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Fraud Prevention

Abuse of aid is a serious problem facing aid providers in fragile conflict and post-conflict areas. Aid organizations operate in some of the most high-risk environments in the world, typically in the bottom quarter of the Transparency International (TI) Corruption Perceptions Index. In theory, this should profoundly influence the way that organizations prepare themselves for work in these difficult situations. However, many organizations are unable to accurately quantify the extent to which fraud risk affects their operations and lack the data necessary to formulate an effective response.

Treadway’s expertise working in such contexts provides the insight into how fraud risks occur and how aid interacts with the local context to create incentives for aid abuse and diversion. With field-tested models for data collection and analysis, Treadway aims to revolutionize the way clients detect, deter, prevent, and respond to threats to their mission.

We understand that a driving limitation to the utility of many counter-fraud controls is the belief that these measures interfere with a fast-paced emergency response. In reality, the battle to make an operation as corruption-free as possible is won or lost long before the first aid truck leaves dispatch. Adequate training, planning and preparation in the preoperative phase, together with sufficient reflective learning, are crucial.

By changing the way that providers think about and perform holistic risk management, Treadway enables organizations to better understand their vulnerabilities and formulate safeguards against the more significant threats to mission.

 
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Our Fraud Prevention services include:

  • Assessing the effectiveness and efficiency of current risk responses against the full breadth of strategic, operational, financial and compliance risks
  • Providing global standardization in counter-fraud risk management, red flags and compliance
  • Providing counter AML, counter terrorist financing, and sanctions support
  • Evaluating the effectiveness of organizational risk culture
  • Providing systems audits and risk assessments
  • Enhancing due diligence for high-risk local environments
  • Developmening incident reporting mechanisms, databases, and case management
  • Providing internal investigation and audit support


 

Treadway is an effective partner for organizations looking to bolster their compliance systems. We provide clients with advisory services and practical solutions to mitigate and remediate compliance and regulatory risk through:

  • AML/ CTF, code of conduct and due diligence consultation
  • Comprehensive institutional policy and procedures review and design
  • Assess, design, and implement enterprise risk management capacities
  • Tone at the top, ethics and compliance training
  • Local partner risk and compliance scoring
  • Supply chain and informal money transfer system enhanced due diligence for volatile environments


 

Governance and Compliance

A common theme for NGOs working in fragile environments is the greater autonomy and devolved governance structure that is adopted in favor of programmatic agility. While these management arrangements provide innumerable advantages, complications can arise if a corresponding level of accountability is committed to. The work culture of field offices can perpetuate local, unethical, incentives, rather than operating in keeping with the mission and values of the organization at large. For many assistance operations, the most highly prioritized objective is the delivery of aid, and if highly empowered managers are not incentivized properly, they may de-prioritize the effective management of ethics and compliance in favor of expedient delivery. 

In recent years, donor scrutiny of the financial management of the partners of humanitarian and development organizations has increased. It is important for aid organizations to respond to this constructively, by demonstrating greater resilience and compliance. 


Training & Workshops

All personnel in an organization play a critical role in fighting aid waste and abuse. According to the ACFE Report to the Nations, more than 50% of all reported allegations of misconduct come from staff tips. That is why investing in staff training on how to deter, prevent, detect, and respond to threats is critical.

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The problem is that management arrangements are often complex and staff are unaware of how their role fits in to the greater fight against fraud and waste. For large international aid providers, many missions require local partnerships to provide greater access, accountability, and buy-in. As a result, staff on each side of the partnership may be unclear regarding their compliance duties and may assume that risks can be “transferred” to the other party.

Consequently, aid organizations often suffer from under-detection and under-reporting of important information about threats to mission-- this is especially acute for small charities or local partnerships. Without the ability to detect these threats, and share data about it internally and externally, aid organizations cannot fully grasp the scope of the problem or its solution. 

Breaking the cycle requires working with lead and partner staff at each level of operation to clarify their roles and responsibilities in the process of fraud prevention. Treadway delivers training and workshops that are engaging and capture the underutilized knowledge and innovation of staff to comprehend the ways in which their organization can better navigate fragile environments.


Operational Research

Understanding the local operating context is an undeniably crucial component in ensuring that missions and programs can operate safely and are able to understand and manage the threats they face. To that end, we recognize that many aid organizations have been presented with highly sophisticated, data management systems to help inform their “atmospheric” awareness. Too often, however, these expensive research systems are poorly integrated into the organization’s structure and are too unwieldy to be effective.

In fact, our experience tells us that it is not typically a lack of understanding that leads to an inability to detect and manage risks, but the fact that important information is siloed within separate parts of an organization. Moreover, risk mitigation measures enacted within a department are likely to be ad-hoc stopgaps that remedy the failures of handbook policies that do not effectively adapt to the complexities of local environments. It is these types of dysfunctions that, over time, can lead to severe risks building up within an organization and which may remain almost undetected and unknown to senior management.

Treadway believes the solution to this problem is not necessarily to have more research resources, but better ones which take into account the personal, structural and technical strengths and weaknesses of the organization. To that end, Treadway’s research experts understand the importance of leveraging individual networks, country-specific expertise and social media in the development and sustaining of high-quality research units that provide in-depth, precise and action-orientated outputs for an organization.

We believe that research must be operational. With wide-ranging research and research management experience, Treadway will find the information management solution that is appropriate for the human strengths and weaknesses of each organization.

 
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Security Management & Access

A core responsibility of any aid provider is to ensure the duty of care for staff, partners, and beneficiaries. While there is broad recognition of the significance of this responsibility, organizations differ considerably in the extent to which security inputs are a systematic part of daily program coordination.

While donors continue to delineate higher expectations for security planning and conflict sensitivity, organizations retain autonomy on developing the structure and functions of their security departments. Fundamentally, security departments must be able to articulate how the risks of operating in any context can be avoided, assumed, transferred, or mitigated. Unfortunately, the departments are often cut off from vital programmatic inputs to be able to perform this function in a timely, consistent, and accurate way. Treadway’s approach to security management is based on providing understandable systems that enhance the level of communication and coordination between security and programmatic functions, while enhancing mission-focused decision-making.

The need to work in active conflict zones presents organizations with critical issues regarding compliance to international sanctions and counter terrorist financing regulations. It is important for security departments to articulate how field finance, supply chains, personnel, and programs interact with local conflict dynamics to help department managers enact effective countermeasures. Treadway’s experts are security practitioners, versed in the latest industry standards in countering sanctioned group interference and conflict sensitivity.

Security management solutions include:

  • Programmatically relevant and routine security products which integrate field and spot reporting functions, ‘tripwire’ security advisories and required staff actions
  • Protocol for effective local partner identification, vetting and due diligence
  • Donor compliant early warning system development
  • Quantifiable and dynamic risk mapping and mitigation
  • Security incident management system and response
  • CTF and mitigation strategies for sanctioned group interference