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Fraud monitoring solution

      Ben Oguntala, LLB Hons, LL.M
                 CEO
    www.riesgoriskmanagement.com
Ben.oguntala@riesgoriskmanagement.com
About the Author
                                                       •   Ben Oguntala
                                                       •   Education
                                                            – LLB Hons
                                                            – LL.M
                                                                   •   Financial/Securities regulation
                                                                   •   UK/EC competition law
                                                       •   Forte
                                                            –   Risk Management specialist
                                                            –   Fraud compliance Consultant
                                                            –   Compliance specialist
                                                            –   Data Protection specialist
                                                            –   Information Security Consultant
                                                       •   Previous clients
                                                            –   British Gas
                                                            –   Vodafone
                                                            –   Orange
                                                            –   O2 Telefonica UK
Ben.oguntala@riesgoriskmanagement.com                       –   RWE NPower
CEO – Riesgo Risk Management                                –   BNP Paribas
Telephone – 07812 039867                                    –   Ministry of Justice (London Probation)
                                                            –   Revenue & Customs
                                                            –   Nortel/Motorola/Ericsson/Nokia
“Fraud management is not dissimilar in concept to           –   CapGemini
a building’s architectural integrity, which requires        –   BT
a piecemeal distribution of integrity enforcement           –   KPMG & Cisco
across all of the building blocks.”
Solution overview

                                  Adaptors            Generate alerts

                                 Compliance           PCI | FSA | DPA
                                                      From business
                              Incident reporting
                                                           units
                                 Products &          From assessment
                                  services               checklist
                               Asset baseline          Alert triggers

                              Asset procedure       Manual procedures

                                 Asset policy       Minimum standard
Fraud Information Asset
                             Asset classification   High   Med    Low


                                Asset owner          Point of contact
Introduction                       Fraud management

• Our Fraud management solution includes
  three key strategies                                                   Fraud
                                                                       detection
   – Fraud detection (knowledge of the subsistence of fraud)
        •   Fraud Asset Register
        •   Fraud baseline
        •   Fraud policies & procedures                                 Fraud
        •   Fraud incident reporting                                  prevention
   – Fraud prevention (mechanism to prevent the subsistence of
      fraud)
        •   Fraud Policy enforcement
        •   Technical preventative measures                             Fraud
        •   Fraud baseline implementation                              mitigation
        •   Zero day detection reporting
   – Fraud mitigation (business process by which Fraud risks are
      mitigated and reoccurrence prevention)
        • Fraud risk management
        • Fraud remedial action plan
Our Fraud management framework
The objective of the framework is to cover as a broad a spectrum as possible in your
Estate (Fraud Asset Register across all business units), the next key stage is to determine
the appropriate level of fraud policy that needs to be applied across each asset. Incident
Management, compliance assessment then capture fraud requirements and refer to the
Fraud management team for expert assessment, whilst the Fraud Risk register is maintained
to ensure all risks are captured.
               Fraud            Fraud          Fraud        Fraud trends                           Fraud asset
   Fraud                                                                                                         Fraud risks
             baseline in      detection        trends       subscription                            across all
  incident                                                                                                       across the
             products &         from            from            from                                business
 reporting                                                                                                       enterprise
              services       compliance      authorities     authorities                              units

  Incident   Product &       Compliance        Fraud       Fraud policy                            Fraud asset   Fraud risk
management    Services       assessment      landscape     management                                register     register




                                           FMA




                                                                           Fraud management tool
                                (Fraud management adaptors)

                           Fraud baseline     Fraud detection engine

                                 Fraud monitoring dashboard

                           Fraud reporting      Fraud investigation
Framework objectives
• Fraud exists due to
  weaknesses in an
  organisations security
  framework. Our objective is
  to re-enforce the fortress of
  protection and enhance the
  capability to reduce
  possibility fraud
  perpetration.
                                                                  Fraud
                                      Incident   Fraud policy               Compliance
•    It is not always possible to   management   management
                                                                  Threat
                                                                            assessment
    prevent fraud from                                          landscape
    occurring which is why
    having adequate detection
    capability is equally
    important to zero day                         Fraud asset   Product &
                                                    register     Services
    detect potential fraud in
    your organisation.
                                                                             Fraud risk
                                                                              register
To capture all fraud incidents
                                               reported from all business




                        4
                                                units including helpdesk                            Fraud
                                                                                                   incident



                                                                                    Incident
                                                                                                  reporting
                                               incidents relating to fraud




                             Incidents
                                                                                  management
                                                Setting a baseline for all




                        5
                                                  products & services




                             P&S
                                                                                                   Fraud




                                              regarding fraud and alerting
                                                                                                  services


                                                                                   Services
                                                                                  Product &
                                                                                                 baseline in
                                                                                                 products &




                                                  business processes

                                              All compliance activities will




                        5
                                               be able to report or refer
                                                                                                    from
                                                                                                    Fraud




                                              potential fraud issues to the




                             Compliance
                                                                                                  detection

                                                                                                 compliance


                                                                                  assessment
                                                                                  Compliance




                                               Fraud team for evaluation




                        10
                                               Auto input via subscription




                             Threats
                                                                                                    from
                                                                                                   Fraud




                                                                                   Fraud




                                               on fraud trends and alerts
                                                                                                   trends




                                                                                   Threat
                                                                                 landscape
                                                                                                 authorities




                        10
                             Policies          A framework for distributing



Fraud Management team
                                              fraud policies and procedures
                                                   across the enterprise.
                                                                                  Fraud policy
                                                                                                  &procedures




                                                                                  management
                                                                                                  Fraud policies

                                                                                                  dissemination




                        5




                                              The asset register lists all the
                                               fraud related assets for the
                             Asset register
                                                                                                    units




                                                  organisation across all
                                                                                                                   Framework objectives (1)


                                                                                    register
                                                                                                  business
                                                                                                  across all



                                                                                  Fraud asset
                                                                                                 Fraud asset




                                                      business units

                                                 The fraud risk register
                        5




                                               demonstrate the fraud risks
                                                  associated with the
                             Risk register
                                                                                   register




                                              organisation and the relevant
                                                                                  Fraud risk
                                                                                                  across the
                                                                                                  enterprise
                                                                                                  Fraud risks




                                                         assets
Fraud Management     Sources                  Captures                       FMT dashboard
Implementation
                                   Auto forward from Helpdesk tools
                    Incidents
                                       Manual entries from staff            Incidents        2   3   9

                   Products &      Risk assessment results on fraud
                    services                                               Products &    4       4   8
                                            Fraud baselines                 services
                                        Baseline violation alerts
                   Compliance                                              Compliance
                                                                                         1       3   4
                    referrals                                               referrals
                                 Fraud query referral from compliance

                      Fraud                                                   Fraud
                                     Fraud threats from authorities                      2       3   5
                     threats                                                 threats

                                 Policies & procedures sent to all BUs
                      Fraud                                                   Fraud
    management




                    policies &           Update to procedures               policies &   3       3   6
      Fraud




                   procedures                                              procedures
                                  Fraud assets for each business unit
                                                                           Fraud asset
                                                                                         1       3   4
                   Fraud asset       Asset owner for responsibility          register
                     register           Fraud risk for each asset          Fraud risk
                                                                                         5       3   8
                                                                            register
                                 Risks from assets, products or services
                   Fraud risk
                    register         Risks from audit assessments

                                    Risks from the threat landscape
Fraud implementation stages
Fraud asset register

• The creation of the Fraud Asset register gives you an idea of the scale of your fraud
  estate
• No. of Assets per business unit
• Type of information contained and risk ratings

Fraud Policy management

• The creation of the Fraud policies relating to the Fraud Assets
• Definition of the Fraud procedures, triggers across each Asset

Products and services

• Creation of Fraud risk assessment checklist
• Inclusion of the Fraud risk assessment checklist into the risk assessment regime for
  all new products and services

Compliance

• Inclusion of the Fraud risk assessment to all compliance activities
• Inclusion of 3rd party engagement to include fraud risk assessment checklist
Fraud implementation stages (1)
Incident management

• Capture of all incidents relating to fraud onto the Fraud dashboard
• Automatic alerts generated when new fraud incidents are raised
• All business units will have the capability to register a fraud incident

Fraud risk register

• An active register of all the fraud risk across all the business units
• Contains the associated Fraud policy or fraud Asset
• Fraud asset owners are included in the issues related to his/her asset

Internal/External Audits

• Internal/External auditors will have the capability to record non
  compliances against Fraud Assets, Policies or Departments.
Fraud Implementation stages (2)
                           Creation of         Across all business
        Fraud asset
1                           the fraud             units of the
          register
                          asset register           enterprise                                                      7
                                                                                                        Fraud
                                           Policies & procedures to support                           landscape
                      Fraud policy
                                           each type of the Fraud assets for
                      management
              2                                      the enterprise
                                                                                                          Fraud
                                                     All products & services are                      trends and
                                 Product &
                                                    risk assessed to comply with         3            alerts from
                                  Services
                                                            Fraud policies                                   the
                                                        Compliance teams                              authorities
                                 Compliance                                                           are impact
                                                     implement fraud checklist           4
                                 assessment                                                           assessed &
                                                       in their assessments
                                                                                                         filtered
                                                       All fraud incidents are
                                  Incident                                                                  into
                                                    captured & escalated to the          5
                                management                                                              relevant
                                                             Fraud team
                                                                                                          areas
                                                       Fraud risks from all the
                                  Fraud risk
                                                          modules without                6
                                   register
                                                        immediate mitigation



Incidents         P&S        Compliance           Threats        Policies         Asset register   Risk register

    4              5              5                 10               10                 5                5

                                            Fraud Management team
Operational overview
                                                       Incidents
1. Visibility
     • End to end visibility                                       Fraud Asset
2. Joined up approach                  Fraud alerts
                                                                     register
     • All relevant units
         involved
3. zero day detection of
   Fraud events
     1. Email alerts
     2. Dashboard listing         Fraud                 Fraud
                                                                           Fraud Risk
    rd party inclusion          policies &            management
4. 3                                                     team               Register
                               procedures
     1. Incident reporting
     2. Fraud policy
         application
     3. Compliance

                                       Compliance
                                                                   Compliance
                                       assessment
                                                        Fraud
                                                        Threat
                                                       register
Fraud monitoring dashboard
    Incidents     P&S       Compliance       Threats       Policies      Asset register    Risk register

       4            5            5              10            10               5                 5

                                         Fraud Management team

•    Incident
       – Generates incidents reported from any of the business units
       – Generates automated alerts from any of the Fraud assets
•    Products & services
       – Reports fraud risks from new products and services that have failed fraud checklist or baseline
•    Compliance
       – Reports non compliance that create fraud risks
•    Threats
       – Subscription based fraud alert services from the authorities that alert on new fraud threats to
         the organisation
       – Provides guidance on how to improve fraud prevent, detection and mitigation mechanisms
•    Policies
       – Reports policy and procedure violations from Fraud assets
•    Asset register
       – Reports on the number of assets per business unit
       – Indicates which of the assets have risks associated with them
•    Risk register
       – List all the risks associated with the organisation and includes the relevant assets
Inside the Fraud management tool
                                                              Fraud Asset      A register of Asset &
                                                                register        their Fraud impact

                                                                               Host based adaptors       Retrieve information and
                                                                  FMA
                                                                                    for servers           send to the dashboard

                                                                                Creation of a fraud           All violations of the
                                                             Fraud baseline
               FMA                                                             baseline for the estate       baseline are reported
    (Fraud management adaptors)     Fraud management tool
                                                            Fraud detection    Setting to determine the level of
     Fraud        Fraud detection                               engine             detection to be reported
    baseline          engine
                                                            Fraud monitoring     All detections and alerts are
                                                               dashboard          placed on the dashboard
     Fraud monitoring dashboard
                                                                                Reports on all activities within
                                                            Fraud reporting
      Fraud           Fraud                                                        the Fraud framework.
    reporting      investigation
                                                                 Fraud            Fraud investigators will be able to take on
                                                              investigation    records for investigation and close off if needed.



The tool is designed to set a fraud baseline across your estate ensuring loop holes are covered off.
It also allows for adaptors to be installed in order to retrieve breach or non compliance alerts .
All features are captured on the dashboard in real time and alerts sent out to the fraud team.
Snapshots

Fraud Asset Register               Fraud Assets by Business unit
Snapshot (1)
Fraud Incidents reported per Business unit




                                             Fraud Risk register
Representation of all the business units in an
organisation with each Head of Department and
             Fraud point of contact
                                                                   Assets
                                                   Fraud estate overview with no. of Fraud
Implementation project
               Gap analysis                      Project design                   Implementation                     Roll out
     Stage 1




                                       Stage 2




                                                                        Stage 3




                                                                                                           Stage 4
               • Assess your current             • Designing your                 • Once the HLD is                  Taking stage 3
                 estate & your                     requirements based               designed and signed
                 objectives                        on the result of                 off, we initiate the
                                                                                                                     and
               • Release of your BRS               stage1                           implementation and               methodically
               • Scope definition                • Release of the HLD               across a portion of              rolling out the
                                                   to be signed off                 your estate
                                                                                                                     solution to the
                                                                                  • We confirm that all
                                                                                    the adaptors can                 rest of your
                                                                                    trigger alerts.                  estate.



The implementation project takes 6 months and 3 Man resources. The number of resources
may vary due to the scope of the project.

The costs associated include:
-Software licence
- incident management licence
-Support and maintenance

The solution is designed to be a cost effective means to curtailing fraud within your estate.
Contact details
• Ben Oguntala
• Email
  – Ben.oguntala@riesgoriskmanagement.com
• Telephone
  – +44 7812 039 867

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Fraud Monitoring Solution

  • 1. Fraud monitoring solution Ben Oguntala, LLB Hons, LL.M CEO www.riesgoriskmanagement.com Ben.oguntala@riesgoriskmanagement.com
  • 2. About the Author • Ben Oguntala • Education – LLB Hons – LL.M • Financial/Securities regulation • UK/EC competition law • Forte – Risk Management specialist – Fraud compliance Consultant – Compliance specialist – Data Protection specialist – Information Security Consultant • Previous clients – British Gas – Vodafone – Orange – O2 Telefonica UK Ben.oguntala@riesgoriskmanagement.com – RWE NPower CEO – Riesgo Risk Management – BNP Paribas Telephone – 07812 039867 – Ministry of Justice (London Probation) – Revenue & Customs – Nortel/Motorola/Ericsson/Nokia “Fraud management is not dissimilar in concept to – CapGemini a building’s architectural integrity, which requires – BT a piecemeal distribution of integrity enforcement – KPMG & Cisco across all of the building blocks.”
  • 3. Solution overview Adaptors Generate alerts Compliance PCI | FSA | DPA From business Incident reporting units Products & From assessment services checklist Asset baseline Alert triggers Asset procedure Manual procedures Asset policy Minimum standard Fraud Information Asset Asset classification High Med Low Asset owner Point of contact
  • 4. Introduction Fraud management • Our Fraud management solution includes three key strategies Fraud detection – Fraud detection (knowledge of the subsistence of fraud) • Fraud Asset Register • Fraud baseline • Fraud policies & procedures Fraud • Fraud incident reporting prevention – Fraud prevention (mechanism to prevent the subsistence of fraud) • Fraud Policy enforcement • Technical preventative measures Fraud • Fraud baseline implementation mitigation • Zero day detection reporting – Fraud mitigation (business process by which Fraud risks are mitigated and reoccurrence prevention) • Fraud risk management • Fraud remedial action plan
  • 5. Our Fraud management framework The objective of the framework is to cover as a broad a spectrum as possible in your Estate (Fraud Asset Register across all business units), the next key stage is to determine the appropriate level of fraud policy that needs to be applied across each asset. Incident Management, compliance assessment then capture fraud requirements and refer to the Fraud management team for expert assessment, whilst the Fraud Risk register is maintained to ensure all risks are captured. Fraud Fraud Fraud Fraud trends Fraud asset Fraud Fraud risks baseline in detection trends subscription across all incident across the products & from from from business reporting enterprise services compliance authorities authorities units Incident Product & Compliance Fraud Fraud policy Fraud asset Fraud risk management Services assessment landscape management register register FMA Fraud management tool (Fraud management adaptors) Fraud baseline Fraud detection engine Fraud monitoring dashboard Fraud reporting Fraud investigation
  • 6. Framework objectives • Fraud exists due to weaknesses in an organisations security framework. Our objective is to re-enforce the fortress of protection and enhance the capability to reduce possibility fraud perpetration. Fraud Incident Fraud policy Compliance • It is not always possible to management management Threat assessment prevent fraud from landscape occurring which is why having adequate detection capability is equally important to zero day Fraud asset Product & register Services detect potential fraud in your organisation. Fraud risk register
  • 7. To capture all fraud incidents reported from all business 4 units including helpdesk Fraud incident Incident reporting incidents relating to fraud Incidents management Setting a baseline for all 5 products & services P&S Fraud regarding fraud and alerting services Services Product & baseline in products & business processes All compliance activities will 5 be able to report or refer from Fraud potential fraud issues to the Compliance detection compliance assessment Compliance Fraud team for evaluation 10 Auto input via subscription Threats from Fraud Fraud on fraud trends and alerts trends Threat landscape authorities 10 Policies A framework for distributing Fraud Management team fraud policies and procedures across the enterprise. Fraud policy &procedures management Fraud policies dissemination 5 The asset register lists all the fraud related assets for the Asset register units organisation across all Framework objectives (1) register business across all Fraud asset Fraud asset business units The fraud risk register 5 demonstrate the fraud risks associated with the Risk register register organisation and the relevant Fraud risk across the enterprise Fraud risks assets
  • 8. Fraud Management Sources Captures FMT dashboard Implementation Auto forward from Helpdesk tools Incidents Manual entries from staff Incidents 2 3 9 Products & Risk assessment results on fraud services Products & 4 4 8 Fraud baselines services Baseline violation alerts Compliance Compliance 1 3 4 referrals referrals Fraud query referral from compliance Fraud Fraud Fraud threats from authorities 2 3 5 threats threats Policies & procedures sent to all BUs Fraud Fraud management policies & Update to procedures policies & 3 3 6 Fraud procedures procedures Fraud assets for each business unit Fraud asset 1 3 4 Fraud asset Asset owner for responsibility register register Fraud risk for each asset Fraud risk 5 3 8 register Risks from assets, products or services Fraud risk register Risks from audit assessments Risks from the threat landscape
  • 9. Fraud implementation stages Fraud asset register • The creation of the Fraud Asset register gives you an idea of the scale of your fraud estate • No. of Assets per business unit • Type of information contained and risk ratings Fraud Policy management • The creation of the Fraud policies relating to the Fraud Assets • Definition of the Fraud procedures, triggers across each Asset Products and services • Creation of Fraud risk assessment checklist • Inclusion of the Fraud risk assessment checklist into the risk assessment regime for all new products and services Compliance • Inclusion of the Fraud risk assessment to all compliance activities • Inclusion of 3rd party engagement to include fraud risk assessment checklist
  • 10. Fraud implementation stages (1) Incident management • Capture of all incidents relating to fraud onto the Fraud dashboard • Automatic alerts generated when new fraud incidents are raised • All business units will have the capability to register a fraud incident Fraud risk register • An active register of all the fraud risk across all the business units • Contains the associated Fraud policy or fraud Asset • Fraud asset owners are included in the issues related to his/her asset Internal/External Audits • Internal/External auditors will have the capability to record non compliances against Fraud Assets, Policies or Departments.
  • 11. Fraud Implementation stages (2) Creation of Across all business Fraud asset 1 the fraud units of the register asset register enterprise 7 Fraud Policies & procedures to support landscape Fraud policy each type of the Fraud assets for management 2 the enterprise Fraud All products & services are trends and Product & risk assessed to comply with 3 alerts from Services Fraud policies the Compliance teams authorities Compliance are impact implement fraud checklist 4 assessment assessed & in their assessments filtered All fraud incidents are Incident into captured & escalated to the 5 management relevant Fraud team areas Fraud risks from all the Fraud risk modules without 6 register immediate mitigation Incidents P&S Compliance Threats Policies Asset register Risk register 4 5 5 10 10 5 5 Fraud Management team
  • 12. Operational overview Incidents 1. Visibility • End to end visibility Fraud Asset 2. Joined up approach Fraud alerts register • All relevant units involved 3. zero day detection of Fraud events 1. Email alerts 2. Dashboard listing Fraud Fraud Fraud Risk rd party inclusion policies & management 4. 3 team Register procedures 1. Incident reporting 2. Fraud policy application 3. Compliance Compliance Compliance assessment Fraud Threat register
  • 13. Fraud monitoring dashboard Incidents P&S Compliance Threats Policies Asset register Risk register 4 5 5 10 10 5 5 Fraud Management team • Incident – Generates incidents reported from any of the business units – Generates automated alerts from any of the Fraud assets • Products & services – Reports fraud risks from new products and services that have failed fraud checklist or baseline • Compliance – Reports non compliance that create fraud risks • Threats – Subscription based fraud alert services from the authorities that alert on new fraud threats to the organisation – Provides guidance on how to improve fraud prevent, detection and mitigation mechanisms • Policies – Reports policy and procedure violations from Fraud assets • Asset register – Reports on the number of assets per business unit – Indicates which of the assets have risks associated with them • Risk register – List all the risks associated with the organisation and includes the relevant assets
  • 14. Inside the Fraud management tool Fraud Asset A register of Asset & register their Fraud impact Host based adaptors Retrieve information and FMA for servers send to the dashboard Creation of a fraud All violations of the Fraud baseline FMA baseline for the estate baseline are reported (Fraud management adaptors) Fraud management tool Fraud detection Setting to determine the level of Fraud Fraud detection engine detection to be reported baseline engine Fraud monitoring All detections and alerts are dashboard placed on the dashboard Fraud monitoring dashboard Reports on all activities within Fraud reporting Fraud Fraud the Fraud framework. reporting investigation Fraud Fraud investigators will be able to take on investigation records for investigation and close off if needed. The tool is designed to set a fraud baseline across your estate ensuring loop holes are covered off. It also allows for adaptors to be installed in order to retrieve breach or non compliance alerts . All features are captured on the dashboard in real time and alerts sent out to the fraud team.
  • 15. Snapshots Fraud Asset Register Fraud Assets by Business unit
  • 16. Snapshot (1) Fraud Incidents reported per Business unit Fraud Risk register
  • 17. Representation of all the business units in an organisation with each Head of Department and Fraud point of contact Assets Fraud estate overview with no. of Fraud
  • 18. Implementation project Gap analysis Project design Implementation Roll out Stage 1 Stage 2 Stage 3 Stage 4 • Assess your current • Designing your • Once the HLD is Taking stage 3 estate & your requirements based designed and signed objectives on the result of off, we initiate the and • Release of your BRS stage1 implementation and methodically • Scope definition • Release of the HLD across a portion of rolling out the to be signed off your estate solution to the • We confirm that all the adaptors can rest of your trigger alerts. estate. The implementation project takes 6 months and 3 Man resources. The number of resources may vary due to the scope of the project. The costs associated include: -Software licence - incident management licence -Support and maintenance The solution is designed to be a cost effective means to curtailing fraud within your estate.
  • 19. Contact details • Ben Oguntala • Email – Ben.oguntala@riesgoriskmanagement.com • Telephone – +44 7812 039 867