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Financial Services

A Guide to Fortify Your Institution Against Senior-Level Embezzlement Risks


This blog, the first in a series by Perficient’s Risk and Regulatory Center of Excellence (CoE), provides actionable measures your company can adopt to safeguard against senior-level embezzlement risks and maintain the integrity of your institution’s financial transactions.


On October 19th, 2023, the Office of the Comptroller of the Currency (OCC) published an article highlighting new enforcement actions and clarifying explicit rules regarding misconduct, particularly as it relates to financial abuse by senior-level management.

As the world witnesses the onset of what has been termed the “largest transfer of generational wealth” the inherent challenges and temptations for institutions to exploit their customers have become more pronounced. Against this backdrop, it becomes paramount for organizations to fortify their defenses and implement robust controls to block senior-level embezzlement tactics.

Establishing Strong Internal Controls

Segregation of Duties (SoD): The primary goal of SoD is to ensure there are checks and balances in a transaction; one person is not allowed to have complete control over a transaction from start to finish.

  • Divide responsibilities among multiple individuals to prevent a single person from having too much control over financial transactions.
  • Ensure checks and balances are present in all transactions.
  • Avoid having one person with complete control over transactions from start to finish.

Clear Policies and Procedures: Establishing clear guidelines and protocol practices is crucial in safeguarding your business.

  • Establish clear guidelines and protocols for financial transactions, approvals, and reporting.
  • Regularly review and update policies annually to ensure compliance with current rules and regulations.
  • Ensure all employees, including senior management, are aware of and adhere to those policies.
  • Implement a check and balance or send policies/procedures through a multi-business review approach to confirm documentation updates and adherence to current rules and regulations.

Monitoring and Oversight: Other effective internal controls are the basis for strong financial systems, programmatic oversight, and processes that prevent fraud, waste, and abuse.

  • The use of monitoring systems that track and analyze financial activities.
  • Software tools to detect unusual patterns or transactions, risk management protocols, compliance assurance, regular reporting, and quality control.

Regulatory Risk and Compliance is Our Expertise

Emerging anti-corruption regulations, from all over the world, have led to a complicated international market with businesses needing to establish third-party compliance programs.

Our client, a global regulatory and financial crime, risk, and compliance company, felt it needed to build a product to further empower its business and its customers while it had industry-leading knowledge and advisory services. We partnered with our client’s technical teams to build advanced and intuitive software that would quickly and effectively generate risk profiles for third parties, helping its customers maintain compliance.

As a result, from partnering with our client, we were able to create a product with an intuitive user experience that is localized and configurable to support a diverse worldwide customer base. All information can be managed in one place, which saves money, increases accuracy, and streamlines third-party onboarding and management for customers.

READ MORE: Developing a Third-Party Risk Management Tool

Are you ready to optimize your business? 

As your digital solutions partner, Perficient invites you to engage in discussions addressing your specific risk and regulatory challenges.

Our unparalleled financial services expertise and digital leadership across platforms and businesses empower the largest organizations to overcome complex challenges and foster growth.

Contact us today to navigate the evolving landscape of risk and regulation successfully.

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Oscar Echeverria

With over ten years of experience in risk management, Oscar is a dedicated professional adept at identifying, assessing, and mitigating potential risks to ensure organizational resilience. Oscar holds a Master of Arts in Political Science, constantly engages in professional and personal development, and remains at the forefront of emerging risk management methodologies. He is committed to delivering strategic solutions that fortify organizations against uncertainties and support sustainable growth.

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