2020 Economic Crime - Corruption Watch

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2020Economic crime –When the boardroombecomes the battlefieldPwC’s Global Economic Crimeand Fraud Survey7th South African editionMarch 2020www.pwc.co.za

2 2020 Global Economic Crime and Fraud Survey – 7th edition

Contents04Leading observations07Foreword081 Fraud perspectives: When less is actually more102 Changing tides in the types of economic crime123 Redefining being bulletproof by looking inward164 Feeling the pinch: The cost of economic crime185 A wake-up call for boards and regulators246 Taking initiative: Preparing for fraud267 When the time comes, react the right way288 Rising from the ashes: Measuring success30Conclusion: The writing is on the wall31ContactsPwC 3

Leading observationsOrganisations are facing increased complexity — are you prepared?20 to 34%%Fraud perpetrated by seniormanagement up from 20% in 2018 to34% in 2020.22 to 34%%Accounting/Financial statementfraud up from 22% in 2018 to 34% in2020.One in five incidents featured internaland external perpetrators.Cybercrime remains in the top five.Value up, volume down — does this measure the complete cost?VolumeValue604%Incidents down from 77% in 2018 to60% in the current survey.Cost%4% report direct losses in excess of 100 million (global: 7%). One in three South Africanrespondents cite distrust as beingthe most significant emotionalimpact of incidents. Brand damage, loss of marketposition, employee morale, andlost future opportunities remainunquantified.Is your fraud programme delivering what you think it is?60Shockingly, however:%of South African respondents thataddressed a disruptive incidentsay their organisation emergedstronger.%of respondentsdidn’t conduct aninvestigation%of incidents were notdisclosed to the board4259 More scrutiny from broader stakeholders Almost half of respondents are planning to increase their spend on fraud prevention4 2020 Global Economic Crime and Fraud Survey – 7th edition%of incidents were notdisclosed to the auditor6672The demands are only increasing Speed of response will determine the containment of damages and losses%of incidents were notdisclosed to regulatorsor law enforcement

Global5,000 respondents6272%of respondentswere C-suite%have US 10M in global revenue99territoriesUS 42Bin lossesSouth Africa245South African participants71%of respondentswere C-suiteUS 1.7Bin lossesPwC 5

Industry sectorsIndustrial manufacturing& automotiveTechnology, media gy,utilities &resources2%%OtherHealthindustries6 20%Government &public sector2020 Global Economic Crime and Fraud Survey – 7th edition24Financialservices%

ForewordChief Justice Mogoeng highlighted in an address at the University ofKwaZulu-Natal in 2017 that private sector actors had escaped scrutiny inthe past and while:“There is a lot of wrongdoing, I dare say, in the public sector.A lot, as corruption and as mismanagement, but there is a lot ofwrongdoing in the private sector. How it escapes the public spaceor find[s] some space there for a little while and immediatelydisappears, has confounded me for a very long time ”1Trevor WhitePartner, Forensic ServicesPwC South AfricaGlobal Economic Crime and FraudSurvey LeaderEconomic crime, at60%, is much lowerthan two years ago,but instances of highervalue fraud haveincreased considerably!This has changed in the past couple of years with private sectorfrauds, due to the size of many of these and the involvement of seniormanagement, now being much more widely reported on in the press andfor much longer periods of time.The results of our 2020 Global Economic Crime and Fraud Surveyhave turned up one major surprise, that being that the percentage ofrespondents who had experienced economic crime in South Africadeclined for the first time in the last decade.However, there was no surprise in the finding that bribery and corruptionand financial statement fraud are still among the more prominent typesof economic crime reported. This, combined with increased involvementof senior management in perpetrating such acts, has resulted in a sharpincrease in the value of losses incurred as a result.Our message is clear: To survive the catastrophic impact of economiccrime, organisations need to be proactive, agile and resilient, to react inan appropriate manner and to do so swiftly. Organisations adopting theright approach to dealing with fraud will be able use these occurrencesto emerge stronger.1Steve Bhengu, “Mogoeng calls on SA to address corruption in the private sector.” East Coast Radio. 2017. ddress-corruption-private-sector/ (accessed 5 February 2020)PwC 7

1Fraud perspectives:When less is actually moreIn this, the seventh edition of the PwC Global Economic Crime andFraud Survey, we saw levels of fraud awareness and insight amongSouth African organisations continue to outperform their global peers,with 73% of South African respondents indicating a high or extensiveknowledge in this area, compared to 65% of global respondents.Nevertheless, as witnessed by the major scandals that have rocked ourlocal market over the past few years, the persistence of the scourge ofeconomic crime is not to be ignored and awareness of the issues mayserve us very little if action is not taken to actively eradicate the problem.So very aware, yetso very helpless:How can we convertknowledge to armourin the fight againsteconomic crime?South Africa: Reported rate of economic crimeQHas your organisation experienced any fraud and/or economiccrime within the last 24 months?South 4%37%36%20112014201647%0%200920182020Source: PwC analysisThe silver lining of a very dark cloud: Reported rate of economic crimedeclinesAs South Africans, we have become accustomed tobeing at the very top of the naughty list, but in the twoyears since our previous survey, we have seen a rathersurprising drop in the reported rate of economic crime,from 77% in 2018 to 60% this year!What could possibly have driven a 17 percentagepoint decline in the reported rate of economic crime?And should we be celebrating?Having our reported rate of economic crime return tolevels last seen in 2011, while global trends consistentlyexhibit higher levels than seen in the past 20 years, mayoffer a rare glimmer of hope for South Africa. But viewingthis statistic in isolation presents a sadly distortedpicture.8 2020 Global Economic Crime and Fraud Survey – 7th editionFor one thing, at 60%, South Africa’s rate of reportedeconomic crime remains significantly higher thanthe global average rate of 47%. Added to this is thestark reality that the incidence of higher value seriouseconomic crime has doubled in the past 24 months from1% to 2%. There has also been a disturbing increase inthe level of involvement of senior management as themain perpetrator, escalating from 20% in 2018 to 34%in 2020.With respondents in India and China reporting the highestoccurrence of economic crime, South Africa has slippedto third in the top ten ranking of countries with the highestreported economic crime in the world. Before now, Indiahas never featured in the top ten.

Top 10 countries reporting most economic crimeQHas your organisation experienced any fraud and/or economic crime within the last24 months?69%India57%China60%63%South Africa60%77%58%Kenya75%United States56%53%United reland51%49%20202018Reported rate of economic crime by regionQHas your organisation experienced any fraud and/oreconomic crime within the last 24 months?AfricaNorth AmericaLatin AmericaMiddle 6%42%202046%2018With 38% of global participants in PwC’s 23rd Annual Global CEO Survey (2020) identifying Chinaand India as the most important countries to their organisations overall growth prospects over thenext 12 months (South Africa: 14%), this is a matter of serious concern.China and India have emerged as economic powerhouses, but with fast-growing economies suchas these being subject to concentrated attacks, the global impact is magnified. With the exceptionof the Middle East, which showed an increase in the regional rates of reported economic crime (bya significant 11 percentage points), all regions showed a decline. Africa still emerged as having thehighest rate of economic crime, with the Americas following close behind.PwC 9

2Changing tides in the typesof economic crimeFor the first time sincethis survey began,asset misappropriationwas not identified asthe most prevalenteconomic crime.Types of economic crime/fraud experiencedQWhat types of fraud and/or economic crime has yourorganisation experienced within the last 24 months?Customer fraud35%34%Bribery & t fraud22%34%28%31%29%34%Cybercrime23%49%Asset misappropriation31%21%23%Human resources fraud17%19%Deceptive businesspractices16%33%16%39%Procurement fraud19%Tax fraudMoney laundering t law infringement10%3%13%SA 2020Insider/Unauthorisedtrading10%3%10%Global 2018Intellectual property(IP) theft8%7%11%Other8%7%4%SA 2018This year’s surveyushers in a new era inwhich customer fraudhas come to the foreas the most prominenteconomic crime,followed by bribery &corruption and financialstatement fraud.It is notable that whileincidences of mostfraud types declinedin South Africa,occurrences of the topthree rose, and so toodid cybercrime, whichseems to be creepingup to previous levels.The significant increasein financial statementfraud is concerningas this type of fraudinvariably involvessenior managementand the amounts aresignificant. The negativeeffect of this crime onall stakeholders and thefuture sustainability ofthe entity as a wholecan be catastrophic.Source: PwC analysisCustomer fraud was introduced as a category for the first time inour 2018 survey. It refers to fraud committed by the end-user andcomprises economic crimes such as mortgage fraud, credit cardfraud, claims fraud, cheque fraud, ID fraud and similar fraud types.10 2020 Global Economic Crime and Fraud Survey – 7th edition

Most disruptive economic crimes likely to be experienced over the next24 monthsQThinking about the next 24 months, which of the following fraud and/or economic crimes is likely to be the mostdisruptive/serious in terms of the impact on your organisation (monetary or otherwise)?19%Bribery & corruption16%Accounting/Financial statement fraud14%Customer fraud11%Cybercrime10%Asset misappropriation7%Other5%Procurement fraud4%Insider/Unauthorised tradingDeceptive business practices3%Tax fraud3%Money laundering & sanctions3%Anti-competition/Anti-trust law infringement2%Human resources fraud2%Source: PwC analysisGiven the recent scandals rocking South Africa, both in the public and private sectors, it comes as no surprise thata fifth of respondents consider bribery & corruption to be the most serious and disruptive economic crime to affectorganisations.The prominence of accounting and financial statement-related fraud, which has left many casualties in the past fewyears, has perhaps been one of the major factors prompting companies to take a cold, hard look at themselves and tohonestly reflect on what is being done to counter the scourge of economic crime.Cosmetic interventions are losing their lustre and trust is a precious commodity that is being lost. A third ofSouth African respondents identified distrust as the most significant emotional impact brought about by acts ofmalfeasance.The added risk, and a systemic risk at that, is that with the prominence of economic crime being perpetrated by socalled ‘captains of industry’, there is a tendency for common folk to rationalise criminal actions. The rise of customerfraud, which was only introduced as a category in the survey in 2018, is an indication of the erosion of the ethical fabricof our society.When threats abound, both inside and outside the organisation, uncertainty regarding future prospects increases. Thisis reflected in our finding that 42% of South African respondents in PwC’s 23rd Annual Global CEO Survey are notconfident about their organisation's prospects for revenue growth over the next 12 months.22PwC's 23rd Annual Global CEO Survey 2020 - www.ceosurvey.pwcPwC 11

3Redefining being bulletproofby looking inwardThe actors that perpetrate economic crime inSouth AfricaQWho was the main perpetrator of the most disruptive economiccrime experienced?36%External perpetrator41%Internal perpetratorCollusion betweeninternal andexternal actorsRecent experienceshave woken us upto the fact that amajor fraud risk areafor organisations isthe very custodiansentrusted to run them.21%Source: PwC analysisFraud hits companies from all angles and may take various forms, such as the internal perpetrator (41% of economiccrimes were perpetrated by this group), the external perpetrator, and collusion between the two, which rears its headin one-fifth of cases, and is by far more difficult to detect and contain.South African organisations have seen an upsurge in instances of senior management perpetrating fraud. Economiccrimes perpetrated by senior management are often among the most sinister because of the ability (whether throughdelegated authority levels, system knowledge, or influence) of top executives to override (or conspire to override)internal controls.With more than a third of South African respondents falling prey to this phenomenon, much greater focus ongovernance is required in organisations. The days of the passive non-executive board member have surely passed andthere is a need for this independent oversight function to become more involved and ask the difficult questions, andthereafter demand and interrogate the answers provided.12 2020 Global Economic Crime and Fraud Survey – 7th edition

Main perpetrators of internal fraud in South AfricaQAt what level within your organisation was the internal perpetrator of the most disruptive economic %MiddlemanagementJunior management/Operational 20112014201620182020Source: PwC analysisLook both ways: External forces remain a threatExternal perpetrators of economic crime in South AfricaQWho was/were the external perpetrator(s) of the most disruptive economic crimeincident against your organisation?2725Organised oint venture/Alliance partnerConsultant/AdvisorSource: PwC analysisPwC 13

Outsourcing has become the norm in companies and corporationsseeking to minimize costs, but these cost-reduction exercises introducea new dimension to the fraud landscape. Any chinks in the armourof these business partners become your risks and can lead to theunravelling of the most sophisticated fraud prevention strategies, if notformally and comprehensively addressed. It is telling, therefore, thatthree of the top five external perpetrators of economic crime qualify asbusiness partners, in one form or another. One in five respondents cited vendors/suppliers as the source of theirmost disruptive external fraud; But more than half lack a mature third-party risk programme; and Almost a quarter of respondents (24%) have no third-party duediligence or monitoring programme at all.In contrast to the trend globally,South African respondents citedorganised crime as the highest ratedsource of external perpetrators withfraud committed by customers comingin a close second (at 25%) as the mostdisruptive fraud. From a global perspective, customerfraud is especially prominent in thefinancial services and consumermarkets segments. This could betelling as industries shift to direct-toconsumer strategies. The good news? It’s also one of thefrauds where dedicated resources,robust processes and technology haveproven effective in prevention.One in five economic crimes perpetratedby external parties were committedby hackers, highlighting the fact thatorganisations cannot drop their guardin any area, especially if they areadopting greater levels of technologicalsophistication.14 2020 Global Economic Crime and Fraud Survey – 7th edition

Businesses behaving badlyThis year, for the first time, we askedrespondents if their organisations hadbeen accused of perpetrating a fraud.Of those who reported experiencingeconomic crime, nearly one in five SouthAfrican respondents reported that theirorganisations had also been accused ofcommitting a fraud, corruption, or othereconomic crime.In almost equal numbers,444331%%%competitorsemployeescustomers (to aslightly lesser extent)were most likely to point the finger. Onlyin a quarter of instances did a regulatormake the accusation. This may speakto greater business and stakeholderactivism, or perhaps that we have becomea society that deflects attention away fromour own actions by pointing at others.PwC 15

4Feeling the pinch:The cost of economic crimeFinancial loss due to all economic crime experiencedQIn financial terms, approximately how much do you think your organisation may have directly lost through allincidents of fraud, corruption or other economic crime over the last 24 months?38%Less than US 100,00027%US 100,000 to US 1 million13%US 1 million to US 5 million8%US 5 million to US 50 million3%US 50 million to US 100 millionUS 100 million, or moreAmount is immeasurableDon’t know4%1%5%The total losses associated with economiccrime are difficult to calculate.While some costs such as direct financial loss or costs due to fines,penalties, fraud response and remediation can be quantified, it isnear impossible to place a value on other areas impacted by fraud —opportunity costs, reputational damage to a name or brand, loss ofmarket position, and the impact on employee morale and productivity.Threats arising from outside an organisation are generally transactionalin nature, can potentially be monitored actively with relative easeand have limited (or at the very least, quantifiable) financial impact.Less predictable attacks such as bribery & corruption and internallyperpetrated fraud lend themselves to greater complexity because theyattract more costly fines and bring with them other related issues (suchas brand value impairment or lost revenue). These need to be managedand mitigated from the perspective of the amount of loss that could besustained as a result of a decline in company or security value.Roughly 7% of South African respondents who experienced a fraudin the last 24 months reported losing more than 50 million across allincidents, with 4% reporting direct losses in excess of 100 million for allincidents of fraud, corruption or economic crime experienced in the past24 months. Incidences of losses in excess of 100 million with respectto the most disruptive economic crime experienced by South Africanrespondents doubled since the 2018 survey, from 1% to 2%.16 2020 Global Economic Crime and Fraud Survey – 7th edition

Financial loss associated with the most disruptive economic crimeexperiencedQIn financial terms, approximately, how much do you think your organisation may have directly lost through themost disruptive economic crime incident over the last 24 months?GlobalSouth Africa25%Less than 50,000US 33%36%17%50,000 to 100,000 US 17%21%19%22%5 million to 50 million US 21%11%16%19%19%19%100,000 to 1 million US 13%11%9%1 million to 5 million US 27%50,000 to 100,000 US 12%100,000 to 1 million US 35%37%Less than 50,000US 8%5%4%1 million to 5 million US 8%7%5 million to 50 million US 5%8%10%13%50 million to 100 million US 3%1%0%50 million to 100 million US 3%0%0%100 million US ,or more2%1%1%100 million US ,or more2%1%2%3%Amount isimmeasurable1%3%0%Amount isimmeasurableDon't know5%0%6%7%11%11%2020Don't know2018201614%13%202020182016Source: PwC analysisEndemic corruptionOne in five South African respondents cited bribery & corruption as the economic crime which had the mostdisruptive impact — and almost half the companies surveyed were themselves accused of bribery & corruption.This remains a big challenge to business and government alike.In the past 24 months, 42% of South African respondents (global: 29%) say they have been asked to pay a bribein the course of doing business. Add this to the 44% who believe they have lost an opportunity to a competitorwho paid a bribe, and you realise how dismal the situation is.Considering the increased reported prevalence of these kind of incidents since our 2018 survey, swift anddecisive action needs to be taken.PwC 17

5A wake-up call for boardsand regulatorsAs businesses have evolved from sole traders to the complexorganisations of today, so too have the structures governing them.These include the board of directors and various regulators, whoseprimary responsibility is independent oversight of what is happening atthe organisation.Changes to board structures have been spearheaded by the variousKing Codes, among other regulations. However, recent corporatefailures in South Africa and abroad highlight the fact that despite thesestructures and oversight, corporate failures as a result of economiccrime continue to occur.Regulators are actively looking at these events to determine what wentwrong and how they can be prevented in the future. This is likely tolead to a new wave of additional regulatory oversight, despite the factthat 53% of South African participants (global: 36%) in our 23rd AnnualGlobal CEO Survey are ‘extremely concerned’ about the threat ofover-regulation to their organisations' growth prospects.In an environment of pervasive fraud and growing scrutiny fromregulators and the public, no organisation can afford blind spots.Our survey uncovered two particular anomalies and disconnects thatcall into question current anti-fraud strategies:Allegations and irregularities should beinvestigatedIt seems self-evident, but the best way toavoid getting embroiled in another fraud is toinvestigate the last one and to take appropriateremedial action. However, 42% of South Africanorganisations (global: 44%) did not conduct aninvestigation after finding fraud.Incidents should be taken seriously andreported appropriatelyOur survey uncovered some shocking findings:726659%(global: 73%) of incidents were notdisclosed to the auditors%(global: 69%) of incidents werenot disclosed to regulators or lawenforcement%(global: 65%) of incidents were notdisclosed to the board of directors18 2020 Global Economic Crime and Fraud Survey – 7th editionAre you assessing thethreats you face wellenough, or are gaps inyour perception leavingyou dangerouslyexposed?

Responses to incidents of economic crimeQHow did your organisation respond to the incident?Conducted an investigation / fact-finding58%Disclosed to board41%Disclosed to regulator / law enforcement34%Hired external forensic accountant / specialist30%28%Disclosed to auditor17%Prepared an insurance claimHired external counselDisclosed to other stakeholdersPublic disclosure or notificationOtherDon’t know14%12%10%8%2%Action takenNo action takenSource: PwC analysisIn our 2018 survey, we reported that one of the best antidotes to perpetrators rationalising their fraud is transparencyand openness. If the organisation is not investigating and/or not reporting its findings it has a long way to go inremedying the problem.In addition to the non-reporting highlighted in our survey, our experience confirms that reporting to the board andother oversight bodies often falls short of what is required for them to perform their oversight roles.Poor reporting is often as a result of: Defensive/Excessive reporting — resulting in anoverwhelming amount of information;These poor reporting strategies either leave the recipientsunable to determine what to do with the informationor without the information necessary to perform thenecessary oversight. Oversimplified/Underplayed reporting — resulting ininsufficient information to understand the extent of theincident; orTwo questions we should all be asking are: Deceptive reporting — resulting in a perception thatthe relevant information is being reported, when in factit is withheld or buried intentionally. Are there heightened risks that require additionaloversight by those charged with governance? Are organisations as mature as we think?PwC 19

5Are organisations as mature as we think?Which option best describes the key elements of your overall fraud programmesin relation to governance/resources?Q12%88%No dedicatedprogramme toaddress risksOrganisationswith a dedicatedprogramme toaddress risksOur findings revealthat a significantpercentage oforganisations arenot disclosingincidents totheir board andregulators, despitethe fact that 88%of South Africanrespondents saythey have someform of dedicatedanti-fraudprogramme.Formalised vs unformalised governance programmesQWhich option best describes the key elements of your overall fraudprogrammes?Governance resources53%Third party management53%49%Risk assessment43%Training / communication42%Monitoring / auditingInvestigations / disciplinary measures/ incentives41%35%Policies and procedures53%Informal or no governance with limited or no budgetFormal governance with adequate or prioritised budgetSource: PwC analysisOur survey reveals that, on average, only 55% of South African organisations have formal governance over anti-fraudprogrammes. With only half of organisations reporting formal governance over their fraud risk assessments, andfewer than that over fraud resources and governance, the question arises whether boards of directors should be moreinvolved.20 2020 Global Economic Crime and Fraud Survey – 7th edition

PwC 21

Heightened risks that require additional governanceTen red flags seen in recent governance failures1Dominant CEO5 Belittles members of the board andothers who disagree Directors are vastly experienced, but areonly passengers and do not contribute Runs organisation through fear Directors are vastly experienced, but indifferent industries and cannot contributeeffectively Often pride-driven and egocentric Will create a team around them who willnot rock the boat by asking questions2Unhealthy board dynamics Directors do not understand theoperating environment and businessmodel complexity of the organisation6 The chair uses a ‘tick-box’ method tomove through the agenda Some directors have significantinfluence on board decisionsInconsistent governance andreporting standardsWatch the hidden tactics tohide fraud Material year-end transactions areperformed and approved, withoutcommercial substance, just beforefinancial statements finalisation Members reluctant to express theirpoints of view in front of management3Expertise of board is out of sync Related parties are not adequatelyidentified7Culture of deference and lackof challenge Policies, standards and frameworks arenot complied with and not questionedby the board Members are not willing to put theirhands up and ask the challenging or‘stupid’ questions Multiple auditors in the group, making itdifficult to see the full picture Do not ask questions when companyis healthy – even if industry is notperforming well Directors do not get proper answers totheir questions and don’t probe further4Monitoring of managementrelations and performance Management’s personal wealth,including incentive/performancebonuses, is linked too closely to theperformance of the company Inappropriate close relations betweenthe CEO and CFO22 2020 Global Economic Crime and Fraud Survey – 7th edition8Ineffective nominationscommittee Composition and expertise of the boardis of no importance Role of the nominations committee toensure board is balanced and equippedto perform its required duties isundermined

These dynamics bring up theneed to ‘trust, but verify’.9Weak assurance functions Weak assurance functions led byinexperienced CAE, CRO or CCOWhile two-thirds of organisations surveyed arecovering the basics — policies, procedures,training and monitoring — barely half are dedicatingresources to risk assessment and governance. Theseare, or should be, the head, heart and engine of arobust and credible anti-fraud programme — andsome regulators are beginning to demand more than"check-the-box" compliance, which can only beachieved with the necessary resources and oversight. Not focused on strategic business risks Does not have the required standing10Board pack not fit for purpose Packs are excessively congested andfilled with information of poor qualityor little importance to board members— used to mask important and/orincriminating information Not enough time to prepare becauseboard packs arrive latePwC 23

Fraud insights:Prepare.Respond.Emerge stronger.6Taking initiative:Preparing for fraudFrom a global perspective, on average, companies have four dedicatedprogrammes in place to mitigate fraud risk (larger companies withmore than 10,000 employees average more). While almost sixtypercent of South African respondents say they have policies andprocedures in place that include training and monitoring, only aroundhalf of organisations in South Africa are dedicating resources to riskassessment, governance, and third-party management.24 2020 Global Economic Crime and Fraud Survey – 7th editionWhat measuresare you taking toprevent fraud? Canyou adequatelyidentify fraud in yourenvironment? Haveyou considered whatis working — and whatsimply isn’t? Do yourprogrammes, methodsand technology closeoff all gaps or arethere gaping holes inyour armour? Whatimprovements can bemade right now andhow are you managingthese?

So how do we solve for this serious issue?An active androbust riskassessmentprocessCompanies should perform robustrisk assessments, gatheringinternal input from stakeholdersacross the organisation and acrossgeographies, to identify risks andassess mitigating factors. Externalfactors should also be considereddur

Types of economic crime/fraud experienced Customer fraud was introduced as a category for the first time in our 2018 survey. It refers to fraud committed by the end-user and comprises economic crimes such as mortgage fraud, credit card fraud, claims fraud, cheque fraud, ID fraud and similar fraud types. Source: PwC analysis 2

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