Operational Risk [19]

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Bullet points include: An agent who chooses to defraud is assumed not to report fraud committed by others since this would attract scrutiny. Arguably not realistic in practice, especially if agent ‘expected’ to monitor subordinates. Individual who chooses neither to commit fraud nor monitor others may be penalised as accessory to fraud, if fraud inside member’s span of responsibility. Individual who chooses not to commit fraud but to monitor others may rewarded if fraud is detected as a result of their investigations

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