, are business owners still falling victim to BEC and other scams? More concerning, some executives only hear about BEC when they have become a victim – so what is BEC and how does it happen?

BEC is a type of fraudulent email scheme (scam) – more specifically a cybercrime – where fraudsters attack a company’s internal processes or functions. Most commonly, I come across BEC in relation to invoicing scams or banking transactions, but there are also other less common variations. Criminals use phishing techniques, which involve well crafted or deceptive emails, and in some cases other social engineering tactics as well, to convince an employee or manager that they are legitimate.

an exhausted woman reading documents
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At times, these emails may even be combined with other channels such as phone calls to reinforce the sense of urgency, build trust and rapport with the victim. A simple ‘BEC attack example’ involves 4 phases – research & reconnaisance, targeting, attack, escape – as illustrated below:

Here’s an example how BEC could play out:

BEC is still happening – why?

As a cybercrime / online fraud, the simple TTP (Tactics, Techniques, Procedures) employed by criminals mean and the ensuing response by workers means BEC is still going strong. According to the Australian Competition & Consumer Commission (ACCC) ‘Targeting scams 2022‘ report:

  • In 2022, Australian’s reported $569million in losses to ScamWatch, a 76% increase on the previous year
  • The volume of incidents has decreased – but the value of incidents has increased (average losses have increased by 224% since 2020)
  • Losses from False Billing scams totalled $24million in 2022

These statistics demonstrate the size of this problem. Clearly, businesses need to do more to manage fraud, cybersecurity and scam risks.

Why is BEC still this prominent? Simple – because it works.
For criminals, fraudsters and scammers, it’s quick, cheap and profitable.

People are too busy to stop and think about what they are doing or take process shortcuts, to trusting of what happens online due to poor security awareness or inadequate fraud awareness training, or because the way the scammer delivers their ‘attack’ email is so well crafted it gets the recipient on the hook easily and convinces them it’s legitimate.

For managers, its important to realise that BEC has a strong nexus to your Insider Risk Management program – BEC scams cannot succeed without a wilful, complacent or ignorant insider.

A strong Trusted Insider program should be mutually reinforced and supported by a strong security culture, where all staff (including contractors and casuals, not just employees) understand and embrace the importance of security to your business. If security awareness is low and you have a poor security culture, employees and contractors can be complacent or even ignorant of the risk.

How to prevent BEC and other scams?

Who typically gets targeted? Because BEC frauds primarily target the invoicing process, staff in accounts and procurement are most likely to be targeted, as well as potential line managers, executives and their assistants.

1. Up your game – improve culture and awareness

Whilst all staff in your organisation should have some level of fraud and security awareness, staff in these roles should have a high level of understanding about BEC, it’s various forms, and how prolific it is.

2. Identify, assess and manage the risk

Too often, I find organisations which haven’t stopped to think about how fraud and security issues can materialise in their business. Business need to perform a detailed security risk assessment to understand how and where they may be vulnerable to cybersecurity or fraud compromise. Any security or fraud risk assessments should be regularly updated to reflect changes in the business and its operations.

3. Review your business processes and internal controls

Frauds and scams differ from violent crimes in that they exploit a business process. To succeed, criminals must complete a particular task, often in a specific order. For a business, each of these tasks is a vulnerability unless you have sufficient internal control coverage to mitigate these risks.

In practice, I find overlaying a process map of the scam or fraud from the criminals (external) perspective onto the internal business process helps identify gaps (vulnerabilities). This is often done in Red Teaming and other Security Assurance activities.

Further Reading

DISCLAIMER: All information presented on ForewarnedBlog is intended for general information purposes only. The content of ForewarnedBlog should not be considered legal or any other form of advice or opinion on any specific facts or circumstances. Readers should consult their own advisers experts or lawyers on any specific questions they may have. Any reliance placed upon ForewarnedBlog is strictly at the reader’s own risk. The views expressed by the authors are entirely their own and do not represent the views of, nor are they endorsed by, their respective employers. Refer here for full disclaimer.