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implicated 
in the fraud 
(d) 
Assessing whether the 
fraud
was not detected because 
existing controls 
were not operating 
properly, or whether existing controls would have been unlikely to prevent or identify the fraud 
Key decisions in fraud investigation will include who will be 
carrying out the investigation
and also 
whether the investigation will be 
undercover
. Guidance produced by the accountancy firm KPMG has 
highlighted the importance of quickly obtaining a picture of the 
activities 
of the suspected fraudster by 
reviewing their personal paperwork (diaries, files, expense claims, etc) and also contacting the people 
who worked with them. 
Ultimately the detection and prevention of fraud requires not only a 
clear strategy 
but also a 
willingness 
to enforce controls
. 
4.24 Evolving control systems 
The environment in which organisations exist and operate changes constantly. The risks organisations 
face also change over time. Some risks will decrease with time, other risks will increase, new risks will 
arise.
For the systems intended to control and minimise the impact of risks to be effective they also must 
change and adapt. The control systems must evolve to deal with the risks present in the changing 
environment. Control systems must therefore be reviewed constantly and, if necessary, changed or 
adapted in order to cope with new risks.
This is particularly true where legislation changes, such as the relatively recent changes in the UK to 
money laundering and bribery legislation. Control systems must enable the organisation and the 
individuals that work within the organisation to meet their legal obligations under new legislation.
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