Page 45 - CMA Journal (Jul-Aug 2026)
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F oc us  S ec t ion



              The risk becomes more signi cant in procurement   Similarly, Brazilian construction company Odebrecht                                        Connecting Data Across Systems                    of analysing each additional transaction can fall                                         For countries where internal  audit teams are     controls such as segregation of duties, audits and
              when individuals have control over substantial    was  involved in  corruption across multiple  countries                                                                                      substantially.                                                                            consistently outnumbered by procurement volumes,   supplier checks remain important, but technology can
               nancial resources and considerable decision-making   and ultimately paid substantial penalties and                                          Fraud schemes can also exploit gaps between di erent   In some cases, organisations may achieve a return on                                 automated tools are increasingly becoming a necessity   extend their reach by analysing transactions at scale,
              authority.                                        settlements.  The Petrobras “Car  Wash” scandal also                                       organisational systems rather than weaknesses within   investment within six to twelve months when avoided                                  rather  than  simply a modernisation initiative.   identifying  unusual  patterns  and  connecting
                                                                resulted in signi cant  nancial losses associated with                                     a single system. Cross-system AI can therefore provide                                                                                      Technology can expand the coverage of audit and   information across multiple systems.
              In developing economies, reliance on manual                                                                                                  additional value by correlating information from email,   losses and sta  time savings are considered. However,
              processes can further increase the opportunity for   overpriced contracts.  These cases demonstrate how                                      enterprise  resource  planning (ERP)  systems  and   successful implementation depends heavily on proper                                    monitoring functions without requiring organisations   The objective is not to eliminate human involvement
              fraud. Physical  les can be altered, removed or   procurement fraud and corruption can become deeply                                                                                           integration and con guration. Poorly tuned AI systems                                     to increase their audit workforce proportionately.  from procurement oversight but to enable
                                                                embedded in business operations when fraudulent
 Due  to  limited  resources,  it is  not possible for every   companies established   destroyed, while fragmented records may make it   practices remain undetected for extended periods.                   operating on inaccurate or incomplete vendor data                                         The Future of Anti-Fraud Procurement              professionals to focus their expertise where it matters
 organisation to produce everything independently.   for such  purposes  may,   di cult to establish a complete audit trail.                                                                                 can generate excessive false alerts and may ultimately                                                                                      most. AI, machine learning, continuous monitoring,
 Resource constraints have therefore compelled   upon investigation, be   What Traditional Controls Missed  What Technology Is Doing Di erently                                                              cost more than the losses they prevent.                                                   Despite the potential of these technologies, their   blockchain and stronger vendor-data  controls can
 organisations at the national, regional and global   linked to  an employee’s   One of the most signi cant changes in modern                                                                                Why  Technology Matters More in                                                           adoption should not be interpreted as an argument for   provide earlier warnings and broader visibility, while
 levels to work together to ful l one another’s needs.   address, bank account or   For decades, the primary tools for preventing and   procurement is the shift  towards continuous                                                                                                                   replacing  human   judgment   with  algorithms.   accountants, auditors and procurement professionals
 This may involve the supply of raw materials, high-tech   other personal interests.  detecting procurement fraud were largely manual and   transaction monitoring. Instead of reviewing a sample            Developing Economies                                                                      Presenting technology in such terms would overlook   remain responsible for interpreting those signals and
 equipment and machinery, as well as services such as   Other  forms  of  periodic.  These included segregation of duties,   of transactions periodically, automated systems can                             The case for adopting anti-fraud technology becomes                                       important limitations  associated with automated   taking appropriate action.
 construction and consultancy. Procurement is the   procurement  fraud  post-transaction internal audits, policy checks,   assess transactions as they occur and identify                                    particularly compelling in developing economies                                           decision-making.                                  Ultimately, anti-fraud technology is most e ective
 process of identifying needs, searching for suppliers or   include invoice fraud   reference checks and supplier blacklists. Such controls   potentially unusual activity. For example, a system can        where audit capacity may be limited relative to                                           Research and practice  concerning trustworthy  AI in   when it  is  supported  by reliable  data,  sound
 vendors, and negotiating the prices and costs of goods   and  overbilling,  remain valuable and have successfully identi ed    ag duplicate payments as soon as they are recorded.  payment platforms. This can help identify patterns that   procurement volumes.                                    public procurement continue to highlight the      governance  and professional judgment.  The real
 or services. While de nitions may vary slightly across   undisclosed con icts of   numerous cases of procurement fraud. However, their                    may remain invisible when each system is analysed                                                                                           importance of e ective governance. If an AI model is   opportunity  is  therefore  not  simply  to  automate
 sources, an e ective procurement process generally   interest,  splitting  e ectiveness is limited by their reliance on sampling   Arti cial intelligence and machine learning can take   separately.       South  Asia  provides  several  examples  of  digital                                     deployed without appropriate oversight, it may    existing controls, but to create a procurement
 incorporates a number of core operational steps.  purchases into smaller   and periodic review.  this capability further by identifying deviations from   The Impact of Anti-Fraud Technologies             procurement at di erent stages of development.                                            incorrectly   ag  a  legitimate  supplier  as  suspicious   environment in which unusual behaviour is identi ed
                                                                                                                                                                                                             India’s Government e-Marketplace (GeM), launched in
 For any organisation, procurement represents one of   transactions  to  Sampling can detect only those transactions selected   normal purchasing patterns across vendors, categories                        2016, represents a relatively mature example.                                             without providing a su ciently transparent basis for   earlier,  investigated  more  e ectively  and  becomes
 the areas through which substantial amounts of   circumvent  approval  for examination. A fraudulent scheme spread across   and transactions. The systems can identify behaviours   According to Feedzai/Orbograph industry survey data,   According to the available data, it connects more than     the decision. Such an outcome can cause signi cant   increasingly di cult to conceal.
 money can leave the organisation without immediate   thresholds, and change-order abuse. In the latter case,   hundreds or thousands of transactions may continue   such as a vendor repeatedly submitting bids that are   close to 40% of  nancial institutions that had adopted   1.6 million buyers with over 2.3 million sellers. An   harm to businesses and undermine con dence in the   References
 visibility. Audit professionals frequently identify   a supplier may submit a low winning bid and   for years without appearing in a sampled transaction.   just high enough to lose while remaining part of a   AI-based fraud detection reported reductions in losses   independent World Bank evaluation found that buyers   procurement process.
 procurement as a high-risk area, not necessarily   subsequently increase the contract value through   Furthermore,  when  controls  are  applied  primarily   recurring bidding pattern, or purchases being   of between 40% and 60%. Ukraine’s ProZorro   achieved  median  price  savings  of approximately   An AI-based system should therefore be su ciently   •   Association of Certi ed Fraud Examiners, Report to the Nations — the
                                                                                                                                                                                                                                                                                                                                                           fraud triangle framework of opportunity, pressure, and rationalisation is a
 because procurement personnel are dishonest, but   variations or additional work that was not subject to   during an  annual audit, the funds  may already have   deliberately divided to remain below approval   procurement system, which combines transparency   9.75%. At the same time, India’s CAG has highlighted   explainable  for  auditors  and  procurement  long-standing staple of fraud examination literature.
 because the process contains numerous discretionary   the original competitive process. In practice,   been transferred and the supporting documentation   thresholds.  mechanisms, blockchain-based record-keeping and   the need for stronger benchmarking of GeM’s savings                         professionals to understand why a particular      •   U.S. Securities and Exchange Commission, “SEC Charges Siemens AG for
 points at which decisions can be manipulated without   procurement fraud schemes may involve a   may have been altered or organised to conceal the   Benford’s Law can also be used as an analytical   AI-supported  agging, has been credited with   methodology, demonstrating  that digitisation alone   transaction or  supplier  has been  agged.  The   Engaging in Worldwide Bribery,” press release 2008-294, December 15,
                                                                                                                                                                                                                                                                                                                                                           2008. sec.gov/news/press/2008/2008-294.htm
 detection for extended periods. Procurement fraud   combination  of  two  or  more  of  these  methods   technique to identify unusual distributions of leading   generating substantial savings. Similarly, India’s   does not automatically guarantee e ective oversight.                           responsibility of accountants and auditors to exercise   •   U.S. Department of Justice, “Siemens AG and Three Subsidiaries Plead
 occurs when an individual deliberately manipulates   operating simultaneously.  underlying activity.  digits in  nancial data. When combined with modern   Comptroller and Auditor General (CAG) announced in                                                                                         professional scepticism does not disappear simply   Guilty to Foreign Corrupt Practices Act Violations,” press release, December
 sourcing, tendering, contracting or payment processes   The   nancial  consequences  of  undetected  anomaly-detection techniques and machine-learning    2026  that  it  was  using  AI  tools  and  advanced  data   Bangladesh’s e-GP system has been operational since                            because an algorithm makes the initial assessment.   15, 2008. justice.gov/opa/pr/2008/December/08-crm-1105.html
 to  obtain  nancial  or  other  bene ts  dishonestly. The   procurement-related corruption can be substantial.   models, such methods can provide an additional layer   analytics to scan public tenders, identify pricing   2011 and had moved most large tenders online  by                         Instead, their role expands to include reviewing the   •   Harvard Law School Forum on Corporate Governance, “2016  Year-End
 critical distinction between an error and procurement   Between 2001 and 2007, Siemens paid more than $1.4   of analysis for identifying invoice batches or  nancial                                        2023. Pakistan has also expanded digital procurement                                      model, its thresholds, the quality of its underlying data   FCPA Update,” January 19, 2017 (Odebrecht/Braskem settlement detail);
                                                                                                                                                                                                                                                                                                                                                           Willkie Compliance Concourse, “Odebrecht Monitorship Comes to a Close,”
 fraud is intent: fraud involves knowingly circumventing   billion in bribes to secure contracts ranging from   records that may warrant further investigation.                                              through  the   Public  Procurement  Regulatory                                            and the processes through which  agged suppliers or   November 2020 ( nal $2.6 billion penalty).
 established rules or controls for an improper purpose.  national identi cation systems in Argentina to metro                                                                                                Authority’s Electronic Procurement System (EPADS).                                        transactions are investigated.                    •   Mongabay,  “Brazil's Lava Jato Investigation:  The Biggest Corruption
                                                                                                                                                                                                                                                                                                                                                           Scandal of the Last Decade,” March 2025; Petrobras Form 20-F  lings, U.S.
 How Procurement Fraud Happens  lines in Venezuela. Following its settlement with US   Strengthening Vendor Master Data                                                                                      During FY2024–25, EPADS reportedly processed                                              Procurement fraud often thrives on transactions that   Securities and Exchange Commission (sec.gov/cgi-bin/browse-edgar).
              and German authorities in December 2008, Siemens   Vendor master data is another important area where                                                                                          526,239 transactions worth Rs. 1.408 trillion and                                         appear routine, insigni cant or anonymous and     •   AllAboutAI, “AI Fraud Detection Statistics 2026,” citing Feedzai/Orbograph
 Procurement fraud generally occurs through several   paid approximately $1.6 billion in  nes and   technology can strengthen procurement controls.                                                          generated  administrative  cost  savings  of  Rs.  20.52                                  therefore receive limited scrutiny. Continuous      industry  survey  data.  allaboutai.com/resources/ai-statistics/
 recurring patterns, with bid rigging among the most   disgorgement, making it one of the largest Foreign   Automated systems can continuously screen vendors                                                billion.  The system has also been connected with                                         monitoring and pattern detection are steadily       ai-fraud-detection
 common. In bid rigging, competing vendors collude in   Corrupt Practices Act sanctions on record.  against relevant watchlists and  other control                                                           institutions including FBR, NADRA, SECP and PEC, with                                     reducing the opportunity for such activity to remain   •   Harvard Kennedy School, Mossavar-Rahmani Center for Business and
                                                                                                                                                                                                                                                                                                                                                           Government, “Overcoming  Corruption and War: Lessons from Ukraine's
 advance to determine who will win a tender.                    databases. Changes to vendor bank details can be                                                                                             oversight access for bodies such as the Auditor                                           hidden. However, organisations that derive the      ProZorro,” 2022; U.S. Strategy on Countering Corruption, December 2021.
 Participants may take turns submitting losing bids so          subjected to dual approval, while system-based access                                                                                        General, NAB and the Competition Commission.                                              greatest value from these technologies are unlikely to   hks.harvard.edu/centers/mrcbg
 that the group can maintain arti cially high prices   What Procurement Fraud Has Actually Cost  controls can restrict who is authorised to create or                                                                                                                                                  be those that simply invest in the most sophisticated   •   World Bank,  “How Government e-Marketplace Is Revolutionizing
                                                                                                                                                                                                                                                                                                                                                           Procurement  in India,”  World Bank  Blogs; Press  Information  Bureau,
 while preserving the appearance of competition.                                                                                                                                                                                                                                                                                                           Government  of  India,  GeM  assessment  note,  2022.
                                                                modify vendor records and payment information.                                             anomalies and detect potential bid rigging.  These                                                                                          platforms. Rather, the strongest results come from   blogs.worldbank.org/en/governance
 Another common form is kickbacks and bribery. In   Why Procurement Fraud Continues to                                                                     developments indicate that advanced analytical tools                                                                                        organisations that combine technology with capable   •   Public  Procurement Regulatory Authority (PPRA), Pakistan, o cial
 such cases, an o cial directs a contract towards a             Blockchain and Record Integrity                                                            are increasingly being incorporated into public-sector                                                                                      professionals who are willing to challenge anomalies   announcements on EPADS FY 2024–25 performance and administrative
 favoured vendor in exchange for a personal bene t.   Occur     Blockchain technology addresses procurement risks in                                       audit and procurement oversight.                                                                                                            and  ask  the  fundamental question  that  has  always   savings. ppra.gov.pk/announcements
 Such bene ts may be disguised as consulting fees,   The recurrence of these fraud patterns across countries   a di erent way. Once a record is entered into a properly   The initial cost of technology can be higher than that of                                                                    been central to good auditing: Why should I believe
 employment opportunities or arrangements involving   and industries can be understood through the   designed shared ledger, it becomes signi cantly more   traditional  manual  controls.  Manual controls  may                                                                                       this?
 relatives or associates.  well-established  concept  of  the  fraud  triangle:   di cult to alter it retrospectively without detection.                   largely  be  incorporated  into  existing  sta                                                                                              Conclusion
 A third form involves  ctitious vendors. Under this   opportunity, pressure and rationalisation. Individuals   Such controls can reduce opportunities for fraudulent   responsibilities, whereas  automated systems  require
 scheme,  an  organisation  is  invoiced  for  goods  or   may rationalise fraudulent behaviour by convincing   Figure 2: Bribes paid versus fines and settlements in two of the largest   backdating  or  unauthorised  modi cation  of  investment in software licences, ERP integration, data        The transformation of procurement through data and
 services that were never supplied or performed. Shell   themselves that such conduct is acceptable because                      procurement-linked corruption cases on record.  procurement records.  cleansing and implementation. However, once                                                     automation represents a signi cant shift from periodic
 others are doing the same.                                                                                                                                automated systems are operational, the marginal cost                                                                                        detection towards continuous prevention. Traditional

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