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A Fraud Prevention Policy sets clear rules and procedures to protect Swiss organizations from financial crimes, scams, and dishonest behavior. It outlines specific steps employees must take to spot and report suspicious activities, while ensuring compliance with Swiss anti-fraud regulations and the Federal Act on Combating Money Laundering.

This policy helps companies create strong internal controls, define staff responsibilities, and establish reporting channels for concerns. It typically includes guidelines for handling sensitive data, managing vendor relationships, and conducting regular risk assessments. Swiss businesses use these policies to maintain their reputation, protect assets, and meet their legal obligations under cantonal and federal oversight.

Consider implementing a Fraud Prevention Policy when your Swiss organization faces heightened risks of financial misconduct or needs stronger internal controls. This becomes especially important during major organizational changes, after detecting suspicious activities, or when expanding into new markets or business lines that carry additional fraud exposure.

Banks, insurance companies, and financial service providers need these policies to comply with FINMA regulations and Swiss anti-money laundering laws. The policy proves particularly valuable when onboarding new employees, updating security protocols, or responding to industry-specific fraud threats. Many organizations also use it to protect their reputation and maintain trust with stakeholders and regulatory authorities.

• Comprehensive Corporate Policy: The most thorough version, covering all fraud types and including detailed procedures for Swiss multinationals
• Department-Specific Policy: Tailored for specific units like finance or procurement, with focused controls and reporting chains
• SME-Adapted Policy: Streamlined version for small and medium enterprises, meeting basic regulatory requirements while remaining practical
• Financial Services Policy: Enhanced controls meeting FINMA requirements, with specific provisions for banking and insurance sectors
• Digital Fraud Policy: Focused on cybersecurity and online transaction risks, particularly relevant for e-commerce and fintech companies

• Board of Directors: Approves and oversees the Fraud Prevention Policy, ensuring it aligns with Swiss corporate governance standards
• Compliance Officers: Draft, maintain, and update the policy while monitoring its effectiveness across operations
• Department Managers: Implement policy controls and ensure staff training within their units
• Internal Audit Teams: Test compliance, conduct investigations, and recommend policy improvements
• All Employees: Must understand and follow the policy's guidelines, reporting suspicious activities through proper channels
• External Auditors: Review policy effectiveness as part of broader compliance assessments

• Risk Assessment: Map your organization's specific fraud vulnerabilities and current control gaps
• Regulatory Review: Identify applicable Swiss laws, FINMA guidelines, and industry-specific requirements
• Internal Structure: Document your reporting lines, roles, and responsibilities for fraud prevention
• Control Mechanisms: List existing internal controls and areas needing enhancement
• Stakeholder Input: Gather feedback from department heads on practical implementation challenges
• Documentation Systems: Define how incidents will be recorded and investigated
• Training Needs: Plan how staff will learn and apply the new policy effectively

• Purpose Statement: Clear objectives and scope of the fraud prevention program under Swiss law
• Legal Framework: References to relevant Swiss regulations, FINMA guidelines, and anti-money laundering laws
• Reporting Procedures: Detailed whistleblowing channels and incident reporting processes
• Control Measures: Specific internal controls and monitoring mechanisms
• Employee Obligations: Clear statements of staff responsibilities and expected conduct
• Investigation Protocol: Steps for handling suspected fraud cases
• Data Protection: Compliance with Swiss data protection requirements
• Enforcement Measures: Consequences for policy violations and disciplinary procedures

A Fraud Prevention Policy differs significantly from a Due Diligence Policy in several key aspects, though both play crucial roles in Swiss corporate risk management. While fraud prevention focuses specifically on detecting and preventing dishonest activities, due diligence covers broader business verification and risk assessment processes.

• Scope and Purpose: Fraud Prevention Policies target specific fraudulent behaviors and schemes, while due diligence covers comprehensive business partner and transaction assessments
• Implementation Timing: Fraud prevention operates continuously throughout operations, whereas due diligence typically occurs before major transactions or relationships begin
• Legal Requirements: Fraud policies align with Swiss criminal law and FINMA regulations, while due diligence policies follow broader commercial and regulatory frameworks
• Internal Controls: Fraud policies emphasize detection and reporting mechanisms, while due diligence focuses on verification and documentation procedures