EBA欧洲银行-EBA-DC-120-28Decision-on-Anti-Fraud-Strategy29_17页_726kb

EBA Anti-Fraud Strategy 2015-2017 Summary

Core Content

The European Banking Authority (EBA) adopted the Anti-Fraud Strategy 2015-2017 on 29 April 2015, with the aim of improving the prevention and detection of fraud, achieving adequate reparation and deterrence, and maintaining the integrity and reputation of the Authority. The strategy is based on a comprehensive threat assessment and aligns with the European Commission's Anti-Fraud Strategy (CAFS) and OLAF's guidance for EU decentralised agencies.

Main Objectives

The strategy outlines four main objectives, each targeting different aspects of fraud prevention and response:

1. Prevent

• Definition: Minimise the likelihood of fraud by denying opportunities and reducing motivation.
• Areas of Action:
  • Address potential conflicts of interest through annual declarations of interests.
  • Implement resilient systems and processes with staff training and oversight.
  • Promote a strong anti-fraud culture through shared ethical values and leadership.
• Indicators:
  • No negative audit findings.
  • Number of risks in priority processes addressed with mitigating measures.

2. Detect and Investigate

• Definition: Continuously monitor for irregularities and support investigations.
• Areas of Action:
  • Use risk assessments to identify "red flags".
  • Establish reporting channels for staff to raise concerns.
  • Maintain communication with OLAF and support its investigations.
• Indicators:
  • Number of established red flags.
  • EBA's responsiveness to OLAF requests for information.

3. Recover, Mitigate and Respond

• Definition: Limit the impact of fraud and impose proportionate sanctions.
• Areas of Action:
  • Use legal powers to recover lost funds and property.
  • Enhance risk management to respond effectively to fraud events.
  • Apply proportionate and legally viable sanctions in line with Staff Regulations.
• Indicators:
  • Proportion of property/finance reclaimed.
  • Proportion of fraud-related harms addressed with mitigation measures.
  • Proportion of sanctions applied following disciplinary board outcomes.

4. Exploit

• Definition: Use lessons from fraud cases to strengthen the strategy and deter future incidents.
• Areas of Action:
  • Incorporate lessons from detected and investigated cases into threat assessments.
  • Publish outcomes of disciplinary cases to communicate consequences and deter future fraud.
• Indicators:
  • Number of fraud cases where lessons were identified.
  • Number of process improvements based on recorded lessons.

Key Information

• The strategy is proportionate to the fraud risks faced by the EBA and considers the costs and benefits of measures.
• It aims to protect the EU's financial interests and reputation while maintaining high standards of accountability and transparency.
• The EBA is a small authority with limited resources, so its anti-fraud efforts are focused on core financial and human resource management tasks.
• The strategy includes capability development and is implemented via an implementation plan that will feed into a revision in Q4 2017.
• The Management Meeting is responsible for risk management and decision-making on mitigation actions.
• The Ethics Officer and Legal Unit play key roles in supporting the strategy, particularly in investigations and sanctions.
• The HR Team ensures anti-fraud principles are integrated into recruitment and manages human resource-related issues during investigations.
• All EBA staff are expected to contribute to threat assessments and report concerns about fraudulent behavior.

Common Characteristics of Fraud

• Motivation: Often driven by personal gain or inappropriate influence.
• Opportunity and Capability: Linked to control weaknesses and lack of awareness/training.
• Rationalisation: Supported by a permissive organisational culture and limited oversight.

Implementation and Review

• The strategy is implemented through a dedicated implementation plan.
• It will be reviewed every three years, following updated threat assessments and incorporating lessons learned.
• The strategy includes communication efforts to reinforce anti-fraud values and deter fraudulent behavior.

Conclusion

The EBA Anti-Fraud Strategy 2015-2017 is a comprehensive framework designed to protect the Authority from fraud, corruption, and other illegal activities. It emphasizes a proactive, proportionate, and integrated approach, leveraging internal controls, stakeholder engagement, and external collaboration (particularly with OLAF) to ensure the integrity of the EU's financial systems.