Appendix 4: external fraud response plan example
- inform the SG Fraud Response Team, the appropriate finance officials and SG Legal that a suspected fraud has taken place and discuss any particular aspect that may require special handling
- consider suspending the [project/grant funding/supplier payment] and whether recovery action is required
- in consultation with the SG Fraud Response Team, consider what actions, if any, need to be taken to raise awareness about any wider effects of the alleged/attempted fraud
- consider what actions need to be taken to report the fraud to the Police and for them to establish the facts. Engage specialist advice as required
- consider what support is required for any ongoing investigations e.g. availability of staff for statements
- keep the Senior Management, including the Accountable Officer, updated as appropriate and ensure the Portfolio Audit Committee fully appraised of the potential fraud, the potential risk and the actions to be taken
- in consultation with the relevant finance officials, consider losses and special payments implications as set out in the Scottish Public Finance Manual.
- consider reporting requirements both in respect of the Annual Fraud Report through the SG Fraud Response Team and [depending on the nature of the fraud] the appropriate Parliamentary Committee
Note: if there is any suspicion of collusion on the part of SG members of staff in a suspected or discovered external fraud, the procedures relating to internal fraud should apply as appropriate, given any requirements arising from ongoing Police/Procurator Fiscal investigations.