Fraud fighting : from process analysis to big data processing. November 2015

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1 C1 Fraud fighting : from process analysis to big data processing

2 SOCIETE GENERALE EQUIPMENT FINANCE : PRESENT IN 35 COUNTRIES, FINANCING DIVERSIFIED ASSETS & PRODUCTS WHICH SOMETIMES SUDDENLY DISAPPEAR Transport Industrial Equipment High tech Transport Trucks Commercial vehicles Busses Machinery Machine tools Printing machines Packing machines IT Hardware Software IT Solutions (HW+SW+Serv) Handling Forklift trucks Handling equipment Agricultural Machinery Tractors Harvesters Aviation and Marine Aviation Shipping Construction machines Loaders Excavators Earth moving equipment Real Estate Office building Eco-friendly equipment Office equipment Copiers & Printers Telecommunication Office Equipment Medical equipment Medical equipment Laboratory equipment P.2

3 3 IT S WELL-KNOWN : FRAUDS ONLY STRIKE OTHERS! Not only because nobody likes to communicate on its failures. but also because frauds in the leasing industry are low-occurrence events, even though very costly. CREDIT LOSSES In a nutshell, not all sales and credit persons have experienced a fraud FRAUD LOSSES and until you did not experience a fraud loss, you re not so convinced it might really happen to you. not speaking of the hundreds of different loss types that exist, depending the country, the process, the asset, THE ONLY REMEDY : TRAINING AND SHARING on fraud types, cases and corrective measures all training support are welcome Circulate reports on existing fraud cases to inform all entities about new fraud schemes Share experiences to help local people to identify potential risks in the areas of fraud and strengthen their monitoring Circulate best practices and adapt action plan against fraud Train all involved staff possibly through practical cases FORMALIZE ANTI-FRAUD INSTRUCTIONS OR GUIDELINES IN EACH ENTITY to ensure adequate, locally adjusted implementation SPECIFICALLY WHEN DEVELOPPING NEW PRODUCT Necessary validation process for new products helps identify and prevent operational risks, including fraud, related to a new product or a new activity June 2015 P.3

4 WE NEED MORE FRAUD CASES! Because fraud cases are significantly less numerous than in retail banking industry or consumer finance, it is key to ensure completeness of fraud collection, which is anyway required by regulator in a number of countries In the fight against fraud, the value of a fraud is not commensurate with the fraud amount. The little fraud will someday be duplicated into a real big loss if nothing is done in the meantime. Based on a sufficiently wide data-basis, it is possible to implement a statistical approach, requiring the following steps: Enrich data-basis with fraud flags and fraud types Tap other external data ressources So before having to face the iceberg, you d better care for smaller icecubes which is not always easy to convince people about, since they generally prefer to insist on their successes rather than their failures Systematic and precise loss collection and pattern analysis is key to enrich the size of available data-basis and ensure succesful data-mining. Try to identify some statistical patterns, related to frauds Develop a fraud probability rating leading to increasing preventive on-site checks on declining the credit decision The efficiency of such big data approach in credit cards frauds or wire transfers is impressive and a model for the leasing industry. June 2015 P.4 4

5 AGAINST FRAUDS, YOU NEED HELPING HANDS Because they know their clients, our partners are our first defense line against fraud. Partnering goes beyond commercial issues and include credit and fraud issues: A specific focus on defaults and claims / disputes with the vendor s customers is critical: In the presence of a significant deterioration in these indicators, an analysis of cases may reveal fraud and allow to quickly stop or amend the relationship with the vendor SGEF entities should develop reporting tools on these aspects ; the vendor review should have a specific focus on these aspects Dialogue with vendors on fraud and its awareness on this issues : Training vendors sales person on these issues can be an option Cristal clear communication channels are necessary to avoid fraud risk with the vendor and its clients. Periodic review of partnership is also desirable in this respect : Collecting and sharing relevant data is an obvious prerequisite in this respect This is still more important for billers Intermediaries. A specific Billing & Collection Agreement is a must. Being an undisclosed financing partner create more fraud risk, especially in case the intermediaries is billing & collecting because in-house controls are then limited. P.5 5

6 EXTERNAL FRAUDS MAY REQUIRE INTERNAL PROCESS REVIEWS External frauds are often facilitated by some internal execution errors or process weaknesses Reviewing the whole process is necessary to adjust the controls to the following : 1. Local regulations 2. Internal and external Tools 3. Local organization 4. Local specificities (be it in regulations or market practices), But it also requires to define detailed standard process to better analyze the gaps CONTRACT ACQUISITION P0 - Develop Vendor Relationship P1 - Approach customer P2 - Make Credit Decision P3 - Close deal CONTRACT MANAGEMENT P4 - Activate contract P5 - Admin. contracts & services P6 - Manage contracts & serv. changes P7 - Manage service events (claims,...) P8 - Collect overdue amount P9 - Recover and remarket Such systematic approach of process allows : to better position and adjust internal controls in the processes to comply with some regulator s requirements but also to beef up operational efficiency. The review should also impact existing set of policies and procedures: Risks procedures, Credit Policies Know-Your-Counterparts procedures P.6 6

7 7 FRAUDS MOSTLY OCCUR DURING FINANCING LIFE, IN LINE WITH CREDIT RISKS: ASSET EMBEZZLEMENTS are situations where there was no fraudulent intent at financing origin. The fraudulent act occurs during the life of the contract, mostly because of a deteriorating creditworthiness and tighter financing. The customer sells assets purely to raise cash The asset embezzlement is often discovered at the time of recovery after termination of the contract. Sometimes, the fraudster disappears simultaneously with equipment Obviously mobile and valuable assets that can be easily moved and remarketed, such as trucks, construction equipments, mobile cranes, are more likely to be resold Such difficult financial situations may also lead to different, less costly operational losses, where the client saves maintenance and insurance costs related to our asset, not complying with its contractual commitments Still more risks when the introducer is responsible for billing and collecting payments from customers P.7

8 FRAUD DURING FINANCING LIFE: CORRECTIVE ACTIONS Traditional monitoring of client s financial situation of the during the life of a contract Periodical update on customer creditworthiness and specific follow-up of deteriorated credit situation in case of first past dues is key in our industry even though it is not always easy to obtain updated financials from clients not having financed new equipment in the meantime Typical preventive measures (obviously in connection with soft recovery): Verify the presence of the customer at the address indicated by a registered mail or a phone call Update Know Your Customer Implement on site checks depending on thresholds defined by country and/or client creditworthiness), with internal or external staffs Alternatively there are some tracking electronic devices such as GPS that may help to locate the assets but at a cost and with some technical/reliability limits, depending on the country, the type of equipments Ask for the last maintenance invoices and annual insurance certificate. It is also a good way not only to check that the asset is still with the client, but that it is properly maintained and insured Accelerate repossession of assets for terminated contracts Study according to local laws and practices which are the possibilities to accelerate the contract termination with a view to repossess the equipment Prioritize recovery of mobile equipment with a market value, as compared to other assets P.8 8

9 FRAUDS AT FINANCING ORIGIN WITH A CREDIT BACK-GROUND: DOUBLE FINANCING Main characteristics: Initiated by the lessee after its financial situation has deteriorated: the lessee tries to get additional financing leveraging on existing assets even if they are already mortgaged or leased. Sale & Lease Back (SALB) very risky, including «technical Sale and Lease Back» where equipment is temporarily purchased by client instead of by the lessor as is the standard pattern. Specific attention is required. Primary diligence is to check that the asset considered for financing is free from any mortgage, lease, lien, which brings back to execution errors All above aspects very much depend from local regulations and processes Corrective actions: The most reliable and effective means of detecting and avoiding double financing seems to be checking the asset to be financed with an asset data base, either official or promoted by the leasing industry (Cf appendix).. Improve internal processes in accessing to official registers Demand evidences that the assets have not been financed beforehand and challenge their accuracy/authenticity Develop specific asset register: Data-basis specific to the industry in case no official register exists. Such data base is in place in Germany P.9 9

10 ORGANIZED FRAUDS AT FINANCING ORIGIN : PERMANENT INNOVATION TROPHY Main characteristics: Non-existent or non-compliant asset Premeditated and organized fraud Initiated by the lessee often in collusion with the supplier of the asset and/or business partners / intermediates that play a key role in business sourcing for the transaction, though sometimes the lessee is also the victim of the organized fraud. Organized fraud is very related to the financed object: be it equipment with a clear secondary-market value or equipment with limited secondary value. Typical fraud occurs when sophisticated equipment is not described accurately in the initial documents and then turn out to be significantly different than what had been imagined. Increased risk in case of : big fleet of assets where frauds are easier to conceal, leased assets are moving from one place to another, very cyclical activity. Starting from traditional forged documents, frauds are becoming more sophisticated, with faked paper and even electronic documents and hence more difficult to uncover. Frauds in collusion with third parties is one of the most difficult fraud scenario to be identified and potentially very costly. As you know, gentlemen, innovation at the point of sale accounts for our competitive edge. P.10 10

11 FRAUDS AT FINANCING ORIGIN: CORRECTIVE ACTIONS ARE NOT EASY Controls on the client Check the consistency of the financed asset and client activity in line with Know-Your-Customer (KYC) process: KYC on suppliers or intermediaries are a must, with a specific attention to cross-border supplier transactions Perform more thorough checks on recently incorporated companies. Check for possible personal connections between the client company and the Vendor/or Intermediate that may hint at possible complicity for a fraud scheme. Sharing such information creates added value for the leasing industry but also probably a few legal problems. At least, it is worth following markets rumors. Strengthened controls on financing operations before contract enforcement Demand a detailed description of equipment specification Strengthen consistency checks between the sale price and its market value, Attend or have a reliable third party attend and photography the asset delivery though it is costly and therefore to be preferred in the more risky cases. Controls on documentation Demand evidences that the client registration documents and financials are genuine and accurate Call the suppliers and manufacturers to corroborate that the received invoices are not fake, that they were paid, that the asset/serial number exists Systematically file a criminal charge More for the possible deterent effect and to prevent the fraudsters from going on Existence of blacklists of physical persons : Useful but legally touchy, especially if exchanged P.11 11

12 SOME NEW TRENDS: CROSS-BORDER TRANSACTIONS, SOCIAL ENGINEERING More cases where fraud is facilitated because of foreign dimension in transactions Non-existing foreign supplier, introduced by local client Most of the embezzled assets are sold abroad, which makes recent companies having strong foreign shareholding connections more risky Corrective actions: Check reinforced on the main representative if foreigner, and on financial statements Revisit local procedures regarding imported equipment, KYC procedure, Raise staff awareness on such transactions. Some cases of Social Engineering: A cyber fraudster manages to interface between a client and its equipment supplier, introducing itself as the supplier and providing an erroneous account number for wire transfer. The fraudster first collected a lot of confidential information through a social engineering approach: The invoice is forged by the fraudster with a wrong settlement account. Even the phone number on the confirmation was also the fraudster s phone number The loss for the client is so important for a big equipment that it defaults. Such hacking could also actually happen to the lessor for direct payments, though this step in the process is hopefully very much scrutinized. Corrective actions: Inform not only Sales and Credit but also clients in case the payment to supplier goes to them. Raise clients awareness on the importance to check the settlement account, not only by phone. P.12 12

13 13 CONCLUSION Common sense and training / education as important as systematic tools and procedures Sharing information does add value : information is one of the few asset that you can share without loosing part of it Organized exchange of information between leasing industry players might make sense and has already proven to be efficient P.13

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