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    The Global Economic Crime SurveyEconomic crime in a downturnNovember 2009

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 2

    We are pleased to present our th Global Economic Crime Survey. Our 2009 survey scrutinisedraud and associated integrity risks during a period in which most territories around the worldexperienced either a dramatic economic downturn or at least a signicant slowdown. Against this

    backdrop, the survey investigated the root causes o economic crime, and the way in which itaects businesses worldwide.

    Economic crime is a truly global phenomenon. Over 3,000 senior representatives o organisations in54 countries (including respondents spread rom Australia to Venezuela) completed our web-basedsurvey. To enable us to determine long-term trends, respondents were asked a number o corequestions on raud. They were also asked a number o other questions specically on the raud threatsthat emerge in an economic downturn. With 62% o respondents reporting that their organisationshad suered a decline in revenues during the last 12 months, we were able to obtain some valuableinsights into the types and causes o raud in an economic downturn. Further details o the survey

    demographics are presented in the methodology and acknowledgements section o this report.

    Introduction

    quitprintEconomic crime thrivingin the downturn

    A deeper dive into

    the statistics

    The fraud

    horizon

    Methodology and

    acknowledgements

    ContactsIntroduction

    Continued

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 3

    more incentives or rauds, andgenerating more opportunities orraudsters to perpetrate their crime.

    In this climate, we are continuingto develop our knowledge andunderstanding o raud and itsperpetrators. With this insight, we areable to recommend what organisationscan do when it comes to tacklingraud. We are very grateul to all therespondents and organisations thatparticipated in the survey, withoutwhom we would not have been ableto produce this report. Crucially, we

    hope that our ndings will urtherassist readers in their ongoing ghtagainst economic crime.

    Global Economic Crime Survey

    Leadership Team:

    Tony PartonPartner, London, United Kingdom

    Vidya RajaraoPartner, Mumbai, India

    Steven SkalakPartner, New York, USA

    November 2009

    We have divided the report into theollowing sections:

    Fraud thriving in the downturn

    in which we outline topical areaso interest arising rom an economicdownturn and the heightened risko raud, as well as the key themesarising rom the core survey questions.

    A deeper dive into the statistics where we take a closer look at thestatistics and at trends related tovictims, types and perpetrators oraud, the underlying causes andactors behind raud and the impacton management and regulatorybodies. This section also highlightsdierences in results reported byrespondents across the world.

    The fraud horizon here we identiyraud trends in the uture, as well aswhat organisations may be able todo to combat them.

    Our survey shows that economiccrime continues to be a serious issue

    aecting organisations worldwide,despite increasing regulatory actions.This is particularly so today, in anenvironment where the globaleconomic downturn has signicantlyincreased pressures on organisationsand individuals to perorm, creating

    the respondents to obtaininormation on the dierent typeso economic crime, the impact

    o such economic crime, bothnancial and in terms o collateraldamage, and the concrete causeso economic crime, as well as therange o remedial actions taken.

    2. Questions related to fraud ina downturn. Our survey givesin-depth insights into raud acedby organisations in times oeconomic downturn. Our ocusedinvestigation into this area has

    enabled us to understand theimpact the downturn has hadon levels, types and causes oeconomic crime.

    3.Analysis of trends over time.Since beginning these surveys,we have continued to ask a coregroup o questions, and additionalquestions as appropriate torefect current issues likely to beimpacting businesses around the

    world. Because our data nowencompasses a 10-year period,we are equipped to identiy andassess long-term developmentsand trends in the ght againsteconomic crime.

    We are particularly grateul or theassistance o the INSEAD businessschool with the scope, content and

    subsequent interpretation o thesurvey data. Their involvement hasadded an extra dimension to thesurvey, bringing signicant valueto this years report. We would liketo take this opportunity to thankProessor Douglas Frank o INSEADbusiness school or his insights andcontribution to the survey.

    The aim o the 2009 survey wasprimarily to:

    Assess corporate attitudes towardseconomic crime in the currenteconomic environment, particularlyto understand how economiccrime changes during an economicdownturn; and

    Understand and explore the trendsin relation to economic crime andthe reasons why these might arise.

    The 2009 survey was based on the

    ollowing research strategies:

    1. Survey of organisation executives.This survey delivers ndings inwhich executives report their ownexperiences in the ght againsteconomic crime. We surveyed

    quitEconomic crime thrivingin the downturn

    A deeper dive into

    the statistics

    The fraud

    horizon

    Methodology and

    acknowledgements

    ContactsIntroduction print

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 4

    had declined. We also expected thatrespondents reporting a stable levelo nancial perormance would havereported ewer rauds, but they reportthe same requency o incidents asthe 62% o respondents reporting adecline. This demonstrates that allorganisations, whether or notsuering a decline in nancialperormance in a downturn, are atrisk o economic crime. Hence, weconclude that economic crimeremains a pervasive business risk,which does not discriminate among

    (43% and 42%, respectively)experienced in the past year weregreater compared to 12 months ago.

    Given the 40%-60% split in viewsas to whether the recession hadincreased the risk or the incidence

    o economic crime, we expected thatthe 38% o organisations reportingno impact o a downturn would havebetter, that is lower economic crimeexperience. We ound, however, thatorganisations that had not sueredrom an economic downturn reportedsimilar levels o economic crime ascompared to those whose businesses

    Fraud pervasive, persistentand pernicious

    One in three respondents reported

    economic crimes in the last 12months within their organisationsin the country in which they wereprimarily based. The survey datashows that the incidence o economiccrime varies by territory; somecountries, mainly those in emergingmarkets, experienced much higherlevels o raud than the average,as much as 71% in one country(see table under the global picture

    section); by industry sector, some(notably insurance, nancial servicesand communications) reporting higherlevels o raud than others; by sizeand type o organisation. But noorganisation is immune.

    O the 3,037 respondents to oursurvey globally, 905 (30%) reportedhaving experienced at least oneincident o raud in the last 12 monthsalone. Not surprisingly, the global

    economic downturn has signicantlyaected most organisations, with 62%o respondents having reported adecline in nancial perormance overthe last 12 months and 40% o allrespondents saying that the risk oeconomic crime had risen due tothe recession. Indeed, almost halo our respondents believed that theincidences and cost o raud

    Economic crimethriving in thedownturn

    quitIntroduction A deeper dive intothe statistics

    The fraud

    horizon

    Methodology and

    acknowledgements

    Contacts

    Continued

    Economic crime thriving

    in the downturn

    the global picture

    print

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 5

    Figure 2: Factors contributing towards increased

    incentives/pressures to commit raud

    0 10 20 30 40 50

    25

    23

    18

    14

    13

    Financial targets more

    difficult to achieve

    Fear of losing jobs

    Desire to earn personalperformance bonuses

    For senior executivesto achieve desired

    financial results

    Bonuses not paid this year

    Maintain financial performanceto ensure lenders do not

    cancel debt facilities

    Other factors

    There is a belief thatcompetitors are paying bribesto win contracts

    47

    37

    27

    % Incentives/pressures

    % respondents who believe increased incentives/pressures are the most

    likely reason for greater risk of economic crime in a downturn

    Among the 40% o respondents who

    believed that there is a greater risk

    o raud in the current economic

    environment, 18% identied increased

    opportunities or committing raud as

    the root cause (see gure 1). In this

    respect, Sta reductions resulting in

    ewer resources deployed on internal

    controls was identied as the main

    contributory actor (62%, see gure 3).

    Financial diculties in a downturn

    when aced with evidence o a

    downturn. Our survey highlighted that

    no industry or organisation is immune

    to raud and it would appear that the

    current economic situation is leading

    to severe, oten cut-throat competition.

    Individuals eel under pressure to

    achieve targets when times become

    dicult, or when it seems impossible

    to achieve targets. Furthermore, an

    individuals personal position may

    be threatened by reductions in pay

    or the risk o possible unemployment.

    Consequently, the temptation to infate

    revenues, and/or omit expenses, is

    more likely to overrule ethical values.

    Our survey revealed that a key actor

    resulting in increased pressure to

    commit raud is job security. O the

    respondents who believed that

    underlying pressures or incentives

    are the main drivers or greater raud

    risk, 37% reported that People are

    araid they might lose their jobs

    (see gure 2). Furthermore, when

    employees are terminated, those

    who remain employed eel increasinglypressured where they eel that their

    own jobs are under threat. Employee

    termination and additional cost

    reduction measures may be inevitable

    in a downturn, but management

    should consider whether such

    actions could, in turn, compromise

    the organisations ability to ght

    economic crime.

    Figure 1: Fraud triangle

    Attitude/Rationalisation

    14%

    !FRAUD RISK

    Incentive or Pressure

    68%

    Opportunity

    18%

    Interestingly, among the respondents

    who believed that there is a greater

    risk o raud in the current economic

    environment, two-thirds elt that

    increased incentives or pressures

    are the most likely underlying cause.

    The most commonly reported actor

    contributing to these increased

    pressures and incentives was that

    fnancial targets were more difcult

    to achieve, covering both individual

    targets and those or the business

    as a whole.

    Clearly, in an economic downturn,

    nancial targets are more dicult to

    achieve, and are oten over ambitious.

    Organisations would thereore be well

    advised to be realistic when setting

    their targets, as well as being more

    prepared to adjust targets downwards

    its victims based on the relative

    degree o their nancial perormance.

    However, our survey results show that

    those organisations suering rom

    a downturn reported notably higher

    levels o one type o economic crime,

    that is accounting raud, which we

    address later in this report.

    Fraud practitioners oten point to

    three actors that are commonly ound

    when raud occurs (Fraud Triangle).

    First, perpetrators o raud need an

    incentive orpressure to engage in

    misconduct. Second, there needs to

    be an opportunityto commit raud,and third, perpetrators are oten able

    torationalise or justiy their actions.

    Our survey probed deeper into the

    impact o these three actors and

    ound that among the respondents

    who believed that there is a greater

    risk o raud in the current economic

    environment:

    68% attributed greater risk o raud

    to increased incentives or pressures;

    18% reported that more

    opportunities to commit raud was

    the most likely reason or greater

    risk o raud; and

    14% believed that peoples ability

    to rationalise was the main actor

    contributing to greater risk o raud

    (see gure 1).

    quitIntroduction A deeper dive intothe statistics

    The fraud

    horizon

    Methodology and

    acknowledgements

    Contacts

    Continued

    Economic crime thriving

    in the downturnprint

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 6

    accounting raud and bribery and

    corruption. Figure 5 shows the trend

    in these three main types o raud

    reported in our last our surveys.

    Figure 5: Trends in reported rauds

    0 10 2 0 3 0 4 0 5 0 6 0 7 0

    Asset misappropriation

    Accounting fraud

    Bribery and corruption

    % Companies

    67

    70

    62

    60

    38

    27

    24

    10

    27

    24

    14

    30

    2009 2007 2005 2003

    % respondents who experienced economic crimes

    Two-thirds o those respondents who

    have experienced economic crime in

    the last 12 months reported having

    suered asset misappropriation(see fgure 5). This type o raud

    the most prevalent since we began

    these surveys 10 years ago covers

    a variety o misdemeanours and

    while it is the hardest to prevent,

    it is arguably the easiest to detect.

    Sharp rise in accounting rauds

    Economic crime takes on many

    dierent orms, some more common

    than others. Figure 4 shows the typeso economic crime suered by those

    respondents who reported experiencing

    economic crime in the last 12 months.

    Figure 4: Types o economic crimes

    0 10 20 30 40 50 60 70

    15

    12

    5

    4

    3

    5

    3

    Asset misappropriation

    Accounting fraud

    Bribery and corruption

    IP infringement

    Money laundering

    Tax fraud

    Illegal insider trading

    Market fraud involving cartelscolluding to fix prices

    Espionage

    Others

    67

    38

    27

    % reported frauds

    % respondents who experienced economic crimes in the last 12 months

    Figure 4 shows that the three most

    common types o economic crimes

    experienced in the last 12 months

    were asset misappropriation,

    orce organisations to reduce costs

    and explore areas where efciencies

    can be generated. Sta reductions

    can result in reduced segregation

    o duties and less monitoring o

    suspicious transactions and activities.

    This, in turn, weakens the internal

    control environment and is oten likely

    to result in more opportunities to

    commit raud.

    Figure 3: Factors contributing towards creating

    more opportunities to commit raud

    0 10 20 30 40 50 60 70

    22

    22

    15

    12

    6

    Staff reductions resulting infewer resources being deployed

    on internal controls

    Shift of management's focustowards survival of business

    Increased workload ofinternal audit staff

    Weakening of IT controls resultingin increased vulnerability of

    external penetration

    Transfer of operationsto new territories

    Diversification ofproduct portfolio

    Reduced regulatory oversight

    Other factors

    % Opportunities

    62

    49

    34

    % respondents who believe more opportunities constitute the most likely

    reason for greater risk of economic crime in a downturn

    quitIntroduction A deeper dive intothe statistics

    The fraud

    horizon

    Methodology and

    acknowledgements

    Contacts

    Continued

    Economic crime thriving

    in the downturnprint

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 7

    resulting in increased regulatoryenorcement. Regulators are takingan increasingly dim view oorganisations and individuals thathave paid or received bribes in orderto secure contracts and business

    organisation uses sales agentsand distributors, and thereore controlis reduced.

    In recent years there has been asea change in attitudes towardsbribery and corruption globally,

    Globally, 27% o respondentsexperiencing economic crimereported having experienced bribery

    and corruption cases in the last12 months (see gure 5). The risko bribery and corruption is present inmost transactions and in all territoriesin which an organisation operates,but o particular concern are dealingswith government ocials in emergingmarkets, where bribery and corruptionis more prevalent, and where an

    However, in our 2009 survey,accounting raud has becomeincreasingly prevalent. O thoserespondents who reported economiccrime in the last 12 months, 38%reported experiencing accountingraud. This orm o economic crimehas signicantly increased since2007 (see gure 5), and this appearsto be linked to the economic cycle.

    The survey results highlight thataccounting manipulations are mostcommon within listed organisationsand least common in amily-owned

    organisations. When we looked atthe actors prevalent in this type oraud, respondents pointed tofnancial targets being more difcult

    to achieve (47%), and seniormanagement wanting to report

    a desired level o fnancial

    perormance (25%).

    Accounting raud encompassesa variety o raudulent actionsincluding accounting manipulations,

    raudulent borrowing/raising onance, raudulent application orcredit and unauthorisedtransactions/rogue trading.

    Accounting fraud a case study:

    There have been allegations by awhistle-blower o earnings manipulation at

    a subsidiary, XYZ Plc/Inc/Ltd/SA (it couldhappen anywhere). The organisation hasoperations in 140 countries, has 55,000employees and a turnover o $33.6bn.

    What actions are needed to investigate?

    Appointanindependentcounseland

    orensic team with the right skills andexperience.

    Setthescopecorrectly/seek

    independent advice on scope.

    Lookbeyondtheallegationsconsider

    other areas o the business/individuals

    indirectly implicated by allegations.Engagefullywiththeauditrmastothe

    scope and approach and allow themaccess to the detailed results.

    Donotlettimepressuresdictateactions,

    delay the audited results, i necessary.

    Accounting raudhas more than tripledsince 2003

    quitIntroduction A deeper dive intothe statistics

    The fraud

    horizon

    Methodology and

    acknowledgements

    Contacts

    Continued

    Economic crime thriving

    in the downturnprint

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 9

    due to a lack o support withinorganisations, insucient publicityand/or leadership not being seento take whistle-blowing seriously.

    Globally, 7% o rauds were detectedthrough ormal whistle-blowingprocedures. This may suggest eitherthe ineectiveness or the absenceo such procedures, which could be

    Our survey statistics also showthat 17% o the rauds reportedwere detected by internal audit(see gure 7), which emerged oncemore as the means by which mostrauds were detected. As notedearlier, almost two-thirds o thosewho suered economic crime in thelast 12 months believed that theopportunities to commit raud haveincreased with reduced resourcesdeployed in internal controls.Perhaps the detection o raudincidences has allen with reducedsta within the internal controls team.

    As such, it is apparent that, i therehad not been any reductions ininternal control sta levels, morerauds could have been detected.

    While internal audit remains keyto the detection o raud, there isa clear trend in recent surveys internal audit is consistentlydetecting less o the rauds reported(see gure 7). Anti-raud controls,especially risk management, were

    reported having detected morerauds in our current survey. Thusthe combination o an anti-raudculture and eective anti-raudcontrols, as we recommended inour 2007 survey report, appearsto be improving the detection oeconomic crime.

    As noted earlier, 43% o therespondents who reported raudbelieved there has been an increasein the level o economic crime comparedto 12 months ago. However, 63% orespondents have made no change tothe requency o raud risk assessmentsin the same period. Since raud is nota static threat, organisations continuallyneed to assess their raud risks. Theimportance o addressing raud risksshould be conveyed rom the topdown, with the objective being todevelop a robust anti-raud ramework.

    Figure 7: Detection methods

    414

    23Other detection methods

    0 10 20 30

    54

    0

    144

    3

    544

    533

    78

    3

    1621

    17

    11 1411

    33

    0

    136

    10

    Internal audit

    Corporate

    controls

    Corporateculture

    Beyond the

    influence of

    management

    Suspicious transaction reporting

    Fraud risk management

    Corporate security

    Rotation of personnel

    Whistle-blowing system

    Tip-off (internal)

    Tip-off (external)

    By law enforcement

    By accident

    % reported frauds

    1719

    26

    2009 2007 2005

    % respondents who experienced economic crimes in the last 12 months for 2009; and in the last 2 years for 2007 and 2005

    A comprehensive fraud risk

    assessment should:

    Identifythepotentialinherentfraudrisks.

    Assessthelikelihoodandsignicanceof

    occurrence o the identied raud risks.

    Evaluatewhichpeopleanddepartments are most likely to commitraud and identiy the methods theyare likely to use.

    Identifyandmapexistingpreventiveand detective controls to the relevantraud risks.

    Evaluatewhetherrelevantcontrolsand processes are eectively designedto address identied raud risks

    Identifyandevaluateresidualraud risks resulting rom ineectiveor non-existent controls.

    Respondtoresidualfraudrisks.

    quitIntroduction A deeper dive intothe statistics

    The fraud

    horizon

    Methodology and

    acknowledgements

    ContactsEconomic crime thriving

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    detect it or have been reluctant toreport it once uncovered.

    While there are some exceptions, our

    survey shows relatively ew raudsbeing reported by respondents in Asiaand some territories in Scandinavia.Conversely, respondents in Easternand Western Europe were amongthose reporting the highest incidenceo raud. Those territories where morethan 40% o respondents reportedraud consisted o a mix o developedeconomies and emerging territories.

    The bigger the organisation,the harder the all

    Size matters when it comes to thenumber o incidences o raud reported.The respondents to our survey wereemployed in small, medium andlarge organisations, in almost equalproportion as shown in the surveydemographics in the methodologyand acknowledgements section o thereport. Our survey shows a correlation

    between the size o the organisation(as measured by the number oemployees) and reported incidenceso raud in the last 12 months. In our2009 survey, 46% o organisationswith more than 1,000 employeesreported having experienced at leastone incident o economic crime(see gure 8).

    Table 2: O the territory respondents,percentage that reported raud

    Territories that

    reported high levels o

    raud (40% or more)

    % Organisations

    Russia 71%

    South Arica 62%

    Kenya 57%

    Canada 56%

    Mexico 51%

    Ukraine 45%

    UK 43%

    New Zealand 42%

    Australia 40%

    Territories that

    reported low levels o

    raud (20% or less)

    % Organisations

    Italy 19%

    Sweden 19%

    Singapore 18%

    India 18%

    Indonesia 18%

    Switzerland 17%

    Finland 17%

    Romania 16%

    Netherlands 15%

    Turkey 15%

    Hong Kong 13%

    Japan 10%

    The depth and breadth o our

    research allowed us to drill downdeeply into the responses weobtained, beore grouping data andcomparing it in the ollowing ways.

    The global picture raudreporting diers rom territoryto territory

    O the 3,037 respondents globally,905 (30%) reported having experienced

    raud in the last 12 months. However,the level o raud reporting dierssignicantly rom territory to territory.Table 2 illustrates the wide variationo reported rauds by territory.

    Organisations in territories whererelatively low levels o raud werereported have either ailed to

    A deeper dive intothe statistics

    quitIntroduction Economic crime thrivingin the downturn

    The fraud

    horizon

    Methodology and

    acknowledgements

    Contacts

    Continued

    A deeper dive into

    the statistics

    print

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    In light o this, it is interesting thatgovernment/state-owned enterprisesshould also be the most satisedwith current regulations (32% thought

    that regulatory/legal authorities werequite or very eective). While theseorganisations may be the targeto certain raudsters, the surveysuggests that the main actorcontributing to such high levels oraud in government/state-ownedenterprises is a lack o internal raudprevention know-how and/or raudprevention procedures.

    This is supported by the act thata relatively large proportion o therauds in government/state-ownedenterprises (18%) were detectedby accident, with just 5% beinguncovered through ormal whistle-blowing procedures. One-third ogovernment/state-owned enterprisesdetected raud through inormalprocedures (via tip-os). This ishigher than the global averageo 27% (and perhaps due to a

    lack o trust in ormal procedures).In addition, although 47% ogovernment/state-ownedenterprises respondents believedthat they were at a greater risk romraud, only 22% increased therequency o their raud riskassessments.

    Organisation type dogovernment/state-ownedenterprises have a greater

    threat o economic crime?The results o our survey show apossible link between the type oorganisation and the level o economiccrime experienced. Between 21% and37% o organisations, when groupedby type, reported having sueredeconomic crime in the last 12 months(see gure 9). This underlines the actthat all organisations are susceptibleto raud. Those in government/

    state-owned enterprises, however,reported the highest level o economiccrime (37%). They also believedthemselves to be exposed to thegreatest risk o economic crime (47%)in the current economic climate.

    Figure 9: Frauds reported by various typeso organisations

    21

    28

    37

    31

    Listed on thestock exchange

    Government/state-ownedenterprises

    Private sector

    Others

    % reported frauds

    % respondents representing individual organisational types

    This has been a consistent picture inall o our previous surveys, where thelarger organisations report the highestnumber o rauds. Figure 8 shows that

    organisations with more employeesare more likely to report at least oneraud event. This is not surprisingsince the bigger the bag o applesthe more likely it will contain at leastone rotten one. In addition, largerorganisations will typically be the oneswith the most robust raud detectionstructures. That said, it is also worthremembering that there are moreplaces to hide in large organisations.

    In other words, there may be evenmore rauds taking place in thoseorganisations but they have, or thetime being, escaped detection.

    Figure 8: Large organisations report more rauds

    0 10 20 30 40 50

    More than 1000

    employees46

    201 1000

    employees26

    Up to 200 15

    Don't know 13

    % all respondents

    % respondents representing different sizes of organisations

    quitIntroduction Economic crime thrivingin the downturn

    The fraud

    horizon

    Methodology and

    acknowledgements

    Contacts

    Continued

    A deeper dive into

    the statistics

    print

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    and energy and mining industry(43%). These industries arerenowned or their exposure to bidrigging and kickbacks. Organisationsin these sectors clearly need to payparticular attention to this area overthe coming years.

    The industry sectors that reportedhaving experienced most economiccrimes are communications, insurance,nancial services, and hospitality

    and leisure. These industries tendto be targeted by raudsters becauseo their product or service; equally,organisations in these industrysectors tend to have more robustand proactive anti-raud measures.In eect, they both suer and detectmore raud than other sectors.

    In 2007, the top our industriesreporting raud were insurance, retailand consumer, government/state-owned enterprises, and nancialservices. Indeed, due to the nature otheir business, insurance and nancialservices have reported consistentlyhigh levels o raud over the last 10years. The 2009 survey also showsthat nancial services is the sectorthat has experienced the largestincrease in raud (56% o respondentsreported an increase in the numbero incidences in the last 12 months).

    This compares with the averageglobal gure o 43% o organisationsacross all sectors reporting anincrease over the same period.

    Relatively high levels o briberyand corruption were reported byrespondents in the engineeringand construction industry (47%),

    No industry is immune

    Turning to the most raud-proneindustry sectors, a pattern that

    will be amiliar to readers romour previous surveys emerges:

    Figure 11: Fraud reported by industries

    0 10 20 30 40 50

    27

    26

    24

    24

    20

    15

    36

    21

    Communications

    Insurance

    Financial services

    Hospitality and leisure

    Transportation and logistics

    Government/state-ownedenterprises

    Retail and consumer

    Energy, utilities and mining

    Entertainment and media

    Automotive

    Aerospace and defence

    Engineering and construction

    Manufacturing

    Pharmaceuticals and

    life sciences

    Chemicals

    Other industries/business

    37

    37

    27

    42

    38

    46

    45

    44

    % reported frauds

    % respondents representing individual industry sectors

    The government/state-ownedenterprises are consistently plaguedby cost issues. Many o theseorganisations have been presented

    with increasingly tough cost-reductiontargets in recent years, and theseare becoming even more onerousin the current economic climate.

    While government/state-ownedenterprises are most likely to reportraud, listed organisations are mostexposed to repeat attacks (15%o listed organisation respondentsexperienced 100-plus incidenceso raud in the last year seegure 10).

    Figure 10: More than 100 incidences o raudreported by various types o organisations

    12

    8

    13

    15

    Listed on thestock exchange

    Government/state-ownedenterprises

    Private sector

    Others

    % reported frauds

    % respondents representing individual organisational types

    quitIntroduction Economic crime thrivingin the downturn

    The fraud

    horizon

    Methodology and

    acknowledgements

    Contacts

    Continued

    A deeper dive into

    the statistics

    print

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    November 2009 PricewaterhouseCoopers 13

    take an active interest in raud riskswithin their organisation. By doingso, and by demonstrating the highestethical behaviour, together with

    robust disciplinary action wherethe perpetrators o raud have beenidentied, the right tone rom thetop can be established. Conversely,senior executives who appearunconcerned about raud withintheir organisation may througha lack o attention and ocus unwittingly oster environmentswhere certain types o raud areperceived to be permissible.

    Establishing the right tone at the topis acknowledged to be key in theght against raud. Certainly, oneuseul deterrent or economic crimehas proved to be a corporategovernance structure, setting outrobust escalation procedures throughwhich employees can report theirconcerns on a condential basis,secure in the knowledge that anyoneound to have committed raud will

    be severely dealt with.

    As we have seen, the impact oraud on employee morale can causecollateral damage. Furthermore,o the respondents who attributedgreater levels o raud to increasedrationalisation within their organisations,

    employees, but also investors, suppliers,customers and potential recruits.

    Building a zero-tolerance cultureSenior executives reported less raudthan other employees, suggestingthat they may not be sucientlyaware o the ull extent o economiccrimes in their organisation. However,undamental to the ght against raudis the attitude and ethical stancedemonstrated by those at the top.I organisations want to get the toneat the top right, senior executives

    need to be better inormed aboutthe raud risks they are acing.

    Our survey urther revealed that just26% o senior executives reported anincidence o economic crime in theirorganisation in the last 12 months.By contrast, 34% o respondentsother than senior executives reportedan incidence o economic crime in thesame period. Either senior executivesare not reporting incidences o crime

    or they are not being made aware ocertain types o economic crime.

    While smaller-value rauds may not beescalated to senior management, it isthe case that even a relatively minorincident can cause signicantreputational damage. We stronglybelieve that senior executives should

    perhaps because it is very dicult toquantiy such costs.

    Figure 12: Collateral damage

    0 10 20 30 40

    Employee morale 32

    Business relations 23

    Relations with regulators

    Organisationsreputation/brand

    19

    Others

    Share price

    16

    6

    4

    % reported frauds

    % respondents who experienced economic crimes in the last 12 months

    However, most damaging, accordingto our survey, is the impact o raudon employee morale (reported asvery signicant or signicant by32% o respondents). In reality, it isimpossible to quantiy the cost o thistype o collateral damage (or anyother type), but it should be o realconcern to organisations no onelikes to see headlines about raudwithin the business, and this type ocoverage can put o, not just

    Beyond the nancialconsequences

    O the respondents that reported

    incidences o raud over the last12 months, 27% said that the directnancial impact o this exposure wasmore than US$500,000. But the costo raud varies, depending on thetype o raud suered. One-quartero the respondents who reportedaccounting raud believed that it hadcost them more than US$1 millionin the last 12 months. By contrast,among respondents reportingincidences o asset misappropriation,only 17% believed that it had costthem over US$1 million. In view othe high incidence o accountingraud reported by our respondents,the comparatively costly nancialimpact o this exposure is evidentlya signicant problem or manyorganisations.

    However, the allout rom raud is notsimply the direct cost. Our survey also

    investigated the collateral damagesuered by organisations and askedabout the impact economic crimehad on their reputation/brand, shareprice, employee morale, businessrelations, and relations with regulators(see gure 12). Interestingly, mostrespondents do not see collateraldamage to cause signicant impact,

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    said that the senior executivecompensation had no variablecomponent. In organisations wheresenior executive compensation

    includes a perormance-basedvariable component o more than50%, 36% reported having sueredraud. In contrast, where there wasno variable perormance-basedcomponent, only 20% reportedhaving suered raud. This starkcontrast may suggest that thereis a correlation between the two.

    Additionally, it appears that eacho the most common types o raud

    asset misappropriation, accountingraud, and bribery and corruption are most prevalent when there isa higher variable component in thesenior executives compensationstructure. It may, at rst sight, seemodd that higher levels o assetmisappropriation, or example, arisewhere the senior executives receivea relatively high perormance-basedcompensation. However, in timeso economic uncertainty, and aced

    with increased personal nancialpressures, it could be that someindividuals are tempted to increasetheir earnings by oul means,possibly because o perceivedunairness o their own earningscompared to those o seniorexecutives.

    relationships (51%) and/or notiy therelevant regulatory authorities(see gure 14).

    Figure 14:Actions brought againstexternal raudsters

    0 10 20 30 40 50 60

    59

    51

    46

    4

    16

    5

    Civil action/criminal charges

    were brought

    Notify relevantregulatoryauthorities

    Cessation ofbusiness

    relationships

    Other actions

    Did nothing

    Dont know

    % reported frauds

    % respondents who experienced economic crimes in the last 12 months

    Compensation structure is this

    a breeding ground or rauds?Our survey shows that amongrespondents who reported economiccrime, 12% said that, in theirorganisation, the senior executivecompensation includes more than50% based on perormance, that is,variable component, whereas 11%

    Figure 13:Actions brought againstinternal raudsters

    0 10 20 30 40 50 60 70 80 90

    Dismissal 85

    Civil action/criminalcharges were brought

    48

    Warning/reprimand

    Notify relevantregulatory authorities

    24

    Did nothing

    Other actions

    Transfer

    22

    4

    5

    2

    % reported frauds

    % respondents who experienced economic crimes in the last 12 months

    But although there has been anincrease in the number o dismissals,another 22% o respondents reportedissuing only warnings or reprimands.This may refect the varying severityo rauds that were uncovered bythese organisations but, i a raudsterbelieves that the punishment orcommitting the crime will be minimal,he or she may be encouraged toperpetrate it. For external perpetrators,the majority o organisations chose tobring civil and/or criminal charges(59%), to terminate the business

    35% identied others do it so its okayas being a contributory actor. Theseresults emphasise the importanceo eective communication (a zero-

    tolerance policy) between managementand employees where attitudes to raudare concerned.

    When the appropriate message romsenior management is not conveyedand/or reinorced through appropriateactions and behaviours, raud canhave a much more damaging impacton an organisation. The complexcultural challenges that arise in the ghtagainst raud can only be overcome ithe workorce has been equipped withthe right skills. A crucial part o thisprocess involves senior managementempowering and motivatingemployees to do the right thing,because it is the right thing to do.

    Once a nancial crime has beenidentied, there are a variety o actionsthat can be taken by an organisation.Our survey shows that, in the majorityo cases, internal perpetrators tend tobe dismissed. Interestingly, levels odismissals or these crimes havedoubled in the last two years (85%in 2009 see gure 13, 40% in 2007).In eect, organisations looking or areason to reduce labour and itsassociated costs in the economicdownturn, have been presented witheasy pickings.

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    Know your enemy

    As with previous surveys, the splitbetween internal and externalperpetrators o economic crime wasairly evenly matched. Organisations thatsuered rom economic crime reportedthat 53% o perpetrators were internaland 44% were external. However,when we reviewed the responses by

    industry sectors, we ound thatthere were our industries (nancialservices, insurance, technology andcommunications) that reported theirmost signicant rauds being committedby external perpetrators. Respondentsrom these our industries alonerepresent 28% o all responses to oursurvey. Respondents rom all other

    Figure 15:Accounting raud reported by allrespondents versus those who reported that thesenior executives compensation includes morethan 50% perormance-based variable component

    0 10 20 30 40 50

    % reported frauds

    44

    38

    More than 50%performance basedvariable component

    All respondents

    % respondents who experienced economic crimes in the last 12 months

    and % respondents from organisations where senior executives compensation

    includes more than 50% performance-based incentives

    Among organisations wheresenior executives compensationstructure includes more thana 50% variable component,44% o those reporting raudin the last 12 months sueredaccounting raud, whereas,rom all respondents, 38%o those reporting raudexperienced accounting raud

    (see gure 15).

    Organisations need to be awareo the apparent heightened raudrisks in this situation. They shouldimplement appropriate controlsand monitor closely to combatthe risk.

    industry sectors reported sueringthe most signicant rauds at thehands o internal perpetrators.

    Figure 16: Perpetrators o raud by industry

    0 20 40 60 80 100

    Industries

    thatreported

    higherexternal

    perpetrators

    offraud

    Industries

    thatreported

    higherinternal

    perpetrators

    offraud

    Insurance

    Financial services

    Communication

    Aerospace anddefence

    Technology

    Manufacturing

    Hospitality andleisure

    Chemicals

    Pharmaceuticals

    and life sciences

    Transportation andlogistics

    Engineering andconstruction

    Retail andconsumer

    Automotive

    Energy, utilitiesand mining

    Government/state-owned enterprises

    Entertainmentand media

    Other industries/business

    Professionalservices

    Global

    35

    25

    45

    39

    76

    80

    74

    74

    69

    70

    67

    67

    67

    36 64

    64

    57

    57

    59

    53

    65

    73

    50

    55

    24

    20

    23

    23

    29

    30

    30

    31

    37

    41

    34

    33

    44

    External Internal Unknown

    % reported frauds

    % respondents representing individual industry sectors

    Do the rightthing, becauseit is the rightthing to do

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    Figure 18: Prole o internal raudsters

    0 10 20 30 40 50

    42

    42

    14

    2

    Junior staffmembers

    Middlemanagement

    Seniorexecutives

    Other employees

    % reported frauds

    % respondents who reported that an internal employee was the main

    perpetrator of fraud

    The rise in rauds being committed bymiddle management could be viewedin the context o increased nancialpressures in the current economicclimate. O respondents who saidraudsters increased ability to

    rationalise their actions was the mostlikely cause o raud, 70% believedthat crimes are committed to maintainliving standards. O this group, onein ve believed these crimes arecommitted by those jealous o higherearners whose compensation orbonuses were believed to be unair.

    O the respondents who reportedattack by external perpetrators,45% had suered raud by customersand 20% by agents/intermediaries

    (see gure 17).

    Figure 17: Prole o external raudsters

    0 10 20 30 40 50

    45

    20

    10

    25

    Customers

    Agents/intermediaries

    Vendors

    Other third parties

    % reported frauds

    % respondents who reported that an external person was the main

    perpetrator of fraud

    The survey also ound that the proleo the internal raudster is changingrapidly. Economic crimes committedby middle managers have risen verystrongly, now accounting or 42% oall internal rauds, up rom 26% in2007 (see gure 18).

    Middle managers deraud

    employers to maintain livingstandards

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    The raud horizon

    Respondents to our surveys haveconsistently estimated that their utureraud exposure is less than theircurrent experience. With hindsight,however, this condence is otenshown to have been misplaced.

    When asked about the most likelyraud threats in the next 12 months,respondents to our survey identiedasset misappropriation, accountingraud and bribery and corruption.

    Hardly surprising since these typeso economic crimes were, ater all,the most commonly experiencedrauds over the last 12 months.However, as we explore later, suchexpectations have oten been shownto be incorrect in the past andmay well prove to be so in uture.

    Figure 19: Trends in perception o raud

    0 10 20 30

    13

    22

    6

    10

    11

    16

    Assetmisappropriation

    Accountingfraud

    Bribery andcorruption

    2007 Perception 2009 Perception

    % all respondents

    % all respondents perception over the next 12 months for 2009; and over

    the next 2 years in the 2007 survey

    Overall, there has been an increasein perception levels around the threemost common types o raud. 22%o all respondents believe that theirorganisation is susceptible to assetmisappropriation within the next12 months. Similarly, 11% and 16%o all respondents believe that theirorganisations may suer accountingraud or bribery and corruption,respectively (see Figure 19). This isconsistent with the overall greater raud

    risk in the current economic climate more raud is expected to lie ahead.

    While general awareness o thesusceptibility to economic crime hasincreased, the ndings o our surveysover time typically highlight a gapbetween perception and reality.

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    Respondentshave consistentlyunderestimatedtheir uture

    raud exposure

    Figure 20: Perception in 2007 vs Realityin 2009

    0 10 20 30

    13

    20

    6

    10

    11

    8

    Assetmisappropriation

    Accountingfraud

    Bribery andcorruption

    2007 Perception 2009 Reality

    % all respondents

    % all respondents perception over the next 12 months for 2009; and over

    the next 2 years in the 2007 survey

    Figure 20 shows that 13% o allrespondents in 2007 thought it waslikely that they would experience assetmisappropriation in the subsequenttwo years. However, in our 2009survey, 20% o all respondents(67% o those who reportedexperiencing economic crime seegure 4) had been victims o assetmisappropriation in the last yearalone. There is a similar gap withthe perception and experience oaccounting raud where the

    perception o risk was only 6% in2007, while the reality in 2009 wasthat 11% o all respondents (38%o those who reported experiencing

    economic crime see gure 4) hadactually suered this type o raudin the preceding year.

    Bribery and corruption is the onlyeconomic crime where perception orisk outweighs reality. In 2007, 10% oall respondents considered themselvesto be at risk rom bribery and corruptionin the subsequent two years. However,according to our current survey, only8% o all respondents (27% o those

    who reported experiencing economiccrime see gure 4) actually sueredthis type o raud. Certainly, bribery andcorruption has received extensivemedia coverage during recent yearsand has thereore come onto theradar o the larger multinationals.Consequently, more organisationsare taking pre-emptive measuresto prevent bribery and corruption,or is it simply that they have not been

    caught yet?In our survey, respondents wereasked who they thought is most likelyto perpetrate a raud external orinternal raudsters in the next year.Fascinatingly, or 10 o the 12 raudlisted, respondents on a global basisexpect external raudsters to be the

    main perpetrators in the year ahead.The reality is, o course, that whilesome organisations will continue toace threats rom external raudsters,

    a signicant threat lies within the

    organisation. This rose-tinted viewneeds to be promptly addressed,otherwise, organisations will struggleto implement adequate detective and

    preventive internal procedures.

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    I d i E i i h i i A d di i Th f d CM h d l d

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    Methodology

    Our th Global Economic Crime Survey was conducted between July and November 2009. A total o 3,037 respondentsrom 54 countries completed our online questionnaire. The participants were asked to respond to the questions regarding

    (a) their organisation and (b) the country in which they are located.

    Methodology andacknowledgements

    Asia Pacifc 652

    Australia 75

    Hong Kong (and China) 67

    India 145

    Indonesia 50

    Japan 73

    Malaysia 65

    Middle East countries* 14New Zealand 85

    Philippines** 1

    Singapore 51

    South Korea** 1

    Thailand 25

    South & Central America 275

    Argentina 39

    Brazil 62

    Chile 76

    Dominican Republic** 1

    Ecuador** 1

    Mexico 94

    Peru** 1

    Venezuela** 1

    Western Europe 1,243

    Austria 34

    Belgium 62

    Cyprus** 1

    Denmark 105

    Finland 52

    France 52

    Germany*** 17Greece 96

    Ireland 91

    Italy 90

    Netherlands 76

    Norway 75

    Portugal** 1

    Spain 55

    Sweden 78

    Switzerland 129

    UK 229

    North America 123

    Canada 52

    USA 71

    Central & Eastern Europe 589

    Bulgaria 59

    Czech Republic 83

    Hungary 53

    Poland 63

    Romania 55

    Russia 86

    Serbia 4Slovakia 69

    Turkey 52

    Ukraine 65

    Arica 145

    Ghana 27

    Kenya 53

    Namibia** 1

    South Arica 63

    Sierra Leone** 1

    No primary country specifed 10

    TOTAL 3,037

    *Middle East countries included participants from Israel, Jordan, Kuwait, Oman, Saudi Arabia and UAE.

    **These are individual participants from 10 countries who found our survey and participated in it online.

    ***500 participants were surveyed separately in Germany. Visit http://www.pwc-wikri2009.de/to read the German survey results.

    Table 3: Participating territory counts

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    Table 8: Job title o participants in the organisation

    % organisations

    Senior executives 52%Chie Executive Ocer/President/ManagingDirector

    12%

    Chie Financial Ocer/Treasurer/Controller

    30%

    Chie Operating Ocer 2%

    Chie Inormation Ocer/Technology Director

    1%

    Other senior executive 4%

    Board member 3%

    Non-senior executives: 48%

    Senior Vice President/VicePresident/Director

    8%

    Head o business unit 3%

    Head o department 15%

    Manager 15%

    Others 7%

    Table 5: Organisation types participating

    % organisations

    Listed on a stockexchange 43%

    Private sector 42%

    Government andpublic sector

    10%

    Others 5%

    Table 6: Size o participating organisations

    % organisations

    Up to 200 employees 32%

    201 to 1,000 employees 33%

    More than 1,000 employees 34%

    Dont know 1%

    Table 7: Function (main responsibility) oparticipants in the organisation

    % organisations

    Executive managementor nance

    58%

    Audit 12%Risk management 5%

    Compliance 4%

    Security 4%

    Advisory/consultancy 3%

    Legal 3%

    Operations and production 3%

    Others 8%

    Table 4: Participating industry groups

    % organisations

    Aerospace & Deence 1%

    Automotive 4%

    Chemicals 2%

    Communication 2%

    Energy, Utilities & Mining 7%

    Engineering & Construction 7%

    Entertainment & Media 3%

    Financial Services 16%

    Government andPublic Sector

    6%

    Hospitality and Leisure 2%Insurance 5%

    Manuacturing 14%

    Pharmaceuticals andLie Sciences

    5%

    Proessional Services 6%

    Retail & Consumer 9%

    Technology 5%

    Transportation& Logistics

    5%

    Other Industries/business 1%

    Table 9: Organisations where senior executivecompensation includes a perormance-basedvariable component

    % organisations

    Less than 20% 24%

    20% to 50% 36%

    More than 50% 10%

    No perormance-basedvariable component

    16%

    Dont know 14%

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 21

    Money laundering

    Actions intended to legitimise theproceeds o crime by disguisingtheir true origin.

    IP inringement (including

    trademarks, patents, countereit

    products and services)

    This includes the illegal copyingand/or distribution o ake goods inbreach o patent or copyright, andthe creation o alse currency notesand coins with the intention opassing them o as genuine.

    Illegal insider trading

    Illegal insider trading reers generallyto buying or selling a security, in breacho a duciary duty or other relationshipo trust and condence, while inpossession o material, non-publicinormation about the security. Insidertrading violations may also includetipping such inormation, securitiestrading by the person tipped, andsecurities trading by those who

    misappropriate such inormation.

    Espionage

    Espionage is the act or practice ospying or o using spies to obtainsecret inormation.

    o the organisation. This can involveaccounting manipulations, raudulentborrowings/raising o nance, raudulentapplication or credit and unauthorisedtransactions/rogue trading.

    Corruption and bribery (including

    racketeering and extortion)The unlawul use o an ocial positionto gain an advantage in contraventiono duty. This can involve the promiseo an economic benet or other avour,the use o intimidation or blackmail.It can also reer to the acceptance osuch inducements.

    Asset misappropriation

    (including embezzlement/

    deception by employees)

    The thet o assets (including monetaryassets/cash or supplies and equipment)by directors, others in duciarypositions or an employee or their

    own benet.

    Accounting raud

    Financial statements and/or otherdocuments are altered or presentedin such a way that they do not refectthe true value or nancial activities

    Terminology

    Due to the diverse descriptionso individual types o economiccrime in countries legal statutes,we developed the ollowingcategories or the purposes othis survey. These descriptionswere dened as such in oursurvey questionnaire.

    Economic crime or raud

    The intentional use o deceitto deprive another o money,property or a legal right.

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    Global Economic Crime Survey November 2009 PricewaterhouseCoopers 22

    Fraud triangle

    Fraud triangle describes the

    interconnected conditions that act

    as harbingers to raud: opportunity

    to commit raud, incentive (or pressure)to commit raud, and the ability o

    the perpetrator to rationalise the act.

    Senior executive

    The senior executive (or example the

    CEO, Managing Director or Executive

    Director) is the main decision-maker

    in the organisation.

    Note:In some cases percentages may total

    more or less than 100 percent as respondentswere able to provide multiple answers.

    About PwC Forensic Services

    The Forensic Services group o the

    PricewaterhouseCoopers globalnetwork o rms plays a lead role in

    addressing the lie cycle o raud and

    other avoidable losses, providing

    reactive investigative services and

    proactive remedial and compliance

    services to clients in the private and

    public sectors.

    Financial performance

    This can be dened as measuring the

    results o an organisations policies

    and operations in monetary terms.

    These results are refected in returnon investment, return on assets and

    value added; typically, In the private

    sector, returns will be measured in

    terms o revenue; in the government/

    state-owned enterprises, returns will

    be measured in terms o service delivery.

    Fraud risk assessment

    Fraud risk assessments are used

    to ascertain whether an organisation

    has undertaken an exercise tospecically consider:

    (i) the raud risks to which operations

    are exposed;

    (ii) an assessment o the most

    threatening risks (i.e. evaluate risks

    or signicance and likelihood o

    occurrence);

    (iii) identication and evaluation o the

    controls (i any) that are in place tomitigate the key risks;

    (iv) assessment o the general anti-raud

    programmes and controls in an

    organisation; and

    (v) actions to remedy any gaps in

    the controls.

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    INSEAD

    As one o the worlds leading and largest graduate business schools, INSEAD(www.insead.edu) brings together people, cultures and ideas rom around the worldto change lives and transorm organisations. This worldly perspective and culturaldiversity are refected in all aspects o our research and teaching. With two campusesin Asia (Singapore) and Europe (France), two centres in Israel and Abu Dhabi, and anoce in New York, INSEAD extends the reach o its business education and research

    across three continents. Our 145 renowned aculty members rom 37 countriesinspire more than 1,000 degree participants in our MBA, Executive MBA and PhDprogrammes. In addition, more than 9,500 executives participate in INSEADsexecutive education programmes. We oer 38 open-enrolment programmes orall business disciplines and design 184 custom learning solutions or groups oexecutives rom a specic organisation yearly. Should you wish to nd out moreabout Executive Development or individual executives or about our Company-specic Programmes, please contact us at [email protected]@insead.edu.

    Acknowledgements

    The 2009 Global Economic Crime Survey editorial team consisted o theollowing individuals:

    Survey Leadership Team

    Tony Parton, Partner,United Kingdom

    Vidya Rajarao, Partner,India

    Steven Skalak, Partner,USA

    Survey Management Team

    Faisal Ahmed, Project Manager,United Kingdom

    Neil Cormack, Marketing Consultant,United Kingdom

    INSEAD (France)Douglas H. Frank,

    Assistant Proessor o Strategy, INSEAD

    Editorial Team members

    Mona Clayton, Partner,Brazil

    John Donker, Partner,Hong Kong

    Peter Forwood, Manager,Australia

    Linda Macphail, Associate Director,South Arica

    Malcolm Shackell, Partner,Australia

    Louis Strydom, Partner,South Arica

    Pierre Tailleer, Partner,

    Canada

    John Wilkinson, Partner,Russia

    Particular thanks in compiling this report are also due to the ollowing individuals at PricewaterhouseCoopers:Mike Ascolese, Paul Bell, Steven Burke, Jonti Campbell, Arijit Chakraborti, Jennier Cibinic, Tirthankar Ghosh,Tracey Groves, Karena Kay, Tim Kau, Elaine Keown, Ruth Lawson, Noel McCarthy, Joel Osborne, Amrita Sidhuand Suzanne Snowden.

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    print

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    http://www.insead.edu/mailto:[email protected]:[email protected]:[email protected]:[email protected]://www.insead.edu/
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    Tony Parton

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    Steven Skalak

    Partner, USA+1 (646) 471 [email protected]

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    Survey Leadership Team contact details:

    Forensic Services Leaders contact details:

    Chris Barbee

    Partner, USA, Global Leader

    +1 267 330 [email protected]

    John Donker

    Partner, Hong Kong, East Cluster Leader

    +852 2289 [email protected]

    Andrew Palmer

    Partner, London, Central Cluster Leader

    +44 (0) 20 7212 [email protected]

    Erik Skramstad

    Partner, USA, West Cluster Leader

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    Survey Management Team contact details:

    Neil Cormack

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    Faisal Ahmed

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    acknowledgements

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