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#

Introduction

## Fraud in the news

Before you delve into the course, take a look at this example.

Select the arrow button to find out more.

### What was uncovered?

A Financial services company disclosed to authorities that, over the course of 17 years, the bank defrauded its clients out of USD 290 million.

### What was the motivation?

The company secretly marked up “out-of-pocket” (OOP) expenses charged to clients to gain profits, despite telling clients that OOP expenses were passed through without markups.

The executives took steps to conceal the mark-ups from clients, including by misleading clients when they inquired about what they were being charged for OOP expenses.

### What was the outcome?

It was agreed they will pay a USD 115 million criminal penalty and enter into a deferred prosecution agreement. They have also agreed to enhance its compliance program, and to retain an independent corporate compliance monitor for a period of two years. Violating this trust also came with a big price-tag in terms of negative press and relationship building, which, for all the financial technology in the world, is still what business transacting in financial services depends upon.

### What does this mean for the Bank?

Within Credit Suisse, the undertaking of undesirable business activity to generate income for the Bank, and the deliberate failure to escalate identified incidents, is not tolerated in any way by Credit Suisse under our standards of conduct, clear escalation requirements, and dedicated reporting lines.

### What are you required to do?

Credit Suisse personnel are required to act with due care and attention, and report unusual incidents or concerns to line management, Compliance, Human Resources or General Counsel, or anonymously via the Credit Suisse Integrity Lines.

Remember: See Something? Say Something.

## Fraud and your responsibilities

Bad actors are now leveraging technology to gain unauthorized access to bank and client funds. Information as well as currency has become a valuable target for both internal and external fraudsters. Credit Suisse personnel must therefore be alert to ALL unusual activities and escalate any potential fraud or suspicious activity immediately.

Credit Suisse has technical controls that mitigate these risks and to further strengthen the bank-wide Anti-Fraud Framework, Anti-Fraud Global Minimum Standards (AFGMS) have been introduced in 2021 to ensure consistent and sustainable internal and external fraud risk mitigation. It is important that Credit Suisse personnel are familiar with these AFGMS as part of their day-to-day activities or whilst working on Change Initiatives.

All personnel should be aware that their footprint is monitored by the Bank. Any Credit Suisse policy violations can result in disciplinary proceedings up to termination of employment, and civil and/or criminal charges, if applicable.

## About this course

This course will:

- Outline your responsibilities in escalating unusual incidents or concerns through the appropriate channels without delay
- Describe the drivers behind internal fraud
- Detail the types of internal and external fraud, and the controls we use to deter them
- Pose several scenario-based questions highlighting red flags of potential fraud

The training will take approximately 30 minutes to complete.

To register successful completion of the course, you will need to review each topic and complete the questions included throughout.

A list of useful links is available at any time by selecting the Resources button.

Intranet links might not be available over the Saba Mobile App.

## Coming next

Now that you’ve had an introduction, let’s get started with your responsibilities in escalating unusual incidents or concerns, and how this should be done through the appropriate channels.

Select the Next Topic button to continue to the next topic or select the Home button to return to the home page.

Escalation of unusual incidents or concerns

## Think about it...

Before we begin, take a moment to reflect.

Why is it important to escalate unusual incidents or concerns?

What is in it for you, our clients, and Credit Suisse?

## What to escalate

You must escalate unusual incidents or concerns that pose, or may pose, significant risks. These include unusual incidents or concerns that could lead to financial loss for Credit Suisse or our clients.

You also must escalate unusual incidents or concerns that could cause other significant, non-financial, or reputational harm to our clients, personnel, Credit Suisse, and the integrity of the markets.

## Escalation channels

When escalating an issue, you are encouraged to consider the appropriateness of the channel of escalation. You must escalate unusual incidents or concerns to any of the following parties, with the exception of incidents involving suspected violations of US Cross Border Policy (P-00025) and/or FATCA Policy (GP-00085):

| Your primary contact to escalate unusual incidents or concerns is your line manager (except when it is inappropriate to do so) or other appropriate management or senior management.
| Compliance, Human Resources, General Counsel.
| The Credit Suisse Integrity Hotline (phone) or Integrity Line (web) (where anonymous reporting is available, if permitted by law).

In some cases, it may be appropriate to escalate an unusual incident or concern to more than one party. For example, the operational risk aspect of a data loss incident is captured according to the Incident Collation Policy (GP-00260) and the conduct-related aspect of the incident in line with the Disciplinary Policy (GP-01058).

## Coming next

Now that you have an understanding of your escalation responsibilities, let’s review the different types of internal fraud and the controls Credit Suisse uses to deter internal fraud.

Select the Next Topic button to continue to the next topic or select the Home button to return to the home page.

Internal fraud

## What is internal fraud?

Internal fraud is an intentional act committed by an organization’s own personnel to defraud the organization or the client.

Often, it is committed by one person acting alone within the Bank and can be identified through behavioral red flags displayed by fraudsters, but it can occur through the collusion between Bank personnel.

The three drivers of fraud, opportunity, motive/pressure, and rationalization are arranged as an equilateral triangle.

Text summarizes the key aspect of the fraud driver opportunity as exploits weaknesses in people or systems.

### Motivation

Motivations to commit fraud can arise from:

- Personal financial problems, vices, or gain (e.g., gambling)
- Unrealistic deadlines and performance goals set by management
- Political and/or moral reasons
- Responses to threats
- Revenge
- Emotional pressure
- Drive to “hit financial targets”
- Infiltration

The three drivers of fraud, opportunity, motive/pressure, and rationalization are arranged as an equilateral triangle.

Text summarizes the key aspect of the fraud driver motive/pressure as looks for incentives to commit fraud.

### Opportunity

The fraud can be facilitated through weaknesses in people, internal controls, or bank systems and processes. For example:

- Inadequate or no supervision, lack of segregation of duties, or management approval
- Knowledge of process weakness and poor controls in the bank
- Poor documentation of internal procedures
- Limited supervision due to work-from-home environment
- Submission of falsified client documents/client orders

The three drivers of fraud, opportunity, motive/pressure, and rationalization are arranged as an equilateral triangle.

Text summarizes the key aspect of the fraud driver rationalization as justifies dishonest actions.

### Rationalization

The individual justifies his/her fraudulent activities. For example:

- "I am merely ‘borrowing’ the money"
- "I work hard so I deserve this money..."
- "I need to recover this client's losses..."
- "I am going to pay it back..."
- "Everyone is doing it..." (other staff/management also acting dishonestly)
- Poor relationship with employer
- Financial services sector already suffers losses due to fraud
- Difficulties during the pandemic

## Types of internal fraud

The following types of internal fraud are common in the financial services industry:

- Unauthorized trading occurs when personnel execute trades to hide profits and losses.
- Unauthorized activity occurs when personnel transfer cash or securities from a suspense or nostro account, or depo break, or amends account statements.
- Unauthorized funds and assets transfers occur when personnel execute funds or assets transfers from client accounts without client instructions.
- Expense reimbursement fraud can be made up of mischaracterized, overstated, or fictitious expenses.

## Credit Suisse controls to deter internal fraud

Credit Suisse has controls to deter internal fraud. However, even with strong controls, internal fraud can occur within the Bank.

Block leave

### Block leave

To mitigate the potential risks of Internal Fraud (incl. Unauthorized Trading), designated sensitive personnel under the Global Block Leave Policy (GP-00387) must take 10 consecutive business days leave period within a calendar year.

In doing so, employees must not perform duties relating to their role, access any Bank premises for business purposes, or use Bank systems including mobile applications.

Segregation of duties

### Segregation of duties

This control requires additional approval or authorization for a transaction or process. The aim is to prevent domination of controls, manual override of controls, or collusion between Bank personnel.

It is imperative that there are adequate segregation of duties involving custody, authorization, and control of source documents and records.

Independent verification of authority

### Independent verification of authority

The independent verification of authority for e.g., via call-back or transaction signing is used to verify transfer of funds/assets (i.e., payments, securities) or requests for changes to client or vendor static data. For such requests, an identity check of the instructing party; an authority check i.e., the right to move funds/assets or changes to client/vendor static data and authenticity checks must be performed to determine legitimacy of the instruction details. For further information please refer to the AFGMS.

## Example of internal fraud

Take a look at this example of internal fraud.

### Personnel collusion

A Fund Manager colludes with his longtime assistant to falsify the disclosures included in a product’s term-sheet.

Yannick is a Fund Manager with an established track-record of delivering tailor-made product solutions. This year Yannick’s line manager integrated ESG targets in his performance objectives/ definition of his annual bonus payment.

### Unauthorized activity

Yannick decides to falsify the term-sheet of an Equity Fund, backed by traditional heavy industry issuers in the Emerging Markets. By introducing ESG compatible disclosures, the product will fit the ESG metrics relevant to his performance objective and contribute to achieving his bonus targets. To put this plan in motion, Yannick poaches the support of his long-time assistant in return of a share of his bonus payment.

### Unauthorized activity concealed from the Bank

To conceal this activity from the Bank, Yannick:

- Circumvented bank controls by using his personal e-mail address to communicate the term-sheet to client and by refraining from documenting product promotion activities in client notes.
- Withheld information from his line manager and Compliance.
- Fabricated Investment Promotion materials.

## Scenario 1: Lee makes a transfer

It’s late afternoon and Lee is trying to quickly enter the last instruction from her client to transfer funds so she can leave on time for her doctor’s appointment. Under pressure, Lee does not realize that she chose the wrong beneficiary client.
Two days later, Lee receives a phone call from the client who complained that the transfer was not made in favor of the correct beneficiary.

The client demands strongly that the transaction be canceled immediately. However, as the beneficiary client does not respond to Lee’s fund return request, Lee forges transfer orders from three unrelated clients to rectify the error and gives them to her colleague Jamie, for approval.

Since Lee is a long-standing employee known for not making any errors and insisted that the orders are urgent, Jamie with no doubts about Lee’s professionalism directly approves the orders.

## Did Lee and Jamie do the right thing?

Which of the following statements about Lee’s situation do you think is correct?

If you’re not sure, review the key learning points first.

Lee did the right thing as she will repay the three unrelated clients once the beneficiary client will respond and return the funds.
Lee did the right thing as she will repay the three unrelated clients once the beneficiary client will respond and return the funds.
Jamie acted correctly as Lee is known for professionalism and known for not making any errors.
Jamie acted correctly as Lee is known for professionalism and known for not making any errors.
Lee and Jamie’s actions are a red flag of internal fraud, as Lee performed unauthorized funds transfers from client accounts without their knowledge and Jamie did not perform a four-eye check on the transactions.
Lee and Jamie’s actions are a red flag of internal fraud, as Lee performed unauthorized funds transfers from client accounts without their knowledge and Jamie did not perform a four-eye check on the transactions.
None of the above.
None of the above.

Well done, that is correct. The right answer has been highlighted.

Lee should have informed her line manager about the error as soon as it was identified and recorded all details in the bank’s incident collation tool.

Jamie, to approve the order should have validated that all pre-transaction checks (identity check, authority check, authenticity check, validation of order details) were performed. In addition, Jamie should have been attentive to the red flags, e.g., payment being time-critical and needed to be processed immediately, unusual client behavior, unusual beneficiaries etc.

In addition please refer to the AFGMS ID 3 which covers the approvers’ duty which encompasses the validation of all pre-transaction checks for value changing orders.

Partially correct. The right answer has been highlighted.

Lee should have informed her line manager about the error as soon as it was identified and recorded all details in the bank’s incident collation tool.

Jamie, to approve the order should have validated that all pre-transaction checks (identity check, authority check, authenticity check, validation of order details) were performed. In addition, Jamie should have been attentive to the red flags, e.g., payment being time-critical and needed to be processed immediately, unusual client behavior, unusual beneficiaries etc.

In addition please refer to the AFGMS ID 3 which covers the approvers’ duty which encompasses the validation of all pre-transaction checks for value changing orders.

Incorrect. The right answer has been highlighted.

Lee should have informed her line manager about the error as soon as it was identified and recorded all details in the bank’s incident collation tool.

Jamie, to approve the order should have validated that all pre-transaction checks (identity check, authority check, authenticity check, validation of order details) were performed. In addition, Jamie should have been attentive to the red flags, e.g., payment being time-critical and needed to be processed immediately, unusual client behavior, unusual beneficiaries etc.

In addition please refer to the AFGMS ID 3 which covers the approvers’ duty which encompasses the validation of all pre-transaction checks for value changing orders.

Unfortunately, that’s incorrect.

Take a moment to review these key points before you try again.

In most cases, internal fraud is committed by one person acting alone within the Bank and can be identified through suspicious behaviors, but it can occur through the collusion between Bank personnel. Suspicious behaviors include:

- Being secretive or nervous
- Unwillingness to share duties
- Willingness to override controls, often to “make things easier”
- Refusal to take vacation, or sick leave
- Accessing the Bank’s premises and/or systems during a block leave period
- Requesting to defer internal audits or inspections to “properly prepare”
- Previous history of policy breaches or near-breaches
- Unusual work hours

Examples of internal fraud include:

- Unauthorized trading occurs when personnel execute trades to hide profits and losses
- Unauthorized activity occurs when personnel transfer cash or securities from a suspense or nostro account, or depot break, or amends account statements
- Unauthorized funds and assets transfers occur when personnel execute funds or assets transfers from client accounts without client instructions
- Expense reimbursement fraud can be made up of mischaracterized, overstated, or fictitious expenses

Credit Suisse controls to deter internal fraud include:

Segregation of duties: This requires additional approval or authorization for a transaction or process. The aim is to prevent domination of controls, manual override of controls, or collusion between Bank personnel. It is imperative that there are adequate segregation of duties involving custody, authorization, and control of source documents and records.

Call-back verification: The verification of authority for e.g., via call-back or transaction signing is used to verify transfer of funds/assets (i.e., payments, securities) or requests for changes to client or vendor static data. For such requests, an identity check of the instructing party; an authority check i.e., the right to move funds/assets or changes to client/vendor static data and authenticity checks must be performed to determine legitimacy of the instruction details. For further information please refer to the AFGMS.

Please try again.

Unfortunately, that’s still not correct.

Review this key point before you try again.

In most cases, internal fraud is committed by one person acting alone within the Bank and can be identified through suspicious behaviors, but it can occur through the collusion between Bank personnel.

We have controls against internal fraud: block leave, segregation of duties, and call-back verification. Segregation of duties requires additional approval or authorization for a transaction or process (e.g., four-eye check principle). The aim is to prevent domination of controls, manual override of controls, or collusion between Bank personnel. It is imperative that there is adequate segregation of duties involving custody, authorization, and control of source documents and records.

Please try again.

Submit

## Scenario 2: Syed examines a request

Syed a supervisor is busy approving personnel expenses for his department’s Investment Consultants.

Next on the list is Jamie’s request for reimbursement of expenses incurred for a client meeting.

Jamie requested CHF 1,000 as done for previous client meetings. However, Syed notices that Jamie was on Block Leave during this period when the client meeting occurred.

## What should Syed do?

What should Syed do regarding Jamie’s request?

Please select all of the correct options. If you’re not sure, review the key learning points first.

Approve the reimbursement as its in line with the expenses reimbursement policy.
Approve the reimbursement as its in line with the expenses reimbursement policy.
Diligently review invoices and receipts from Jamie’s meeting to confirm the client meeting dates match the Block Leave period.
Diligently review invoices and receipts from Jamie’s meeting to confirm the client meeting dates match the Block Leave period.
Reach out to Jamie to understand why a client meeting was held while on Block Leave and close the matter internally.
Reach out to Jamie to understand why a client meeting was held while on Block Leave and close the matter internally.
Report the breach of the Block Leave policy to Compliance.
Report the breach of the Block Leave policy to Compliance.

Well done, that is correct. The right answers have been highlighted.

Jamie’s behavior is a red flag for Internal Fraud and is in violation of the Credit Suisse’s Global Block Leave Policy (GP-00387), which requires designated sensitive employees to take a leave period of 10 consecutive business days within a calendar year, and in doing so, they must not perform duties relating to their role, access any Bank premises for business purposes, or use Bank systems including mobile applications.

In addition, please refer to the AFGMS ID 17 which lists Supervisor’s responsibilities to ensure adequate oversight over internal and external fraud risks during the performance of their day-to-day responsibilities. AFGMS 21 lists the Supervisor’s responsibility to ensure adherence to the Block Leave policy and its access restrictions of their direct reports.

Partially correct. The right answers have been highlighted.

Jamie’s behavior is a red flag for potential expense reimbursement fraud, which can include mischaracterized, overstated, or fictitious expenses. Syed should request invoices and receipts from Jamie’s trip for further review. Syed should also immediately escalate the matter to line management and/or Compliance.

Incorrect. The right answers have been highlighted.

Jamie’s behavior is a red flag for potential expense reimbursement fraud, which can include mischaracterized, overstated, or fictitious expenses. Syed should request invoices and receipts from Jamie’s trip for further review. Syed should also immediately escalate the matter to line management and/or Compliance.

Unfortunately, that’s incorrect.

Take a moment to review these key points before you try again.

In most cases, internal fraud is committed by one person acting alone within the Bank and can be identified through suspicious behaviors, but it can occur through the collusion between Bank personnel. Suspicious behaviors include:

- Being secretive or nervous
- Unwillingness to share duties
- Willingness to override controls, often to “make things easier”
- Refusal to take vacation, block leave, or sick leave
- Accessing the Bank’s premises and/or systems during a block leave period
- Requesting to defer internal audits or inspections to “properly prepare”
- Previous history of policy breaches or near-breaches
- Unusual work hours

Examples of internal fraud include:

- Unauthorized trading occurs when personnel execute trades to hide profits and losses
- Unauthorized activity occurs when personnel transfer cash or securities from a suspense or nostro account, or depot break, or amends account statements
- Unauthorized funds and assets transfers occur when personnel execute funds or assets transfers from client accounts without client instructions
- Expense reimbursement fraud can be made up of mischaracterized, overstated, or fictitious expenses

Credit Suisse controls to deter internal fraud which include:

Block Leave: To mitigate the potential risk of internal fraud, designated sensitive employees under the Global Block Leave Policy (GP-00387) must take a leave period of 10 consecutive business days within a calendar year and in doing so, employees must not perform duties relating to their role, access any Bank premises for business purposes, or use Bank systems.

Please try again and be aware that you may select more than one answer.

Unfortunately, that’s still not correct.

Review this key point before you try again.

In most cases, internal fraud is committed by one person acting alone within the Bank and can be identified through suspicious behaviors, but it can occur through collusion between Bank personnel.

We have controls against internal fraud: block leave, segregation of duties, and call-back verification. The Global Block Leave Policy (GP-00387) requires that designated sensitive employees to take a leave period of 10 consecutive business days within a calendar year, and in doing so, they must not perform duties relating to their role, access any Bank premises for business purposes, or use Bank systems including mobile applications.

Please try again and be aware that you may select more than one answer.

Submit

## Coming next

You’ve worked through some examples highlighting why it’s important to have controls to deter internal fraud. Now we’ll review the different types of external fraud.

Select the Next Topic button to continue to the next topic or select the Home button to return to the home page.

External fraud

## What is external fraud?

External fraud consists of acts committed by clients, suppliers, or other third parties with the intention to deceive or misrepresent in order to obtain financial and/or personal gain; or with intent to deprive another of property/rights or to harm the interests of another.

Fraudulent activities conducted by third parties can create losses for Credit Suisse or our clients, undermine public and investor trust, or damage our reputation.

## Types of external fraud

Types of external fraud that may affect our Bank include:

Vendor and supplier fraud

### Vendor and supplier fraud

When relying on vendors and/or suppliers for the provision of products and/or services, you must be aware of the following red flags of fraud:

- Supplier name is unknown and representatives are not seen
- Supplier address is a residential neighborhood, post-office box, or a mail drop
- Supplier invoices are for services without proof of completion, have limited detail, or exclude usual taxes
- Invoices are inadequate, copied, altered, or forged
- Multiple invoices at or just below threshold levels
- Invalid tax or tax amounts calculated incorrectly
- Invoice lacking detail

Financial statement fraud

### Financial statement fraud

Financial statement fraud occurs where a client provides falsified documentation to misrepresent assets and/or revenues to obtain products and services from the Bank.

Examples of financial statement fraud schemes include recording of fictitious revenue or in improper account periods, improper disclosures, or concealment of liabilities.

Payment fraud

### Payment fraud

Payment fraud is a result of a deliberate deception to convince the authorized payer to execute a payment without client authorization. Cyber-enabled payment fraud uses various forms of cyber fraud as a vehicle to access the funds.

The call-back verification supported by security identifying questions is a control to prevent payment fraud.

Investment fraud

### Investment fraud

The typical investment fraud schemes are characterized by offers of low- or no-risk investments, guaranteed returns, overly consistent returns, complex strategies, or unregistered securities. Examples of investment fraud may include Ponzi schemes, pyramid schemes and a request to pay a processing fee to invest.

Cyber enabled or dependent fraud

### Cyber enabled or dependent fraud

Cyber fraud refers to any type of deliberate deception for unfair or unlawful gain that occurs online, targeting clients and personnel. Oftentimes, cyber fraud is used to execute fraudulent disbursements of funds, securities, and confidential data or material.

Identity theft

### Identity theft

Identity theft is the use of personal non-public information of another individual without authorization with the potential purpose of committing fraud. Identity theft poses a threat to Credit Suisse’s reputation for its due diligence and knowing whom it chooses to conduct business and for safeguarding existing client information. Identity theft is considered a crime in the United States but may be treated differently in other jurisdictions.

Credit Suisse brand misuse

### Credit Suisse brand misuse

Credit Suisse brand misuse refers to a fraud scheme which may involve falsified documents, fraudulent websites and e-mail accounts misusing the Credit Suisse brand or logo. The intention is to make the documents appear as a legitimate investment or financial product to potential investors, banks, or consumers so they invest in the fraud scheme.

## Examples of external fraud

Take a look at these examples of external fraud.

Brand misuse

### Brand misuse

A bad actor advertised a purported Credit Suisse bond investment offer on an external website, where prospective investors were asked to fill in a contact form to receive details of the offer.
A member of public, who was willing to invest in the bond, responded to the fraudulent offer and received a confirmation of agreement with transfer details such as: account number, sort code, amount to transfer; and details of a new Credit Suisse account.
There were no losses to the bank or its clients because of the Credit Suisse brand misuse, however Credit Suisse bears the reputational risks of such fraudulent activity in the market. Additionally, few members of public who invested in such fraudulent investments, believing they were investing with Credit Suisse reportedly lost their funds to such schemes.

Investment fraud

### Investment fraud

A fabricated Credit Suisse-branded bank guarantee for USD 500 million was used in a complex fraud, which targeted the USD 35 billion sovereign wealth fund of a large nation state.

The fraudsters used a complex investment fraud scheme using a purchased shell company and associated business accounts to bolster legitimacy of the investment.

## Scenario 1: Martina receives a client email

Martina, a Relationship Manager receives an email from her client instructing a transfer in favor of his account to another bank.

Martina knows the client well and is aware of a call-back exception that is in place for the funds transfers instructed by the client, in favor of his account to a specific bank. Martina directly enters the payment request into the system which will be released as soon as her colleague Ava approves it.

Two days later, the client contacts Martina to understand why his account was debited when there were no instructions from him to make a transfer.

On investigation, it was revealed that the email of the client was spoofed and the IBAN (International Bank Account Number) that was credited is different than the IBAN on the call-back exception.

## What type of fraud is this?

How do you best describe this scenario?

If you’re not sure, review the key learning points first.

Cyber-enabled payment fraud
Cyber-enabled payment fraud
Legitimate funds transfer request
Legitimate funds transfer request
Vendor fraud
Vendor fraud
None of the above
None of the above

Well done, that is correct. The right answer has been highlighted.

The email Martina received is a red flag for a cyber-enabled payment fraud, which requires deliberate deception to convince Martina as the authorized payer to execute a funds transfer without the client’s authorization. Instances of payment fraud may be cyber-enabled, using various forms of cyber fraud as a vehicle to access the funds. The call-back verification supported by security identifying questions is a control to prevent payment fraud.

In addition, please refer to the AFGMS ID 2.2 which details the pre-transaction verification checks that must be performed for all value changing orders received via non secure client communication channels.

Partially correct. The right answer has been highlighted.

The email Martina received is a red flag for a cyber-enabled payment fraud, which requires deliberate deception to convince Martina as the authorized payer to execute a funds transfer without the client’s authorization. Instances of payment fraud may be cyber-enabled, using various forms of cyber fraud as a vehicle to access the funds. The call-back verification supported by security identifying questions is a control to prevent payment fraud.

In addition, please refer to the AFGMS ID 2.2 which details the pre-transaction verification checks that must be performed for all value changing orders received via non secure client communication channels.

Incorrect. The right answer has been highlighted.

The email Martina received is a red flag for a cyber-enabled payment fraud, which requires deliberate deception to convince Martina as the authorized payer to execute a funds transfer without the client’s authorization. Instances of payment fraud may be cyber-enabled, using various forms of cyber fraud as a vehicle to access the funds. The call-back verification supported by security identifying questions is a control to prevent payment fraud.

In addition, please refer to the AFGMS ID 2.2 which details the pre-transaction verification checks that must be performed for all value changing orders received via non secure client communication channels.

Unfortunately, that’s incorrect.

Take a moment to review these key points before you try again.

The Bank and its personnel are vulnerable to external fraud risks. Key external fraud threats you may encounter include:

Payment fraud
Payment fraud is a result of a deliberate deception to convince the authorized payer to execute a payment without client authorization. Cyber-enabled payment fraud uses various forms of cyber fraud as a vehicle to access the funds.

Cyber fraud
Cyber fraud refers to any type of deliberate deception for unfair or unlawful gain that occurs online, targeting clients and personnel. Oftentimes, cyber fraud is used to execute fraudulent disbursements of funds, securities, and confidential data or material.

Identity theft
Identity theft is a type of fraud committed using the personal non-public information of another individual without their authorization with the potential purpose of committing fraud. Identity theft poses a threat to Credit Suisse’s reputation for its due diligence and knowing whom it chooses to conduct business and for safeguarding existing client information. Identity theft is considered a crime in the United States but may be treated differently in other jurisdictions.

Please try again.

Unfortunately, that’s still not correct.

Review this key point before you try again.

The Bank and its personnel are vulnerable to external fraud risks.

Key external fraud threats you may encounter are cyber fraud, payment fraud, and identity theft.

Payment fraud is a result of a deliberate deception to convince the authorized payer to execute a payment without client authorization. Cyber-enabled payment fraud uses various forms of cyber fraud as a vehicle to access the funds. The call-back verification supported by security identifying questions is a control to prevent payment fraud.

Please try again.

Submit

## What should Martina and Ava have done to prevent the fraud?

What should Martina and Ava have done to prevent the fraud?

Please select all of the correct options. If you’re not sure, review the key learning points first.

Nothing as there is a call-back exception for payments in favor of his account to that specific bank.
Nothing as there is a call-back exception for payments in favor of his account to that specific bank.
Martina and Ava should have checked the email address of the instructing party against the verified email address on record in the relevant CS system.
Martina and Ava should have checked the email address of the instructing party against the verified email address on record in the relevant CS system.
Nothing as the name of the beneficiary is identical to the name of the client.
Nothing as the name of the beneficiary is identical to the name of the client.
Martina and Ava should have carefully checked whether the IBAN number on the payment instruction matches the IBAN number on the exception.
Martina and Ava should have carefully checked whether the IBAN number on the payment instruction matches the IBAN number on the exception.

Well done, that is correct. The right answers have been highlighted.

For orders received via email, in addition to authority and authenticity checks, an identity check is required to verify the email address of the instructing party against the verified email address held on record in the relevant CS systems.

The email address must be carefully checked. Example of spoofed email addresses are below:

Example 1: Genuine john.doe@yahoo.com, Spoofed john.doe@yahoo.ch, Difference Different domains

Example 2: Genuine andrea.baechli@gmx.ch, Spoofed andrea.beachli@gmx.ch, Difference Letters swapped

Example 3: Genuine bbc@aqua.co.uk, Spoofed bbc.aqua.uk@gmail.com, Difference Parts of address moved

For cases where a call back exception exists, all other verification must be conducted. Furthermore, it must be carefully checked whether the IBAN number on the payment instruction fully matches precisely the IBAN number on the exception.

Partially correct. The right answers have been highlighted.

For orders received via email, in addition to authority and authenticity checks, an identity check is required to verify the email address of the instructing party against the verified email address held on record in the relevant CS systems.

The email address must be carefully checked. Example of spoofed email addresses are below:

Example 1: Genuine john.doe@yahoo.com, Spoofed john.doe@yahoo.ch, Difference Different domains

Example 2: Genuine andrea.baechli@gmx.ch, Spoofed andrea.beachli@gmx.ch, Difference Letters swapped

Example 3: Genuine bbc@aqua.co.uk, Spoofed bbc.aqua.uk@gmail.com, Difference Parts of address moved

For cases where a call back exception exists, all other verification must be conducted. Furthermore, it must be carefully checked whether the IBAN number on the payment instruction fully matches precisely the IBAN number on the exception.

Incorrect. The right answers have been highlighted.

For orders received via email, in addition to authority and authenticity checks, an identity check is required to verify the email address of the instructing party against the verified email address held on record in the relevant CS systems.

The email address must be carefully checked. Example of spoofed email addresses are below:

Example 1: Genuine john.doe@yahoo.com, Spoofed john.doe@yahoo.ch, Difference Different domains

Example 2: Genuine andrea.baechli@gmx.ch, Spoofed andrea.beachli@gmx.ch, Difference Letters swapped

Example 3: Genuine bbc@aqua.co.uk, Spoofed bbc.aqua.uk@gmail.com, Difference Parts of address moved

For cases where a call back exception exists, all other verification must be conducted. Furthermore, it must be carefully checked whether the IBAN number on the payment instruction fully matches precisely the IBAN number on the exception.

Unfortunately, that’s incorrect.

Take a moment to review these key points before you try again.

The Bank and its personnel are vulnerable to external fraud risks. Key external fraud threats you may encounter include:

Payment fraud
Payment fraud is a result of a deliberate deception to convince the authorized payer to execute a payment without client authorization. Cyber-enabled payment fraud uses various forms of cyber fraud as a vehicle to access the funds.

Cyber fraud
Cyber fraud refers to any type of deliberate deception for unfair or unlawful gain that occurs online, targeting clients and personnel. Oftentimes, cyber fraud is used to execute fraudulent disbursements of funds, securities, and confidential data or material.

Identity theft
Identity theft is a type of fraud committed using the personal non-public information of another individual without their authorization with the potential purpose of committing fraud. Identity theft poses a threat to Credit Suisse’s reputation for its due diligence and knowing whom it chooses to conduct business and for safeguarding existing client information. Identity theft is considered a crime in the United States but may be treated differently in other jurisdictions.

Please try again and be aware that you may select more than one answer.

Unfortunately, that’s still not correct.

Review this key point before you try again.

The Bank and its personnel are vulnerable to external fraud risks. Key external fraud threats you may encounter are cyber fraud, payment fraud, and identity theft.

Payment fraud is a result of a deliberate deception to convince the authorized payer to execute a payment without client authorization. Cyber-enabled payment fraud uses various forms of cyber fraud as a vehicle to access the funds. The call-back verification supported by security identifying questions is a control to prevent payment fraud.

For cases where a call back exception exists, all other verification must be conducted. Furthermore, it must be carefully checked whether the IBAN number on the payment instruction fully matches the IBAN number on the exception.

Please try again and be aware that you may select more than one answer.

Submit

## Scenario 2: Rahul performs a fraud risk assessment

To move towards a more sustainable global economy, the bank decides to introduce a carbon offsetting compensation program for clients financed for the purchase of yachts or aircrafts. The bank under this program will arrange the purchase of emission reduction certificates to offset the emissions caused by their aircrafts or yachts.

The team of Rahul will administer the compensation process from the calculation of the CO2 emissions based on the information provided by the aircraft’s operator, to the purchase of the certificates from selected and approved vendors, and to the recharge it back to the clients. From the sales proceeds of the certificates, the vendors will use it to finance projects around the world that reduce carbon emissions, protect biodiversity, and / bring benefits to local communities (Green projects).

As part of the New Business review and following AFGMS requirements, Rahul is asked to perform a fraud risk assessment with respect to the carbon compensation program in aviation financing.

## What should Rahul do?

Rahul asks you for help in identifying external fraud scenarios related to this programme.

Please select all of the correct options. If you’re not sure, review the key learning points first.

The external fraud risk is non-existent as the vendors of the emission reduction certificates were reviewed and approved by the bank.
The external fraud risk is non-existent as the vendors of the emission reduction certificates were reviewed and approved by the bank.
The aircraft’s operator could understate the flight hours used to calculate the carbon emissions.
The aircraft’s operator could understate the flight hours used to calculate the carbon emissions.
The risk of external fraud is reduced as the banks takes care of everything from calculating carbon emissions to re-invoicing the customer.
The risk of external fraud is reduced as the banks takes care of everything from calculating carbon emissions to re-invoicing the customer.
The vendors could retain the sale proceeds from the certificates for themselves and not invest in Green projects.
The vendors could retain the sale proceeds from the certificates for themselves and not invest in Green projects.

Well done, that is correct. The right answers have been highlighted.

The carbon offsetting compensation program can present external fraud opportunities which will need to be addressed by the implementation of compensating controls:

- The client can encourage the aircraft’s operator to underestimate the flight hours to help him reduce the cost to offset the client’s carbon emissions.
- The vendors could not follow through on their commitments and retain the sales’ proceeds of the certificates for themselves.
- Bad actors could impersonate the vendors and send invoices with fraudulent payment details.

Also refer to the AFGMS ID 24 which requests the performance of a fraud risk assessment in case of new or changed processes / tools / products / services.

Partially correct. The right answers have been highlighted.

An unsupported leap in profits may indicate financial statement fraud, which Rahul should immediately escalate to his line manager or Compliance for further investigation.

Incorrect. The right answers have been highlighted.

An unsupported leap in profits may indicate financial statement fraud, which Rahul should immediately escalate to his line manager or Compliance for further investigation.

Unfortunately, that’s incorrect.

Take a moment to review these key points before you try again.

The Bank and its personnel are vulnerable to external fraud risks. Key external fraud threats you may encounter include:

Financial statement fraud
Financial statement fraud occurs where a client provides falsified documentation to misrepresent his or her assets and/or revenues to obtain products and services from the Bank. Examples of financial statement fraud schemes include recording of fictitious revenue or in improper account periods, improper disclosures, or concealment of liabilities.

Investment fraud
The typical investment fraud schemes are characterized by offers of low- or no-risk investments, guaranteed returns, overly consistent returns, complex strategies, or unregistered securities. Examples of investment fraud may include Ponzi schemes, pyramid schemes and a request to pay a processing fee in order to invest.

Credit Suisse brand misuse
Credit Suisse brand misuse refers to a fraud scheme which may involve falsified documents, fraudulent websites and e-mail accounts misusing the Credit Suisse brand or logo. The intention is to make the documents appear as a legitimate investment or financial product to potential investors, banks, or consumers so they invest in the fraud scheme.

Please try again and be aware that you may select more than one answer.

Unfortunately, that’s still not correct.

Review this key point before you try again.

The Bank and its personnel are vulnerable to external fraud risks.

Key external fraud threats you may encounter are vendor and supplier fraud, payment fraud, and financial statement fraud.

Fraud committed by clients or parties close to clients are considered as external fraud which are usually committed through the provision of falsified information or documentation.

Please try again and be aware that you may select more than one answer.

Submit

## Coming next

Now that you’ve worked your way through examples of internal and external fraud, let’s look at one final scenario.

Select the Next Topic button to continue to the next topic or select the Home button to return to the home page.

Fraud in review

## Scenario: Jessie receives a payment instruction

It’s a day before the close on a purchase loan from a client, Jessie who works in the Trade Management team receives an email from the client, instructing to change the Standing Settlement Instructions (“SSI”) to a new financial institution to which the proceeds are to be wired.

As the revised SSI is not in the system, Jessie sends the revised instructions to the Operations team to set-up a new SSI.

## Scenario: Lita performs a call-back

Lita who works in the Operations team receives the instructions from Jessie. A call-back must be performed to confirm the authenticity of the new instructions to set-up a new SSI.

Lita follows its procedure and calls the client's switchboard number, which was unsuccessful due to the current work from home situation in the pandemic.

As a result, and on the instructions of Jessie, Lita moves to a Direct Call-back procedure and calls the phone number listed on the email signature of the client. The call back was successful this time and the payment was processed per the revised SSI.

A few days later the client contacts Jessie inquiring about payment of the funds which was still not received. Upon investigation it was discovered that the client's email account had been hacked and that the instruction to change the SSI was fraudulent. Using the client's email domain, the fraudster was able to send the fraudulent payment instructions to Jessie purporting to be the client and bypassing the call-back control.

## What should Lita have done to prevent the fraudulent payment?

What should Lita do?

If you’re not sure, review the key learning points first.

Put the payment on hold as the call-back to the phone number held on file was unsuccessful.
Put the payment on hold as the call-back to the phone number held on file was unsuccessful.
Challenge Jessie on the integrity of the call-back number obtained from the email signature of the client.
Challenge Jessie on the integrity of the call-back number obtained from the email signature of the client.
Escalate the concern to her Line Manager and Compliance for further guidance.
Escalate the concern to her Line Manager and Compliance for further guidance.
All of the above.
All of the above.

Well done, that is correct. The right answer has been highlighted.

The verification of authority for e.g., via call-back or transaction signing is used to verify transfer of funds/assets (i.e., payments, securities) or requests for changes to client or vendor static data. For such requests, an identity check of the instructing party; an authority check i.e., the right to move funds/assets or changes to client/vendor static data and authenticity checks must be performed to determine legitimacy of the instruction details. For further information please refer to the AFGMS.

The call back should not be performed on a phone number received / obtained via an unsecured channel such as email.

Partially correct. The right answer has been highlighted.

The verification of authority for e.g., via call-back or transaction signing is used to verify transfer of funds/assets (i.e., payments, securities) or requests for changes to client or vendor static data. For such requests, an identity check of the instructing party; an authority check i.e., the right to move funds/assets or changes to client/vendor static data and authenticity checks must be performed to determine legitimacy of the instruction details. For further information please refer to the AFGMS.

The call back should not be performed on a phone number received / obtained via an unsecured channel such as email.

Incorrect. The right answer has been highlighted.

The verification of authority for e.g., via call-back or transaction signing is used to verify transfer of funds/assets (i.e., payments, securities) or requests for changes to client or vendor static data. For such requests, an identity check of the instructing party; an authority check i.e., the right to move funds/assets or changes to client/vendor static data and authenticity checks must be performed to determine legitimacy of the instruction details. For further information please refer to the AFGMS.

The call back should not be performed on a phone number received / obtained via an unsecured channel such as email.

Unfortunately, that’s incorrect.

Take a moment to review these key points before you try again.

The Bank and its personnel are vulnerable to external fraud risks. Key external fraud threats you may encounter include:

Payment fraud
Payment fraud is a result of a deliberate deception to convince the authorized payer to execute a payment without client authorization. Cyber-enabled payment fraud uses various forms of cyber fraud as a vehicle to access the funds.

Cyber fraud
Cyber fraud refers to any type of deliberate deception for unfair or unlawful gain that occurs online, targeting clients and personnel. Oftentimes, cyber fraud is used to execute fraudulent disbursements of funds, securities, and confidential data or material.

Identity theft
Identity theft is a type of fraud committed using the personal non-public information of another individual without their authorization with the potential purpose of committing fraud. Identity theft poses a threat to Credit Suisse’s reputation for its due diligence and knowing whom it chooses to conduct business and for safeguarding existing client information. Identity theft is considered a crime in the United States but may be treated differently in other jurisdictions.

Please try again.

Unfortunately, that’s still not correct.

Review this key point before you try again.

The Bank and its personnel are vulnerable to external fraud risks. Key external fraud threats you may encounter are cyber fraud, payment fraud, and identity theft.

Payment fraud is a result of a deliberate deception to convince the authorized payer to execute a payment without client authorization. Cyber-enabled payment fraud uses various forms of cyber fraud as a vehicle to access the funds. The verification of authority for e.g., via call-back or transaction signing is used to verify transfer of funds/assets (i.e., payments, securities) or requests for changes to client or vendor static data. For such requests, an identity check of the instructing party; an authority check i.e., the right to move funds/assets or changes to client/vendor static data and authenticity checks must be performed to determine legitimacy of the instruction details. For further information please refer to the AFGMS.

For cases where a call back cannot be performed, the payment must be put on hold and escalated to the Line Manager / Compliance officer for further guidance.

Please try again.

Submit

## Let’s recap

Before we conclude, take a moment to reflect on the scenarios you encountered throughout the course.

Select the arrow button to find out more.

### Personnel collusion

Yannick’s line manager integrated ESG targets in his performance objectives/ definition of his annual bonus payment. Yannick decides to falsify the term-sheet of an Equity Fund, backed by traditional heavy industry issuers in the Emerging Markets. By introducing ESG compatible disclosures, the product will fit the ESG metrics relevant to his performance objective and contribute to achieving his bonus targets. To put this plan in motion, Yannick poaches the support of his long-time assistant in return of a share of his bonus payment.

### Lee makes a transfer

In a rush to leave for her doctor’s appointment, Lee has transferred money to a wrong beneficiary and committed an internal fraud when she forged orders from other unrelated clients to rectify the error.

### Syed examines a request

While approving expenses reimbursement for his department’s Investment Consultants, Syed notices that Jamie was on a client meeting during Block Leave. This is a red flag for Internal Fraud and a violation the Block Leave policy.

### Martina receives a client email

Martina received a fraudulent payment instruction from someone pretending to be the client to obtain money fraudulently. This constitutes cyber-enabled payment fraud and should be immediately escalated to the line manager and Compliance.

### Rahul performs a fraud risk assessment

The client by asking his aircraft operator to understate the flight hours could commit an external fraud as this will help him to reduce his cost to offset the carbon emissions.

### Lita performs a call-back

Lita performs a direct call back on a phone number provided by Jamie. The call-back was successful, and a new SSI was set-up for Jamie to perform the funds transfer to the client. Lita should have challenged the authenticity of the call-back number obtained by Jessie from the email signature of the client.

## In summary

Here is a summary of the key points covered in the course.

You can also download and print the Escalation and Identifying Potential Fraud Course Summary.

What to escalate, and when

### What to escalate, and when

What?
Escalate unusual incidents or concerns that could lead to financial loss for Credit Suisse/our clients or could cause other significant, non-financial, or reputational harm to our clients, personnel, Credit Suisse, and the integrity of the markets.

When?
Escalate without delay and in an effective manner. Early recognition and resolution of unusual incidents or concerns is key to mitigating risks.

Remember: See Something? Say Something.

Escalation channels

### Escalation channels

Escalate unusual incidents or concerns to any of the following parties, with the exception of incidents involving suspected breaches of US Cross Border Policy (P-00025) and/or FATCA Policy (GP-00085):

1. Your line manager as your primary contact (unless inappropriate to do so) or other appropriate management or senior management.
2. Compliance, Human Resources, General Counsel.
3. The Credit Suisse Integrity Hotline (phone) or Integrity Line (web) (where anonymous reporting is available, if permitted by law).

When it is inappropriate to involve your line manager (e.g., he/she may be involved in the incident or has failed to address the incident appropriately) or you are uncomfortable raising the matter with him/her, you must escalate to another party. In such situations, you must not escalate to individuals who report to your line manager, directly or indirectly, or where there is otherwise a conflict of interest.

Anonymous reporting and confidentiality

### Anonymous reporting and confidentiality

To the extent permitted by applicable laws and regulations, you may choose to remain anonymous when escalating an unusual incident or concern via the Credit Suisse Integrity Hotline (phone) or the Integrity Line (web).

Any incidents or concerns should be escalated freely and without threat of retaliation. Credit Suisse prohibits any retaliatory action against anyone for raising concerns or questions.

All contacts and investigations are treated as confidentially as possible, consistent with the need to investigate and address the incident or concern, subject to applicable laws and regulations and in accordance with Credit Suisse requirements for the treatment of confidential information.

Types of internal fraud

### Types of internal fraud

Often, internal fraud is committed by one person acting alone within the Bank and can be identified through suspicious behaviors, but it can occur through the collusion between Bank personnel.

Types of internal fraud include:

- Unauthorized trading
- Unauthorized activity
- Unauthorized funds and assets transfers
- Data theft
- Expense reimbursement fraud

Controls to deter internal fraud

### Controls to deter internal fraud

Controls we use in the Bank to deter internal fraud include:

- Block leave
- Segregation of duties
- Call-back verification

Types of external fraud

### Types of external fraud

The Bank and its personnel are vulnerable to external fraud risks, such as:

- Vendor and supplier fraud
- Financial statement fraud
- Payment fraud
- Investment fraud
- Cyber fraud
- Identity theft
- Credit Suisse brand misuse

## Conclusion

You have completed this course and can now close the module and exit.

#

As a large organization, Credit Suisse is potentially exposed to fraud, triggered by internal personnel or external parties.

At Credit Suisse, Fraud is defined as:

- An intentional act, misrepresentation or omission of fact committed to obtain an unfair financial or personal gain in favor of the fraudster or a third party, and
- An act intended to deceive others by unjustifiably claiming or being credited with accomplishments or ownership, or with intent to deprive another of property or rights or to harm the interests of another.

Internal Fraud are acts committed by personnel to defraud Credit Suisse or its clients; whereas External Fraud are acts committed by clients, suppliers or other third parties to defraud Credit Suisse or its clients.

Do you understand the impact of Fraud risk to organizations?

Source: Report to the Nations; Association of Certified Fraud Examiners (ACFE).

In this brief course, you will focus on why escalation is important and your responsibilities in escalating unusual incidents or concerns, such as fraud, that pose or may pose significant risks, through the appropriate channels.

You will learn about the various types of fraud, and the controls we use to deter fraudulent activities. In the case studies, you will identify red flags and what you must do to detect and escalate fraud.

To complete this course, there is no final test, but you will have to identify the correct behavior in each scenario.

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